Child Protection and Safeguarding Policy and Procedures

Author information

Produced by: Director of Care and Support Services
Date created: February 2016
Approval by: Board of Trustees
Last updated: April 2025
Updated by: Head of Safeguarding
Audit date: November 2026

Version history

January 2026

Updated changes associated with Keeping Children Safe in Education 2026

April 2025

Updated changes associated with Keeping Children Safe in Education 2024

February 2024

Section on Working Together to Safeguard Children 2023 added.

December 2023

Section on Filtering & Monitoring at InFocus added.

June 2023

Moved Safeguarding Team to Safeguarding page

Moved Key Contacts to Safeguarding page

March 2023

Updated Safeguarding Team – Kate Kingdom, Lisa Buchan and Kelly Jones added to Designated Safeguarding Persons.

Changed year date for Working Together to Safeguard Children to 2022.

Removed bullet error from Our Safeguarding Aims.

Under child-on-child abuse section, replaced peer on peer abuse with child on child abuse.

Changed date of Keeping Children Safe in Education to 2022.

Under COVID-19 safety measures, ‘and beyond’ was added to the introduction to the four key principles to show we continue to take measures to keep people safe from COVID.

September 2022

Replaced terminology peer-on-peer abuse to child-on-child abuse in accordance with KCSIE 2022.

Updated definition of abuse in accordance with KCSIE 2022.

Update on disclosure of abuse in accordance with KCSIE 2022.

Document Sexual Violence and Sexual Harassment Between Children removed in accordance with KCSIE 2022.

New definition of Domestic Abuse in accordance with KCSIE 2022.

Trustee structure amended to reflect changes.

May 2022

Updated to reflect changes to safeguarding team

September 2021

Updated to reflect Keeping Children Safe in Education 2021, change of name and inclusion of COVID 19 guidance.

July 2021

Updated to reflect change of name to InFocus.

June 2021

Katherine Weir joins the safeguarding team

March 2021 Update

If an allegation concerns the Director of Education then this must be passed directly to the CEO.

February 2021 Update

The definition of Safeguarding and promoting the welfare of children now includes preventing impairment of children’s mental health and development (in addition to physical health and development). This is reflected throughout the document (e.g. that mental heal problems can, in some case, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

The Designated Safeguarding Lead (DSL)’s responsibilities now also includes:

• Liaise with the three safeguarding partners (LA, CCG and Chief Officer of Police) and work with other agencies in line with Working Together to Safeguard Children and NPCC – When to call the police.

Policy text

The introduction to the policy text references that Extra-familial harms (contextual safeguarding) means children can be vulnerable to multiple harms.

Specific issues

Upskirting and abuse within intimate relationships have been added

Definitions of extremism and terrorism have been included

Online safety/internet use includes three classifications of risk.

December 2020 Update

Rowan White joins the Safeguarding Team (replacing Sue Stagg)

September 2020 Updates

No changes to the content, other than to bring document in line with new policy templates. Audit in October 2020 is still required.

Key Information

If you see, suspect or discover something that concerns you then you should:

Recognise

Recognise the concern and make a note of what you have seen or heard.

Report

Report all concerns to a member of the safeguarding team immediately by either directly speaking to a member of the safeguarding team or calling the safeguarding team Ext 7000 or 07980 735731 (24 hours a day, 7 days a week!). Do not delay!

Record

After contacting a member of the safeguarding team record your concern as a Safeguarding log.

Key Contacts

An up-to-date list of key contacts can be found on the Safeguarding page.

Safeguarding Team

An up-to-date list of the Safeguarding Team can be found on the Safeguarding page.

Introduction

Here at InFocus our first duty is to keep our children and young people safe.  We are committed to safeguarding and promoting their welfare and aim to create a culture of vigilance. This safeguarding responsibility includes when placing a pupil with an alternative provision provider.

To do this we have put in place lots of ways to make it easy for young people, parents, staff and visitors to talk to us about any concerns they have.  This policy sets out how we approach our safeguarding responsibilities and what to do if you are worried about a young person at InFocus.

Young people with visual impairment often find it difficult to make friends easily with their peers as they do not see well enough to interpret complex social cues and body language.   They can misunderstand social settings and need to develop a secure grasp of social conventions and norms.  People around them recognise their vulnerability and can respond in a protective manner, so that to facilitate independence we must strongly encourage the young person to challenge others’ views, actions and motivations.  Learning difficulties can increase vulnerability with young people working hard to fit in, being manipulated, or finding it difficult to form healthy relationships. Away from home young people meet a lot more adults, so we need to make extra efforts to keep them safe.

To respond to these challenges we work to make our site safe, carefully select our staff and build a culture where it is right to talk about your worries and concerns. No single person, particularly when young people have complex needs, can have a full picture of a young person’s needs or circumstances and if young people and their families are to receive the right help at the right time, everyone who comes into contact with them has a role to play in identifying concerns, sharing information and taking prompt action.

Due to their day-to-day contact with young people, InFocus staff are uniquely placed to observe changes in young people’s behaviour and the outward signs of abuse.  Young people may also turn to a trusted adult at InFocus when they are in distress or at risk.  It is vital that InFocus staff are alert to the signs of abuse and understand the procedures for reporting their concerns.  The school will act on identified concerns and provide early help to prevent concerns from escalating.

Our safeguarding team is led by the Designated Safeguarding Lead, Mark Hutchinson. He has worked in both adults’ and children’s settings so has a good understanding of what our young people need. You can speak to Mark or any of the members of the Safeguarding Team using the details on the back page of this document.

The key message in this document is to share your worries or concerns, and for us to work together to think through what needs to happen with the support of other agencies in Devon.

Being open and honest is the right thing to do, and whilst this is scary at times our firm commitment is to support anyone who raises a concern and ensure you are not left to worry alone.

If you have any comments about this document, or you want to talk to me in confidence about a concern, please do not hesitate to get in touch.

Jane Bell, CEO

Scope     

This policy applies to all staff, trustees, contractors, visitors, volunteers and other stakeholders of InFocus both on campus and off campus (including extended activities and checking of external providers such as residential camps) whenever someone has a concern about a young person.

This policy does not discriminate against any party based on gender, race, disability, sexual orientation, religion or beliefs and meets InFocus’s commitment to equality and diversity. We recognise the extra efforts that will be needed to build trust and enable communication for young people experiencing discrimination or where harm and abuse occurs.

Where abuse, neglect, exploitation, or wider safeguarding issues are suspected, InFocus recognises it is responsible for identifying, communicating and ensuring action is taken on the concern.  ​​​​​​​

We do not undertake child protection investigations.

We are responsible for keeping all young people safe on any activity that InFocus are involved in, regardless of who the young person is. Even if the activity is being run by another organisation using the InFocus centre, we need to make sure that they are committed to safeguarding children.

Who this document focuses on

This document focuses on the protection of young people at InFocus, meaning anyone under 18. Young people over the age of 18 come under the Adults at Risk Protection Policy, although many of the first steps are the same; weighing up your concern and talking to the relevant people.

Our young people are a mixed group so this policy should be read in conjunction with the Adults at Risk Protection Policy.

Safeguarding Definitions

The definitions below are all from Working Together to Safeguard Children 2023. These definitions are used by all professionals working with young people:

Child

Anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate, does not change his/her status or entitlements to services or protection.

Safeguarding and promoting the welfare of children

Defined for the purposes of this guidance as:

• protecting children from maltreatment
• preventing impairment of children’s mental and Physical health or development
• ensuring that children are growing up in circumstances consistent with the provision of safe and effective care
• taking action to enable all children to have the best life chances.

Child protection

Part of safeguarding and promoting welfare. This refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.

Abuse

A form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children.

Keeping Children Safe in Education

As an education provider, InFocus is required to follow statutory guidance from the government.

A key document is Keeping Children Safe in Education and all staff (regardless of whether you are employed or a volunteer with InFocus) are required to have read and understood at least part 1 and annex A of this guidance. (Read more: Keeping Children Safe in Education)

Working Together to Safeguard Children 2023

Chapter 1: A Shared Responsibility: Successful outcomes for children depend on strong multi-agency partnership working across the whole system of help, support and protection, including effective work from all agencies with parents, carers and families.

Chapter 2: Multi-Agency Safeguarding Arrangements: Strengthening how local multi-agency safeguarding arrangements (local authorities, integrated care boards and the police) work to safeguard and protect children locally, including with relevant agencies.

Chapter 3: Providing help, support and protection: How organisations and agencies help safeguard and protect children and their families through a combination of Early help, Safeguarding and promoting the welfare of children and Child protection.

Other Documents

Other relevant documents which inform our work include:

• What to do if you are worried a child is being abused (2015)
• Children missing education (2016)
• Safeguarding disabled children (2009)
• Devon Children and Families Partnership procedures
• Prevent duty guidance (2015)
• Children Act 1989 and Children Act 2004
• Working Together to Safeguard Children 2023

They are updated regularly and we will let you know when this happens.

Responsibilities

Our Safeguarding Aims

We provide a caring, positive, safe and stimulating environment that promotes the social, physical and moral development of every young person. We aim to enable young people to develop high self-esteem, confidence, supportive friends and clear lines of communication with a trusted adult to help to prevent abuse.

InFocus will therefore:

• Support the young person’s development in ways that will foster security, confidence and independence.  Young people will be taught about safeguarding, recognise when they are at risk and how to get help when they need it.
• Provide an environment in which children and young people feel safe, secure, valued, respected, confident and know how to approach adults if they are having difficulties, believing they will be effectively listened to.
• Raise the awareness of all staff / volunteers of the need to safeguard young people and of their responsibilities in identifying and reporting possible cases of abuse, both on and off the campus.
• Provide a systematic means of monitoring young people known or thought to be at risk of harm, ensuring that INFOCUS contribute to assessments of need and support packages for those young people.
• Emphasise the need for effective and appropriate communication between all members of staff / volunteers, parents / carers and external agencies in relation to safeguarding young people.
• Ensure that young people know that there are adults within InFocus who they can approach if they are worried or are in difficulty.
• Maintain a structured procedure within InFocus; this will be followed by all members of INFOCUS in cases of suspected abuse, including incidents that have happened in the wider community.
• Develop and promote effective working relationships with all other agencies involved in safeguarding young people.
• Ensure that all adults within InFocus who have access to young people have been checked as to their suitability, including verification of their identity, qualifications and receipt of a satisfactory enhanced DBS (Disclosure and Barring Service) certificate and, where relevant, a barred list check. A single central record of vetting checks is kept.
• Notify the Multi-Agency Safeguarding Hub (MASH) timely, as soon as there is a significant concern.
• Provide continuing support to a young person (about whom there have been concerns) who leaves INFOCUS by ensuring that such concerns are forwarded under confidential cover to the Designated Safeguarding Lead (DSL) at the young person’s new education establishment as a matter of urgency.
• Notify the Local Authority (LA) of a young person who is removed from statutory education and their intended destination (if known).

All employees, volunteers and trustees

• Complete child protection and safeguarding training (and regular updates)
• Keep up to date with this policy and understand how it makes young peoples lives safer
• Keep young people safe in your care and follow up any issues in line with this policy
• Keep young people’s information confidential, but ensure you pass on concerns
• Know what to do if you have concerns about another staff member’s actions
• Always follow up concerns, until you have a good reason not to be worried anymore
• Support social workers in undertaking statutory assessments of a young person’s needs

Designated Safeguarding Lead (DSL) 

• Make appropriate timely referrals to appropriate Social Care Services and follow these up
• Ensure INFOCUS works with other agencies as necessary and seeks advice from MASH (Multi Agency Safeguarding Hub) as required
• Ensure work with children includes information on how they can keep themselves safe
• Liaise with the three safeguarding partners (LA, CCG and Chief Officer of Police) and work with other agencies in line with Working Together to Safeguard Children and NPCC – When to call the police.
• Provide a termly report for the Board of Trustees detailing any changes to the policy and procedures; training undertaken by all staff and Trustees; findings and recommendations of reviews and other relevant issues
• Ensure child protection procedures are up to date and followed within INFOCUS
• Fulfil all strategic responsibilities as described in KCSIE annex B

If for any reason the DSL is unavailable, a number of trained Deputy DSLs have been identified who will act in their absence.

Safeguarding Team (the DSPs) 

There is always a member of the safeguarding team on call to provide advice.  They will either take action on concerns, or ensure the relevant manager takes action. Members of this team will have completed the relevant multi-agency training (Devon Level 3). Members of the team will be the first point of contact regarding any safeguarding incident / disclosure and will liaise with MASH / out of hours service promptly as necessary.  Team members will attend strategy meetings and undertake early help assessments as required.

InFocus Executive and Trustees 

The executive will appoint a Designated Safeguarding Lead and deputy/ies, and monitor the effectiveness of their work. They will ensure there are sufficient resources to keep young people safe. The CEO will liaise with the Local Authority Designated Officer (LADO) where an allegation is made about a member of staff. The Executive Team will make a referral to the Disclosure and Barring Services (DBS) or regulatory bodies as appropriate.

Trustees will approve this policy, ensure it aligns to the Devon Children & Families Partnership (DCFP) policies and ensure it is effective. In particular, Trustees ensure safer recruitment processes are followed.  The Chair (or a delegate) will take the lead if an allegation is made against the CEO.

Implementation

This policy is considered mandatory reading for all staff. Training and assessment is conducted on a regular basis (including in regular supervisions) to ensure that all members of staff are aware of the policy and its contents.

Policy Text

Introduction

It is the responsibility of all adults to act to prevent or stop abuse to children and adults at risk. Extra-familial harms (contextual safeguarding) means young people can be vulnerable to multiple harms and therefore staff must respond to concerns raised by or about a child or adult at risk whether the concern is related to the time the young person spends at home, in the community or at InFocus.

Anyone can discuss a concern or report a disclosure by phoning the safeguarding phone 07980 735731 (or Ext 7000).  This is a dedicated phone for safeguarding and is manned 24/7.

You can phone or go and see any of the safeguarding team (named at the beginning of the policy and procedure) or contact them through the internal phone system.  You can also refer direct to either the Multi Agency Safeguarding Hub (MASH), Local Authority Designated Officer (LADO, if concerns about a member of staff) or Adults 08451 551007 safeguarding teams.  You can also make a referral to Ofsted, CQC, NSPCC or the Police.

Parents and visitors are invited to contact the INFOCUS safeguarding team with any concerns or to report to the external agencies identified in the policy.

How should I respond?

Recognise

Recognise the concern and establish the level of urgency. Make a record of what you have seen or heard.

Report

Report all concerns to a member of the safeguarding team immediately.

Record

Use Databridge to complete a Safeguarding Log.

Whilst we work to keep all children and young people within InFocus safe, there are times when we have to take specific action to protect a specific child or group of children from significant harm. This is known as child protection.

When should you contact the safeguarding team?

Staff must contact the Safeguarding team immediately when:

• A child or adult at risk tells of something that has upset or harmed them.
• Someone else reports what a child or adult at risk has told them, or that they believe that a child or adult at risk has been or is being harmed either during the college day, in the residences or elsewhere.
• A child or adult at risk shows signs of physical injury for which there appears to be no explanation.
• A child’s or adult at risk’s behaviour suggests he or she is being abused or their behaviour changes suddenly without any known cause.
• The behaviour of one of the workers towards a child or adult at risk is worrying to someone else.
• The behaviour of another adult or sibling towards a child or adult at risk causes you concern.
• You witness worrying behaviour from a child or adult at risk to another child or adult at risk.
• Any other situations which make you feel uncomfortable but you do not have a rational explanation for.

When should you record concerns on Databridge?

Staff must record their concerns on Databridge when:

• you have spoken to a member of the safeguarding team about an incident, disclosure or concern, and the safeguarding team has asked them to make a record.
• you have any concern about a child or young person’s welfare but do not believe the child or young person is at risk of abuse or neglect.
• you notice changes in a child or young person’s behaviour or demeanour that you cannot explain.

Reporting low level safeguarding concerns

If a staff member has a low level concern about a child or young person and does not believe there is a risk of harm and / or has not received a disclosure, they should:

• record their concern on Databridge before the end of the day / shift
• record the signs, indicators or behaviour that raised the concern
• provide any background information that may give context to the concern

A member of the safeguarding team may contact the staff member for further information.

Feedback

If you have reported a concern or disclosure and want an update please request one from the member of the Safeguarding Team who is working on the concern.  If you do not think that there is appropriate action being taken staff should escalate their concern to the DSL.  If this remains insufficient the member of staff should escalate to the CEO and / or statutory authorities.

Ten key points for staff to follow if you suspect, or are told, of abuse

Adults working with children and vulnerable people should be aware of the risks of abuse and take steps to reduce those risks.

1. Staff in charge of vulnerable young people must know what to do if they suspect that someone is being abused or if they are told by a third party that this is happening either during the college day, in the residences or at any other time in the young person’s life.
2. Children may not feel ready, or even know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful. For example, young people may feel embarrassed, humiliated, or being threatened. This is why it is vital staff employ professional curiosity and remain vigilant to any changes which may indicate abuse is taking place.
3. Always stop and listen to someone who wants to tell you about incidents or suspicions of abuse. Allow the child or young person to set the pace of the conversation.
4. If you can and if it does not stop the flow of what you are being told, write brief notes while they are telling you (these may help later if you have to remember exactly what was said) – keep your original notes to give to the DSL, however rough, even if you have written on the back of something else (it is what you have written at the time and it may be important later – not a tidier and improved version written up later). The DSL will also ask you to make a record on Databridge. If you are not able to write notes at the time, make a record on Databridge of what was said and what you observed as soon as possible afterwards.
5. Never make a promise about keeping what is said confidential or about keeping a secret – if you are told about abuse or a suspicion of abuse you have a statutory duty to report it.  If asked you can explain that you need to pass this information on to a named person as it is very important that something is done to make sure that everyone is safe.  You can explain that you will only be telling people who need to know.
6. Do not ask leading questions as this may put your ideas of what has happened into words.  Just ask “what do you want to tell me,” “tell me more about that,” or “is there anything else that you want to say”.  Do not correct the words they have used but ask for clarification of what they mean, if you are not clear.
7. Inform the group leader/teacher/Line Manager that you have had a disclosure and that you need to pass on information to a member of the Safeguarding Team. If the disclosure is about the group leader / teacher / line manager you will need to ensure that the young person is kept safe and raise the alarm as soon as possible.  You may need to stay with the young person until you can get assistance.
8. Never attempt to carry out an investigation of suspected or alleged abuse.  Social Care Teams and Police have staff who are trained to do this.  You could contaminate the evidence and spoil the chance of any criminal proceedings.  It is your responsibility to refer concerns on and not investigate them.  Do not tidy up any area connected to the alleged abuse or clean up the young person.
9. Within 24 hours of a disclosure the member of the Safeguarding Team will refer the matter to the relevant social services teams, taking into account the local criteria for action.
10. Never think that abuse is impossible in the organisation or in a young person’s home or community or that an accusation against someone you know well and trust is bound to be wrong.
11. Children and young people will often tell other young people, rather than staff or other adults about abuse.  The above points should be discussed with young people through house meetings, PSHE, RSE and in tutorials so that they are aware of how to manage any shared concerns and the importance of telling a responsible adult.

​​​​​​​All staff have a responsibility to report concerns to any statutory agency (MASH, Care Direct, Police, NSPCC, Ofsted, CQC), if they believe that the Safeguarding Team or the Designated Safeguarding Lead (DSL) has not reacted appropriately to the concern or allegation or if there is a level of institutional abuse which is not being identified or corrected.​​​​​​​

Safeguarding Concern Pathway

1. Safeguarding Concern raised about a child/adult/Staff Member (RECOGNISE).
2. Speak to member of the Safeguarding Team (REPORT)
3. Safeguarding team member will decide who should complete a Databridge log (RECORD)
4. Case is screened to decide if it is a Safeguarding Case.
5. If no then manage via operational and/or close. Move to step 8.
6. If yes then there will be further assessment by the safeguarding team resulting in:
7. Refer to MASH or LADO, or internal only (children)
8. Refer to Care Direct, or internal only (adult).
9. Outcomes are then are then shared more widely.
10. If dissatisfied with Organisational response Escalate to: Police, Care Direct, MASH, LADO, Ofsted (Child), CQC (Adult), Chair of Trustees as appropriate.

Professional Confidentiality

Confidentiality is an issue which needs to be discussed and fully understood by all those working with young people, particularly in the context of Child Protection.  The only purpose of confidentiality in this respect is to benefit the young person.  A member of staff must never guarantee confidentiality to a young person nor should they agree with a young person to keep a secret.  Where there is a Child Protection concern this must be reported to the Designated Safeguarding Lead or a member of the Safeguarding Team and may require further investigation by appropriate authorities.

Staff will be informed of relevant information in respect of individual cases regarding Child Protection on a “need to know basis” only.  Any information shared with a member of staff in this way must be held confidentially to themselves

Staff must not offer to keep something confidential or a secret with regards to any disclosure, whoever has made it, as this may compromise the safety or wellbeing of the young person or that of another.

• Staff must report the concern immediately to a member of the safeguarding team using the dedicated phone line 07980735731 (or x7000).
• The Safeguarding team will ask the staff member to make a record on Databridge as soon as possible. Any initial notes made by the staff member must be signed, dated and passed to the Safeguarding team.
• The safeguarding team will share information with external agencies as appropriate.
• Feedback will be given to the member of staff who raised the concern, wherever possible.
• Staff have a professional responsibility to share information with other agencies in order to safeguard young people.
• The safeguarding team will always undertake to share the intention to refer a child to the appropriate external agency with their parents unless to do so could put the child or other children at greater risk of harm, or impede a criminal investigation.  If in doubt, consultation with the MASH, Children’s Social Care, Police or other relevant body will be undertaken.
• Different guidelines apply to adults at risk; usually, information will only be shared with parents or carers with the consent of the adult at risk. If in doubt, a member of the Safeguarding team will consult with Care Direct.
• Staff should not discuss a disclosure with parents or carers of children or young people unless this has been agreed with the DSL and a script has been prepared.

Records and monitoring

Well-kept records are essential to good Child Protection practice.  InFocus is clear about the need to record any concern held about a young person or persons within InFocus, the status of such records and when these records should be passed over to other agencies.

Any member of staff receiving a disclosure of abuse or noticing signs or indicators of abuse, must make an accurate record on Databridge as soon as possible noting what was said or seen, putting the event in context, and giving the date, time and location.

These file notes are kept in a confidential file, which is separate to other files, and stored in a secure place (DSL Office/Databridge).  In the same way notes must be kept of any young person who is being monitored for Child Protection reasons.

If a young person transfers from InFocus, these files will be forwarded to the young person’s new education provider marked confidential and for the attention of the receiving provider’s Designated Safeguarding Lead. InFocus will retain a copy of the chronology.

Categories and indicators of abuse

There are four categories of abuse and accompanying indicators which, if observed should trigger you to carefully consider whether what you are seeing could be as a result of abuse.  That something is or is not on the list does not mean that you can instantly rule in or rule out abuse as a possibility and if there is something that is causing you concern you should act on those concerns.

All the definitions below are taken from Keeping Children Safe in Education.

Physical abuse

A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional 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. Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meets the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Sexual abuse

Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education.

Neglect

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. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

• provide adequate food, clothing and shelter (including exclusion from home or abandonment)
• protect a child from physical and emotional harm or danger
• ensure adequate supervision (including the use of inadequate caregivers)
• ensure access to appropriate medical care or treatment

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Indicators of abuse

Physical signs define some type of abuse, for example, bruising, bleeding or broken bones resulting from physical or sexual abuse, or injuries sustained while a child has been inadequately supervised.  The definition of physical signs is complicated, as young people may go to great lengths to hide injuries, often because they are ashamed or embarrassed, or their abuser has threatened further violence or trauma if they ‘tell’.  It is also quite difficult for anyone to categorise injuries into accidental or deliberate with any degree of certainty.  It is important to note the impact on children of all forms of domestic abuse, including where they see, hear or experience its effects. For these reasons, it is vital that staff are also aware of the behavioural indicators of abuse and report any concerns to the Safeguarding Team.

Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

It is the responsibility of staff to report their concerns.  It is not their responsibility to investigate or decide whether a young person has been abused.

A young person who has been abused or neglected may:

• Have bruises, bleeding, burns, fractures or other injuries
• Show signs of pain or discomfort
• Keep arms or legs covered, even in warm weather
• Be concerned about changing for PE, swimming or in the residential areas for bathing/ bed
• Look unkempt and uncared for – present as smelly
• Change their eating habits
• Have difficulty in making or sustaining friendships
• Appear fearful
• Be reckless with regard to their own or others safety
• Self-harm
• Frequently unexplainable and/or persistent absences from education.
• Show signs of not wanting to go home
• Display a change in behaviour – from quiet to aggressive, or happy go lucky to withdrawn
• Challenge authority
• Become disinterested in school work
• Be constantly tired or preoccupied
• Be wary of physical contact
• Be involved in, or particularly knowledgeable about drugs or alcohol
• Display sexual knowledge or behaviour beyond that normally expected for their age.

Individual indicators will rarely, in isolation, provide conclusive evidence of abuse.  They should be viewed as part of a jigsaw, and each small piece of information will help the DSL and the Safeguarding Team to decide how to proceed.

Information sharing

Sharing information internally

Legally, we can share information within InFocus. When we are worried about a child or young person it is essential we inform the safeguarding team promptly.  Other people in the team, such as the managers, may also need to know to provide safe care for the young person. In exceptional circumstances information within InFocus will be restricted, for example:

• Where there is an allegation about a member of staff the CEO will decide with other agencies in a strategy discussion who must be aware of the concern.
• Where the detail of information is particularly sensitive this can be restricted, for example the details of sexual abuse or a young person sharing worries about their mental health or sexuality. Staff involved in their direct care will probably need to know in general terms the nature of the concern.

Sharing information with other agencies

We follow the 7 Golden Rules from Information sharing advice for practitioners, 2024:

1. The Data Protection Act 2018, the General Data Protection Regulations (GDPR) and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriately.
2. We will be open and honest with individuals (and/or family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
3. We will seek advice from other practitioners (e.g. MASH) if in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible.
4. We share information with informed consent where appropriate and, if possible, respect the wishes of those who do not consent to share confidential information. We still share information without consent if, in our judgement, there is good reason to do so, e.g. where a child’s safety may be at risk. We base judgements on the facts of the case. We are clear why we share or request personal information from someone. We remain mindful that individuals might not expect information to be shared, even with consent.
5. We consider safety and well-being and base our information sharing decisions on considerations of the safety and well-being of the child, their parent(s) and others who may be affected by their actions.
6. Necessary, proportionate, relevant, adequate, accurate, timely and secure: We ensure information we share is necessary for the purpose for which we are sharing it, is shared only with individuals who need to have it, is accurate and up-to-date, is shared in a timely fashion, and is shared securely.
7. We keep records of our decision to share (or not to share) and the reasons for it. We record what we have shared, with whom and for what purpose.

Specific issues

You must respond if you identify any of the following:

Domestic Violence and Abuse (DVA)

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn. InFocus recognises that DVA has a significant impact on a child’s development and emotional wellbeing and should always lead to a child protection referral through the safeguarding team to MASH / MARAC (multi-agency risk assessment conference) / Police.

InFocus is a member of the Operation Encompass initiative.  Operation Encompass is a unique Police and Education early intervention safeguarding partnership which supports children and young people exposed to domestic abuse.  Operation Encompass is the reporting to colleges before the start of the next college day when a child or young person has been involved or exposed to a domestic abuse incident the previous evening.

The information is given in strict confidence to InFocus’s Key Adult to enable support to be given dependent on the needs and wishes of the child.

DVA is very widespread and where staff have concerns for other staff members they should talk to their supervisor.

Physical intervention and restraint

Staff at InFocus must read the Physical Intervention and Restraint policy and understand how to work with young people in a person-centred way and learn to analyse the young person’s behaviour and respond in a proactive and caring way to reduce the stress displayed.

InFocus’s procedure on physical intervention and restraint is set out separately, and acknowledges that staff must only ever use physical restraint as a last resort, when a young person is endangering themselves or others, and that at all times it must be the minimum force necessary to prevent injury and applied for the shortest possible time.  INFOCUS understand that physical intervention or restraint of a nature which causes injury or distress to a young person may be considered a disciplinary matter.

Bullying

While bullying between young people is not a separate category of abuse it is a very serious issue that can cause considerable anxiety and distress.  At its most serious level, bullying can have a disastrous effect on a young person’s wellbeing and in very rare cases has been a feature in the suicide of some young people.

Child-on-child abuse

Children can abuse other children. This is generally referred to as child-on-child abuse and can take many forms. This can include (but is not limited to) bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sharing nudes and semi-nudes, upskirting, abuse within intimate relationships and initiating/hazing type violence and rituals. A child or young person being lesbian, gay, or bisexual can sometimes be targeted by other children. Further information can be found at UKCCIS Guidance: Sexting in Schools and Colleges.

All incidents of bullying and child on child abuse, including cyber bullying and prejudice-based bullying, should be reported and will be managed through INFOCUS’s Anti-Bullying Procedure and in some circumstances, could lead to a child protection referral.  Bullying is addressed across INFOCUS through PSHE sessions with a yearly anti-bullying week.  Tutors and keyworkers will work with individual young people who have been bullied/abused and those who have bullied/abused others to assist them to understand their actions. If the bullying/abuse is particularly serious or if the procedures taken are ineffective the DSL and the CEO will consider implementing child protection procedures.

Staff who allow or condone bullying may face disciplinary proceedings under the Child protection procedures.  This includes cyber, racist, homophobic and gender related bullying.

Sexual violence and sexual harassment between children in schools and colleges

Sexual violence and sexual harassment are crimes and can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Staff should be aware that some groups are potentially more at risk. Evidence shows girls, children with SEND and LGBT children are at greater risk. Staff should be aware of the importance of: • making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up; • not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”; and • challenging behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, upskirting, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them.

If sexual violence or harassment is alleged in our setting, we will

• Take the disclosure seriously and not minimise the young person’s concerns
• Undertake a risk & needs assessment in order to support the victim(s), the alleged perpetrator and any other children or young people who may be affected
• Make a referral to MASH, taking into account the DCFB Thresholds tool
• If a crime has been committed, inform the police (taking into account the wishes of the alleged victim/s)

Children with sexually harmful behaviour

Children may be harmed by other children.  Staff will be aware of the harm caused by bullying and will use the InFocus anti-bullying procedures where necessary.  However, sexually harmful or sexually problematic behaviour warrants a response under the Child Protection procedure rather than anti-bullying procedures. We will assess the level of concern using an established tool such as the Brook traffic lights or AIM2 and, taking into account the DCFB thresholds tool, make a referral to the MASH team.

Racist incidents

InFocus acknowledges that repeated racists incidents or a single serious incident may lead to consideration as a disciplinary matter under Child Protection procedures.

Forced Marriages & Honour Based Violence

Forced marriage is when a person faces physical pressure to marry (e.g. threats, physical violence or sexual violence) or emotional and psychological pressure (e.g. if you’re made to feel like you’re bringing shame on your family).

‘Honour’ based crime is intended to protect ‘family honour’ through violence, threats, insults or other acts around forced marriage, where a cross-cultural relationship is suspected, or where other ‘taboos’ are broken such as wearing of non-traditional clothes or attending events that violate a family or cultural ‘norms’. If staff become aware of either possibility it must be reported immediately to the Safeguarding Team or the Police.

Child sexual exploitation (CSE)

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact: it can also occur through the use of technology. Like all forms of child sex abuse, child sexual exploitation:

• can affect any child or young person (male or female) under the age of 18 years, including 16 and 17 year olds who can legally consent to have sex;
• can still be abuse even if the sexual activity appears consensual;
• can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity; • can take place in person or via technology, or a combination of both;
• can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence;
• may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media);
• can be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse; and
• is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.

Some of the following signs may be indicators of child sexual exploitation:

• children who appear with unexplained gifts or new possessions;
• children who associate with other young people involved in exploitation;
• children who have older boyfriends or girlfriends;
• children who suffer from sexually transmitted infections or become pregnant;
• children who suffer from changes in emotional well-being;
• children who misuse drugs and alcohol;
• children who go missing for periods of time or regularly come home late; and
• children who regularly miss school or education or do not take part in education.

Child criminal exploitation (CCE) – County Lines

Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. Like other forms of abuse and exploitation, county lines exploitation:

• can affect any child or young person (male or female) under the age of 18 years;
• can affect any vulnerable adult over the age of 18 years;
• can still be exploitation even if the activity appears consensual;
• can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;
• can be perpetrated by individuals or groups, males or females, and young people or adults; and
• is typified by some form of power imbalance in favour of those perpetrating the exploitation. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources.

Female Genital Mutilation (FGM)

FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences.  It is a grave violation of the human rights of girls and women to life and their right to health. The UK Government has signed a number of international human rights laws against FGM, including the Convention on the Rights of the Child.  Any staff who believe a girl may be at risk of FGM, become aware that this may be planned or has happened for any young women attending INFOCUS must inform a member of the Safeguarding Team immediately.  If a teacher, in the course of their work in the profession, discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report this directly to the police.

So-called ‘honour-based’ abuse

So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the context of preserving ‘honour’ often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take. All forms of HBA are abuse (regardless of the motivation) and should be handled and escalated as such. If you have a concern regarding a child that might be at risk of HBA or who has suffered from HBA, you should speak to the designated safeguarding lead (or deputy).

Trafficking and exploitation

The two most common terms for the illegal movement of people – ‘trafficking’ and ‘smuggling’, are very different. In human smuggling, immigrants and asylum seekers pay people to help them enter the country illegally; after which there is no longer a relationship. Trafficked victims are coerced or deceived by the person arranging their relocation. On arrival in the country of destination the trafficked child or person is denied their human rights and is forced into exploitation by the trafficker or person into whose control they are delivered.

Children are a special case, any child transported for exploitative reasons is considered to be a trafficking victim, whether or not they have been deceived. This is partly because it is not considered possible for a young person to give informed consent.

Even when a young person understands what has happened they may still appear to submit willingly, to what they believe to be the will of their parents.  Any concerns about trafficking and exploitation must be reported to the Safeguarding Team immediately.

Radicalisation

Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.  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. 

Extremism is defined by the Crown Prosecution Service as:

The demonstration of unacceptable behaviour by using any means or medium to express views which:

• Encourage, justify or glorify terrorist violence in furtherance of particular beliefs;
• Seek to provoke others to terrorist acts;
• Encourage other serious criminal activity or seek to provoke others to serious criminal acts; or
• Foster hatred which might lead to inter-community violence in the UK.

There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.

Young people 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 INFOCUS staff are able to recognise those vulnerabilities.

Extremism: is the vocal or active opposition to our fundamental values, including democracy, the rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs.
Terrorism: is 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.

Indicators of vulnerability include:

• Identity crisis – the young person is distanced from their cultural / religious heritage and experiences discomfort about their place in society;
• Personal crisis – the young person 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 young person’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 young person 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 – young people 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; and
• Significant changes to appearance and / or
• behaviour;
• Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

Preventing radicalisation – the Prevent duty

In order to reduce the risks of young people being radicalised whilst involved with InFocus, we will:

• ensure that staff at InFocus are aware that the DSL is there to protect young people at InFocus from radicalisation and involvement in terrorism;
• maintain and apply a good understanding of the relevant guidance in relation to preventing young people from becoming involved in terrorism, and protecting them from radicalisation by those who support terrorism or forms of extremism which lead to terrorism;
• raise awareness about the role and responsibilities of InFocus in relation to protecting young people from radicalisation and involvement in terrorism;
• monitor the effect in practice of the college’s promotion of British values to ensure that it is used to promote community cohesion and tolerance of different faiths and beliefs;
• raise awareness within INFOCUS about the safeguarding processes relating to protecting young people from radicalisation and involvement in terrorism;
• require the DSL to act as the first point of contact within InFocus for case discussions relating to young people who may be at risk of radicalisation or involved in terrorism;
• collate relevant information from referrals of vulnerable young people into the Channel[1] process;
• ensure the DSL attends Channel meetings as necessary and carries out any actions as agreed;
• ensure that progress on actions is reported to the Channel Co-ordinator; and share any relevant additional information in a timely manner.

Online safety/internet use

Young people are increasingly using mobiles phones, tablets and computers on a daily basis.  They are a source of fun, entertainment, communication and education.  However, we know that some adults and young people will use these technologies to harm young people.  The harm might range from hurtful and abusive texts and e-mails, to enticing young people to engage in sexually harmful conversations, webcam photography or face-face meetings.  Concerns can also occur both online and offline simultaneously. INFOCUS’s online safety policy explains how we try to keep young people safe at INFOCUS.  Cyber bullying and sexting by pupils, via texts and emails, will be treated as seriously as any other type of bullying and will be managed through the INFOCUS Anti-Bullying procedure.

There are three classifications of risk:

Content: being exposed to illegal, inappropriate or harmful material. This also includes misinformation, disinformation (including fake news) and conspiracy theories.

Contact: Being subjected to harmful online interaction with other users.

Conduct: Personal online behaviour that increases the likelihood of, or causes, harm.

Commerce: Commerce is about the risk from things like online gambling, inappropriate advertising, phishing or financial scams. 

“Chatrooms” and social networking sites are the more obvious sources of inappropriate and harmful behaviour and young people cannot access these on the INFOCUS system.  INFOCUS will provide teaching for young people on how to maintain their own safety and how to summon help if they are concerned about what they see on line. Some young people will undoubtedly be chatting on mobiles or social networking sites at home and parents are encouraged to consider measures to keep their young person safe.

The staff Code of Conduct provides further advice and guidance regarding the use of social networking and electronic communication with young people who are involved with the InFocus.

Filtering & Monitoring at InFocus

At InFocus we apply a system of filtering and monitoring of online content in order to protect students in our care. Access to the internet is protected by WatchGuard Firewall and this applies to all college devices and networks.

If someone tries to enter an address on the internet browser, which is deemed unsafe, or involves concerning content, then access will be blocked, and an alert will automatically be raised to the Business & Systems Manager and Designated Safeguarding Lead (DSL). It will then be possible to see the type of content searched and where and by whom tried to access this.

The InFocus WatchGuard Firewall is in operational 24/7. During which any activity which causes concern will trigger an alert. Alerts or suspicious activity will be actively monitored during the hours of 08.30-17.00 on normal working days. Alerts outside of these hours will be reviewed the next working day.

Weekly reports will indicate what type of site content were requested. However, if access to a concerning site involves a student, then this alert will be addressed immediately to protect the student from any potential harm.

On an annual basis, filtering & monitoring arrangements will be reviewed for effectiveness by the Business & Systems Manager in conjunction with the DSL/Head of Safeguarding and Safeguarding Trustee.

Filtering & Monitoring reports/trends, as well as online safety, will also be discussed at the weekly Safeguarding Meeting as a standing item.

Part of the staff induction includes expectations and responsibilities in relation to online safety, use of InFocus devices and filtering and monitoring.

Where an alert of online content activity is triggered by a staff member this will either be dealt with as part of a safeguarding incident and/or referred to the staff members’ line manager and HR to be dealt with under the staff conduct policy.

Photography and images

The vast majority of people who take or view photographs or videos of children do so for entirely innocent, understandable and acceptable reasons.  Sadly, some people abuse young people through taking or using images, so we must ensure that the following safeguards are in place.  While parents are permitted to bring in a camera to events, no staff member should use their personal equipment to take photographs of young people. InFocus provides equipment for this purpose.

Where a staff member has concerns someone is taking photographs in breach of this policy they should contact the safeguarding team.

To protect children, we need to:

• seek their consent for photographs to be taken or published (for example, on our website or in the newspapers or other publications).
• parental consent for any images that may be published.
• use only the young person’s first name with the image.
• ensure that the young person is appropriately dressed.
• encourage young people to tell us if they are worried about any photographs that are taken of them.

Staff should be aware that many indecent images in current circulation were taken by the young person themselves or peers. Sex, sexuality and relationships should be an age-appropriate topic in the college and home, and include what to do if young people are worried about an image they see.

Children who are absent from education

All staff should be aware that unexplainable and or/persistent absences from education, particularly repeatedly, can act as a vital warning sign of a range of safeguarding possibilities. This may include abuse and neglect, which may include sexual abuse or exploitation and child criminal exploitation. It may indicate mental health problems, risk of substance abuse, risk of travelling to conflict zones, risk of female genital mutilation or risk of forced marriage. Early intervention is necessary to identify the existence of any underlying safeguarding risk and to help prevent the risks of a child going missing in future. Staff should be aware of InFocus Unauthorised Learner Absence Procedure (Including Missing Young Person Procedure).  This procedure explains what we do when a child has poor attendance or are regularly missing. InFocus will ensure we have two emergency contacts for each young person.

Private fostering

Private fostering occurs when a child under the age of 16 (under 18, if disabled) is provided with care and accommodation by a person who is not a parent, person with parental responsibility for them or a relative in their own home. A child is not privately fostered if the person caring for and accommodating them has done so for less than 28 days and does not intend to do so for longer. Such arrangements may come to the attention of INFOCUS staff through the normal course of their interaction, and promotion of learning activities, with children.  INFOCUS will notify the local authority to allow the local authority to check the arrangement is suitable and safe for the child.

Homelessness

Government data indicates that there are about 250,000 homeless children in England and Wales and this number is predicted to rise sharply in the next 1 – 2 years. Research by organisations such as the Children’s Society and NSPCC shows that families with a disabled child are at greater risk of poverty and homelessness. If it is believed that any child or young person is homeless or at risk of homelessness (with or without their family), the DSL will liaise with the housing department and relevant charitable organisations either in Devon or in the placing authority.

• Other specific issues
• Keeping children safe in education part 1 and Annex A provide additional information on a range of specific safeguarding issues including:
• having a family member in prison
• children involved in the court process – either as victims, witnesses or perpetrators of crime, or through family court proceedings
• young carers
• children going missing, or missing from education
• children involved in or at risk of being drawn into gang involvement, organised crime or anti-social behaviour

See also Keeping Children Safe in Education Part One.

Prevention

We all play a significant part in the prevention of harm to young people.  We will work to ensure that wherever possible harm is prevented.

Safer recruitment

InFocus endeavours to ensure that it employs ‘safe staff’ by following the guidance in ‘Keeping Children Safe in Education’ 2023 together with the guidance given by the Devon Children & Families Partnership and InFocus’s individual procedures.

Safer recruitment means that all applicants will:

• understand their duties to safeguard young people from the outset through the advertisement and in their job description
• complete and sign an InFocus application form which includes a full education and employment history (with explanations for any gaps)
• provide business contact details for two verified, formal referee statements following an InFocus format, including their current or most recent employer and at least one who can comment on the applicant’s suitability to work with young people (the last child care employer if they have one). One reference must be from someone who has known the candidate for at least 5 years
• provide evidence of identity and qualification
• be checked in accordance with the Disclosure and Barring Service(DBS) regulations as appropriate to their role
• provide evidence of their right to work in the UK
• be interviewed by a panel of two testing skills and abilities with Value Based questions against the job description including at least one person with safer recruitment training
• ensure that recruitment documentation will state its commitment to safeguard young people.

InFocus will also verify the candidate’s mental and physical fitness to carry out their work responsibilities. All new members of staff will undergo face to face induction training which includes familiarisation with the safeguarding policies and procedures and support to identify their Child Protection training needs. All staff will sign to confirm that they have read and understood the safeguarding policies and procedures including ‘Keeping Children Safe in Education 2023’. InFocus obtains written confirmation from supply agencies that agency staff have been appropriately checked, and their suitability to work with young people at InFocus will be assessed based on the young person’s needs. InFocus maintains a single Central Register of recruitment checks undertaken.

Supporting staff

Code of conduct

InFocus has a published code of conduct which sets out expectations of staff around appropriate boundaries and staff keeping themselves safe – it is important you read this document.

Emotional support

Having to deal with a situation where a young person has suffered, or appears to be likely to suffer, harm can be stressful and upsetting.  InFocus will support staff in a variety of ways, including a debrief with the DSL or their deputy.  Where necessary confidential counselling services and additional resources will be sought.

Supervision

Staff involved in working directly with young people at InFocus, or supervising staff who do, will receive regular supervision.  This supervision will take place every half a term and will provide a space for the staff member to talk about issues which they are facing in the work environment, thoughts that they have in terms of developing the service that is provided to the young people and discuss the emotional impact of the role as well as any other issues that they consider relevant.

Supervision will also be used to reflect on any safeguarding issues that the staff member has been involved in (directly or indirectly) and allow for agreement on any further action required.

Training

Throughout this document the terms Group 2 and Group 3 refer to Working Together to Safeguard Children 2023 when training needs for a range of groups were last specified. We are aware this guidance has been replaced by later guidance which does not cover training in such depth, but this consistent language enables effective communication with training providers and the Devon Children & Families Partnership.

All staff who work with young people will undertake appropriate Child Protection awareness training to equip them to carry out their responsibilities for Child Protection effectively, this will start at induction and will be kept up to date by formal refresher training at no more than three yearly intervals. In addition, regular briefing sessions to all staff at least annually will be used to increase knowledge and skills, highlight changes in legislation and needs of the young people.

Temporary staff and volunteers who work with young people at InFocus will be made aware of our arrangements for child protection and their responsibilities.  They will be given information at reception which informs them of the contact details.  Throughout this document the terms Group 2 and Group 3 refer to Working Together to Safeguard Children 2018 when training needs for a range of groups were last specified. We are aware this guidance has been replaced by later guidance which does not cover training in such depth, but this consistent language enables effective communication with training providers and the Devon Children & Families Partnership.

Specific support where risks are identified

Supporting Young People at Risk

InFocus recognises that young people who are abused or who witness violence may find it difficult to develop a sense of self-worth or view the world as a positive place.  INFOCUS may be the only stable, secure and predictable element in the lives of young people at risk.  Nevertheless, whilst at InFocus their behaviour may still be challenging and defiant or they may be withdrawn.

Young people known to be in this category will need additional support from staff and greater liaising with external agencies to enable the young people to develop in self-confidence, self-worth and self-belief and to feel safe at InFocus.Early help assessments may be carried out by Children’s Social Care and INFOCUS staff will be directed as required to support this.

Safeguarding incidents and/or behaviours can be associated with factors outside the college and/or can occur between children outside college. All staff, but especially the designated safeguarding lead (and deputies) should be considering the context within which such incidents and/or behaviours occur. This is known as contextual safeguarding, which simply means assessments of children should consider whether wider environmental factors are present in a child’s life that are a threat to their safety and/or welfare. Children’s social care assessments should consider such factors so it is important that schools and colleges provide as much information as possible as part of the referral process. This will allow any assessment to consider all the available evidence and the full context of any abuse. Additional information regarding contextual safeguarding is available here: Contextual Safeguarding.

Attendance at Child Protection Conference and Core Groups

It is the responsibility of the DSL to ensure that INFOCUS is represented or a report is submitted to any Child Protection conference called for young people at or who have attended InFocus.  Whoever attends should be fully briefed on any issues or concerns INFOCUS has and be prepared to make a decision on InFocus’s ability to protect the young person at the end of the conference.

When a young person is placed at INFOCUS and is identified as needing protection it is the DSL’s responsibility to ensure that the young person is monitored regarding their school attendance, welfare and presentation.  If INFOCUS is part of the core group then the DSL should ensure that INFOCUS is represented at these meetings by someone sufficiently senior to make decisions and someone who knows the young person well; that the Designated staff at INFOCUS understand their role in delivering the child protection plan, that there is a record of attendance and issues discussed.  All concerns about the Child Protection issue and/or the young person’s welfare should be discussed and recorded at the core group meeting unless the young person is at further risk of significant harm.  In this case the DSL must inform the young person’s social care key worker immediately of any concerns and then record that they have done so and the actions agreed.

Safe College, safe staff

It is essential that the high standards of conduct and professional responsibility adopted with regard to alleged child abuse by parents are similarly displayed when members of staff are accused of abuse.

Only authorised agencies may investigate child abuse allegations (Social Care Services, the Police or in some areas, the NSPCC).  Whilst it is permissible to ask the young person/people simple, non-leading questions to ascertain the facts of the allegation, formal interviews and the taking of statements is not.

The CEO will inform the LADO (Local Authority Designated Officer) in an event of an allegation being made against a member of staff and follow their direction.
Risk Assessment

• All young people will have in place an individual risk assessment and behaviour plan appropriate to their needs which will inform staff of how to respond to any statements made through behaviour.
• All activities will be risk assessed in line with INFOCUS procedures.

Allegations against staff

All InFocus staff should take care not to place themselves in a vulnerable position with a young person.  Staff must adhere to the “Working Alone with Young People” and “Intimate Care” procedures and adhere to “Keeping Children Safe in Education” 2023. All concerns, whether high or low level, regarding staff conduct should be reported in accordance with ‘Recognise, Report, Record’.

InFocus understand that a young person may make an allegation against a member of staff.

The CEO on all such occasions will discuss the content of the allegation with the Local Authority Designated Officer (LADO) for the management and oversight of allegations.

If the allegation concerns the Principal then this must be passed directly to the CEO.

If the allegation concerns the CEO, the Designated Person will immediately inform the Chair of Trustees without notifying the CEO first.

InFocus will follow the Devon Children & Families Partnership (DCFP) Procedures for managing allegations against staff and notify the LADO team of the allegation/concerns.

InFocus will notify the DBS should an allegation made against a member of staff be found to be true and the individual is removed from regulated activity.

Whistleblowing

The staff at InFocus occupy a vital position in promoting good practice and professional conduct throughout the organisation.  We recognise that staff are committed to providing a high standard of service.

InFocus recognises that young people cannot be expected to raise concerns in an environment where staff fail to do so.

All staff should be aware of their duty to raise concerns, where they exist, about the management of Child Protection, which may include the attitude or actions of colleagues.  If necessary, they should speak to the Designated Lead, CEO, safeguarding trustee or LADO.

If a member of staff notices anything that gives them cause for concern it is vital that this is raised.

Acting upon staff concerns is fundamental in order to ensure good practice and support for staff.

Resolving issues must be viewed by all staff as a positive action and not a breach of trust between colleagues or an attack on the organisation.

InFocus values an atmosphere of openness and honesty and welcomes suggestions, complaints and criticisms.

Whistleblowing includes raising and passing on concerns about any of the following:

• Poor standards of service
• Issues of bad practice
• The conduct of colleagues or managers
• Anything which is not in the best interest of the young person or the organisation
• Anything which is illegal or unacceptable behaviour.

InFocus has a detailed Whistleblowing procedure in place.  This procedure can be found on the Intranet.

Any member of staff who fails to report child protection concerns immediately is placing the young person at risk of potential further harm, and themselves at risk of disciplinary action. This includes safeguarding disclosures made by a child, young person or concerned adult in other community situations.

Contractors

All contractors working for InFocus will be expected to comply with the requirements of this policy and know what to do if they have a concern.  Where appropriate INFOCUS will require contractors to have the necessary checks (e.g. DBS and references) completed prior to commencing work at INFOCUS.

InFocus will ensure that these requirements are set out in any tendering and contractual documents.

Further information

Further information can be obtained from the Head of Safeguarding.

There are many organisations to assist with safeguarding and some of the information in this policy has been taken from:

• Devon Children and Families Partnership
• Southwest Child Protection Procedures
• Devon Safeguarding Adults Partnership
• NSPCC information service
• SCIE safeguarding adult resources

Who do I need to speak to?

You can contact a Designated Person (member of the Safeguarding Team) 24 hours a day, 7 days a week on 07980 735731 or Ext 7000 (from a InFocus landline).

InFocus personnel responsible for carrying out safeguarding procedures are:

• Designated Safeguarding Lead (DSL; Training: Level 3 Child Protection Training with evidence of CPD annually)
  • Head of Safeguarding
• Deputy Designated Safeguarding Leads (DDSLs)
  • Principal
  • Director of Care and Support Services
  • Head of Learning
  • Head of Health and Therapy
• Safeguarding Team (Designated Safeguarding Persons or DSPs; Training: Level 3 Child Protection Training renewed at least every 2 years with annual updates)
• Designated Trustee (contact via the CEO’s PA EXT 201)

Ofsted can be contacted on www.ofsted.gov.uk  or 0300 1234 666

Care Quality Commission (CQC) can be contacted on www.cqc.org.uk or 03000 616161

Multi Agency Safeguarding Hub can be contacted on 0345 155 1071

LADO can be contacted on 01392 384964

Care Direct can be contacted on 0845 155 1007

Annex 1: How do I tell if a young person is at risk of harm or neglect

It is difficult to be certain, but if you have a reason to worry then that is enough for us to talk more about the risk or to involve other agencies.

Use the definitions of abuse or neglect from earlier in this document and the Threshold Tool (www.devonsafeguardingchildren.org)

Risk Assessment

The table shows how the risk increases from Level 1 to Level 4 as the Likelihood and Impact of the event increase.

Impact is either:

• Low
• Concern
• Harmful
• Significant harm

Likelihood is either:

• Very unlikely
• Possible
• Suspected
• Likely
• Almost certain

The risk increases based on the combination of likelihood and impact. For example, an event that is rated Significant Harm but Very Unlikely would be level one. If the Impact is Significant harm but the likelihood increased to Possible then the risk level would rise to Level 3.​​​​​​​

Definitions

Level 1 (Low)

No injury or cause for concern

Level 2 (Concern)

A young person isn’t doing as well as they should, although there is no evidence of harm. They may benefit from extra help. For example, a young person hits herself but has a plan in place to reduce occasions where this happens… on one occasion they hit themselves but do not leave a mark. We would want to review this periodically, or if it worsens.

Level 3 (Harmful)

Harm means ill-treatment or the impairment of health or development, including for example, impairment suffered from seeing or hearing the ill-treatment of another. For example, the above young person injures herself leaving a bruise. This will need to be explored further to establish why they have been harmed.

Level 4 (Significant Harm)

Neglect, physical abuse, sexual abuse or emotional abuse including for example, impairment suffered from seeing or hearing the ill-treatment of another. Any harm which may be attributable to an adult who encounters a young person at work.

Very unlikely        

An event that could happen, but is almost certain not to happen

Possible      

An event that could happen

Suspected   

There is an indication that something has happened or may happen

Likely

Something you believe is more likely to happen than not

Almost certain      

Something that will happen unless action is taken

Annex 2: Case responsibilities for child protection and safeguarding issues

Definitions

Staff response: staff are the alerters. They have the relationships with the young people.

Supervisor response: supervisors take responsibility for marking sure concerns are explored.

Safeguarding team: The safeguarding team are consultants and audit each situation to ensure proper processes are followed

Designated Safeguarding Lead (or Deputy): The DSL is responsible for the system, and signs off all CP cases

RED: Worried a child is at risk of abuse or neglect

Staff response

Stop any immediate risk. Phone the safeguarding team. Record your concerns on Databridge and flag for action. Follow up and escalate.

Supervisor response

Stop any immediate risk, if necessary contacting Police MASH or Emergency Duty Service. Contact lead professional and consider contacting parents if appropriate.

Safeguarding team

Attend meetings and track progress of all child protection enquiries and ensure INFOCUS are happy with any decisions made by partner agencies.

Designated Safeguarding Lead (or Deputy)

Refer under s47 where local criteria for action have been met. Ensure there is a strategy discussion within one working day or sooner if required and that CP procedures are followed.

AMBER: Something significant has happened, things are getting worse or you’re unsure whether they’re at risk

Staff response

Record your concerns on Databridge. Follow up and escalate.

Supervisor response

Assess the risk, considering the need for any immediate action as above. Contact parents and lead professional. Create a plan to reduce the future risk.

Safeguarding team

Consider needs against the DCFP Threshold Tool. Escalate to Red if a child protection concern. Coordinate an early help assessment for children who would benefit from this.

Designated Safeguarding Lead (or Deputy)

Review and sign off decisions of manager and safeguarding team.

GREEN: A child isn’t doing as well as they should.

Staff response

Record your concerns. Discuss with the team and in supervision. Follow up and escalate.

Supervisor response

Assess the risk, considering the need for any immediate action as above. Keyworker contacts parents and lead professional. Create a plan to reduce the future risk.  Consider needs against the DSCP Threshold Tool. Escalate to Amber or Red if a child protection concern.

Safeguarding team

Consider needs against the DCFP Threshold Tool. Escalate to Red if a child protection concern. Coordinate an early help assessment for children who would benefit from this.

All safeguarding team

Random audit/checks on 10% files each month to ensure decisions are being made effectively audit activity.

Annexe 3: Record Keeping

InFocus uses Databridge, a secure digital system, to record child protection and safeguarding concerns relating to children and adult service users. All staff have access to Databridge and are expected to record their concerns / reports directly to the system. Where a paper record exists (for example, a child’s drawing or writing, a staff member’s initial notes) these will be signed and dated, scanned into Databridge and the log number recorded on the original paper; the paper original will also be retained securely by the DSL.

It is important to note that the retention requirements are two-fold; that is, records must be retained as specified above but should not be retained for any longer unless there is a good reason to do so[2] (for example, because legal action is pending).

There are different guidelines for the transfer of records relating to an adult at risk; the safeguarding team will consult with the allocated social worker as part of transition planning.

We follow national guidelines regarding the retention of records when a child leaves our college:

Student leaves college and does not transfer to a new FE setting

Where concerns were at low level OR threshold for referral to social care not met OR no inter-agency involvement then the child protection file should be retained until young person’s 25th birthday (or the end of that school year).

Where a referral was made OR social care involved (s47) OR other agencies involved then the child protection file should be retained for 35 years from date the child left the college.

Student moves to another FE setting

Chronology (ies) should be kept for at least the periods stated above. They may be archived for longer if this is stated in your policy.

Where the child protection file has been posted to a new setting then a copy of the entire file should be kept until the new setting confirms safe receipt. The copy should then be shredded.

All cases

Looked after child: records should be kept for 75 years from the date the child left the college.

Where there are records relating to allegation against staff OR harm to a pupil by staff, visitor or volunteer then records should be kept until that person’s retirement age or 10 years, whichever is longer BUT for the duration of IICSA, it is a criminal offence to destroy any records that could be called as evidence so retain everything.

COVID-19 College arrangements for safeguarding and child protection

Our COVID-19 safety measures

We are all learning to live with Covid as per the Government advice.  However, we will remain vigilant to any changes in health advice and act accordingly.

Vulnerable Children

Vulnerable children include those who have a social worker and those children and young people up to the age of 25 with education, health and care (EHC) plans. 

Those who have a social worker include children who have a child protection plan and those who are looked after by the local authority. A child may also be deemed to be vulnerable if they have been assessed as being in need or otherwise meet the definition in section 17 of the Children Act 1989. 

 Those with an EHC plan will be risk-assessed in consultation with the local authority (LA) and parents, to decide whether they need to continue to be offered a college place in order to meet their needs, or whether they can safely have their needs met at home. This could include, if necessary, carers, therapists or clinicians visiting the home to provide any essential services. Many children and young people with EHC plans can safely remain at home. 

Eligibility for free college meals in and of itself should not be the determining factor in assessing vulnerability. 

 Senior leaders, especially the DSL (and deputy) know who our most vulnerable children are and have the flexibility to offer a place to those on the edge of receiving children’s social care support. 

InFocus will continue to work with and support children’s social workers to help protect vulnerable children. This includes working with and supporting children’s social workers and the local authority virtual school head (VSH) for looked-after and previously looked-after children. The lead person for this will be: Jason Ryder (College Principal). 

Attendance and remote education

Attendance is mandatory for all pupils of compulsory college age. This means it’s your legal duty as a parent to send your child to college regularly if they are registered at one.

If you have concerns about your child attending, you should discuss these with your school or college.

All clinically extremely vulnerable children and young people should attend their education setting unless they are one of the very small number of children and young people under pediatric or other specialist care who have been advised by their clinician or other specialist not to attend.

Further information is available in the guidance on supporting pupils at school with medical conditions.

Remote education if your child cannot attend college

 Online safety in colleges 

InFocus will continue to provide a safe environment, including online. This includes the use of an online monitoring and filtering system.  

Where children are using computers in school, appropriate supervision will be in place.  

Children and online safety away from college 

It is important that all staff who interact with children, including online, continue to look out for signs a child may be at risk. Any such concerns should be dealt with as per the child protection policy and where appropriate referrals should still be made to children’s social care and as required the police. 

 Online teaching should follow the same principles as set out in the school’s or college’s staff code of conduct.  

InFocus will ensure any use of online learning tools and systems is in line with privacy and data protection/GDPR requirements. 

Supporting students not in college 

InFocus is committed to ensuring the safety and wellbeing of all its students.  

The Designated Safeguarding Lead will ensure that a robust communication plan is in place for each child, their parent(s)/carers and the allocated social worker or placing authority.   

Details of this communication plan must be recorded on Databridge as should a record of any contact made.  

The communication plan may include; remote contact, phone contact, door-step visits. Other individualised contact methods should be considered and recorded.  

InFocus and its Designated Safeguarding Lead will work closely with all stakeholders to maximise the effectiveness of any communication plan.  

This plan must be reviewed regularly and where concerns arise, the Designated Safeguarding Lead will consider any referrals as appropriate, taking into account the local criteria for action.  

 In addition, the college will share safeguarding messages on its website and social media pages.  

InFocus recognises that college is a protective factor for children and young people, and the current circumstances have a significant potential to affect the mental health of pupils and their parents. Teachers and pastoral staff at InFocus will be aware of this in setting expectations of pupils’ work where they are at home.  

InFocus will ensure that if we are unable to care for the children of critical workers, residential pupils and vulnerable children on site, we will liaise with the placing local authority and the parent / carer to find a suitable alternative; e.g., at a ‘hub’ college or via a multi-disciplinary package of support. In that situation, the DSL will ensure that the DSL of the hub college / lead practitioner is made aware of any relevant safeguarding information relating to a child.   

Reporting a concern 

Where staff have a concern about a child, they should continue to follow the process outlined in the school safeguarding policy (recognise, report, record), which includes making a report via Databridge which can be done remotely.  

Associated documents

This Policy should be read in conjunction with the following procedures:

• Keeping Children Safe in Education 2023 (Part 1 and Annex A)
• Sexual violence and sexual harassment between children in schools and colleges 2021 (withdrawn and now included in KCSIE)
• Working Together to Safeguard Children 2023
• Adults at Risk Protection Procedures
• Positive Behavioural Support
• Physical Intervention
• Anti-bullying
• Whistleblowing
• Confidentiality
• Complaints
• Code of Conduct
• Working alone with Young People
• Intimate Care
• Supervision Procedure
• Staff selection and recruitment procedures
• Online safety Policy
• Risk Assessment Guidelines
• Sex and Relationship Education Procedure (SRE)
• Unauthorised Learner Absence
• Off-site Activity policy

Online safety links

• Be Internet Legends developed by Parent Zone and Google is a free internet safety curriculum with PSHE accredited lesson plans and teaching resources for Key Stage 2 pupils
• Disrespectnobody is Home Office advice and includes resources on healthy relationships, including sexting and pornography
• Education for a connected world framework from the UK Council for Internet Safety supports the development of the curriculum and is of particular relevance to RSHE education and Computing. It is designed, however, to be usable across the curriculum and beyond (covering early years through to age 18) and to be central to a whole school or college approach to safeguarding and online
• PSHE association provides guidance to schools on developing their PSHE curriculum
• Teaching online safety in school is departmental guidance outlining how schools can ensure their pupils understand how to stay safe and behave online as part of existing curriculum requirements
• Thinkuknow is the National Crime Agency/CEOPs education programme with age specific resources
• UK Safer Internet Centre developed guidance and resources that can help with the teaching of the online safety component of the Computing

Access to this document

This document is stored on the InFocus Intranet and public website.

Please contact the MIS office if you would like a copy of this document in an alternative format such as Braille or large print.​​​​​​​