POLICIES
SAFEGUARDING POLICY
1. Safeguarding Policy
Shell Education policies include the safeguarding policy which is mandatory for all staff and host families to read and recommended for parents. This policy relates to all children under our care regardless of gender, age, ethnicity, nationality, religion or disability. All children have the right to protection from any kind of abuse and the right to exist in a safe and friendly environment whilst in the care of Shell Education.
Shell Education is committed to the ongoing promise of safeguarding children. To ensure that all staff receive the most up to date information, this policy is reviewed and redistributed annually as standard. Should a significant change take place, the policy is immediately redistributed thereafter.
Policy
This policy is based on guidance from Keeping Children Safe in Education and Working Together to Safeguard Children, and describes the policy aims, safeguarding measures, safer recruitment, use of IT and the internet, confidentiality.
We implement our safeguarding policy as follows:
· By following safer recruitment procedures to check the suitability of Shell Education adults.
· Ensuring that all Shell Education adults understand their legal and moral responsibility to safeguard the welfare of children at Shell Education.
· Having a clear code of conduct in place for all Shell Education adults.
· By providing children and parents/carers with codes of conduct and ensuring they understand what those are.
· By adopting child protection guidelines and accepted procedures.
· By providing appropriate training, guidance, and procedures for Shell Education adults to meet the needs of children.
· Ensuring children’s health and safety whilst in our care taking part in activities.
· By sharing information about any concerns about children’s welfare.
· To continually develop awareness of any issues which might harm these children.
· Not to make Shell Education adults unnecessarily vulnerable to suspicion of any form of abuse.
· Ensuring that this policy is available to all on our website.
Safeguarding and promoting the welfare of children is everyone’s responsibility.
Everyone who meets children has a role to play in safeguarding children. In order to fulfil this responsibility effectively, Shell Education requires all staff and host family members to make sure their approach is always a child-centred one. This means that they should consider, at all times, what is in the best interests of the child. No individual can have a full picture of a child’s needs and circumstances. If children 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. To ensure this happens close liaison with Parents, Agents and partner schools will always take place to ensure the safety of the child.
If you have any reason to believe that a child in your care is suffering from any form of abuse or neglect, then please report it immediately in confidence to the DSL.
Olga Bernstein, Email: contact@shelleducation.co.uk, Phone: +447770925045 (available 24/7)
Shell Education policies are available on the website www.shelleducation.co.uk and are available in hard copy on request.
1.1. Policy Review
Shell Education is also committed to reviewing this policy and good practice every 12 months.
Local Agency Contacts
Shell Education is aware of how to access local agency contacts which includes Local Safeguarding Partnerships across the country and how to access locally agreed interagency procedures and guidance. In addition, the agency is aware of non-emergency reporting procedures via the Local Authority’s Children’s Services relevant to the area or Multi-Agency Safeguarding Hub (MASH) or by contacting the non-emergency Police Number 101. In emergency situations, the agency is aware of the need to contact Police by calling 999.
The specific LADO’s for Dorset area is Pan Dorset Safeguarding Children Partnership
Contact: LADO should be contacted by email lado@bcpcouncil.gov.uk or by phone on 01202 817600.
This policy applies to all full-time, part-time, contracted, volunteer staff and host families including those who do not have direct and regular contact with students to carry out their guardianship duties.
1.2. Aims of the policy
This policy aims to ensure that Shell Education students have a safe environment which promotes and prioritises students their safety and well-being, support children’s development by protecting them from specific safeguarding issues and all forms of child abuse, create a culture of safe recruitment and adopt procedures that help to identify people who might abuse children and create an environment where staff remain vigilant. Ensure that appropriate action is taken in the event of incidents or concerns of abuse being reported to Shell Education staff and that support is provided to individuals who raise or disclosure the concern, to ensure that confidential, detailed, and accurate records of all safeguarding concerns are maintained and securely stored.
The policy is reviewed every year after development or sooner if in response to changes in legislation or government guidance.
1.3. Terminology
”Safeguarding” is the protection of children from maltreatment, preventing the impairment of children’s health/development and ensuring that children grow up in circumstances consistent with the provision of safe and effective care. Working together to safeguard children (HM Government 2019)
“Child Protection” is a part of safeguarding and promoting welfare to protect specific children, who are suffering or are at risk of suffering significant harm.
Staff refers to all those working for Shell Education, full time or part time, in either a paid or voluntary capacity.
Child, Student refers to all young people who have not yet reached their 18th birthday.
Parent refers to birth parents and other adults who are in a parenting role, for example stepparents or adoptive parents.
Designated Safeguarding Lead (DSL) is a person identified as taking the lead in safeguarding matters in an organisation. This person will be trained to a higher level.
2. Safeguarding Policy and Key Principles
Shell Education adults have a duty to keep U18s safe and protect them from physical and emotional harm or potential abuse. Effective safeguarding will reduce the need for action to protect children from harm.
The welfare of the child is paramount (Children Act 1989). Shell Education is aware of the national threat of child sexual abuse cases as per Strategic Policing Requirement March 2015, that protecting children is a matter of national importance and working together with schools and parents is critical in our work.
Shell Education adults are responsible for their own actions and behaviour and should avoid any conduct which would lead any reasonable person to question their motivation and intentions.
Shell Education adults should work, and be seen to work, with U18s in an open and transparent way.
Records should be made of any such incident and of decisions made/further actions agreed.
Shell Education adults should apply the same professional standards to children regardless of gender, ethnicity, nationality, disability, sexual orientation or religion.
Shell Education adults should know the name of their designated person for child protection and understand their responsibilities to safeguard and protect children. This will be explained in inductions.
Shell Education aims to ensure that the students in our care experience at all times a caring and secure environment in which they feel safe, respected and valued.
In pursuit of this aim, Shell Education undertakes the following:
1. Training is provided for all staff and host families to a level appropriate for their role.
2. We promote an environment of trust, openness and clear communication between students, school and Shell Education staff and host families, so that student welfare, safety and pastoral care is recognised as the top priority.
3. We respond to any reported allegation or suspicion of child abuse in accordance with the Shell Education procedures as outlined below.
4. We ensure that all guardianship personnel, host families and personnel offering outsourced services who come into direct contact with students in our care, are recruited using safer recruitment practices and are formally screened through the completion of an enhanced DBS check.
5. We maintain links with the appropriate agencies who have a statutory responsibility to deal with child welfare and child protection concerns.
2.1. Supporting Procedures
This policy is to be read in conjunction with the following policies and documents:
• Anti-bullying (including cyber-bullying) Policy
• Anti-Radicalisation Policy
• Online safety Policy
• Missing student Policy
• Safer Recruitment Policy
• Staff and Host Family Code of Conduct
• Whistleblowing Policy
· Low-Level Concerns Policy
• Emergency procedure (This includes information on the guardianship organisation’s approach to foreseeable emergencies, such as a pandemic.)
3. Types of Abuse
Shell Education aims to protect children from the four main types of abuse:
Physical Abuse
Where the victim is caused physical harm – may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Can also be fabrication of a child’s symptoms of or deliberately induces illness in a child. Signs and things to be aware of are: Bruising (especially symmetric) commonly on the head, neck or soft areas, defensive wounds, cluster of bruises with dots of blood under skin, burns or scalds can be from hot liquids, hot objects, flames, chemicals or electricity, Physical markings/colouration to skin/hair, Medication without symptoms/cause, bite marks, fractures or broken bones. Other injures and health problems could relate to scarring, effects of poisoning such as vomiting, drowsiness, seizures, and respiratory problems from drowning, suffocation, or poisoning.
Sexual Abuse
Forcing or enticing a young person to take part in sexual activities (not necessarily involving a high level of violence, child may not be aware of what is happening). May involve physical contact, including assault by penetration (e.g., rape or oral sex) or nonpenetrative acts (e.g., masturbation, kissing, rubbing, touching outside of clothing). Can be non-contact activities (e.g., 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). Can happen online and technology can be used to facilitate offline abuse. Can be committed by male, female or other children. Signs and things to be aware of: Inappropriate sexualised play, Inappropriate needy attention seeking behaviour, high incidence of teen, abuse of other teens. Children who are sexually abused may stay away from certain people, might avoid being alone with people such as friends or family members, or they could seem frightened of a person or reluctant to socialise with them.
Emotional Abuse
Persistent emotional maltreatment to cause severe and adverse effects on child’s emotional development. e.g. conveying to a child they are worthless, unloved, inadequate or only valued by meeting the needs of another. Not giving the child opportunities to express their views, deliberately silencing, or making fun of what they say or how they communicate. Age or developmentally inappropriate expectations imposed on child e.g. Interactions that are beyond a child’s developmental capability, overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. Seeing/hearing ill-treatment of another. Serious bullying (including cyberbullying), causing child 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, although it may occur alone). The signs and things to be aware of are: Lying and spreading rumours, Negative facial or physical gestures, menacing or contemptuous looks; Playing nasty jokes to embarrass and humiliate, mimicking unkindly, encouraging others to socially exclude someone; Damaging someone's social reputation or social acceptance. Withdrawn. Expressing comments/behaviour that are older than their years.
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. Can occur during pregnancy, e.g. as a result of maternal substance abuse. Depriving a child of basic needs e.g. food, clothing, shelter (including exclusion from home or abandonment), ensuring access to appropriate medical care/treatment. May also include neglect of or unresponsiveness to a child’s basic emotional needs. Signs and things to be aware of are: Most common away from home. Unused to supervision, Friendship circles, Appearance– unclean or odour, Unhealthy weight or diet, Medical concerns.
Child-on-Child abuse
Child-on-child abuse can manifest in many different ways, including but not limited to on-line bullying, sexting, banter, initiation rituals and inappropriate or harmful sexualised behaviours. In most instances, the conduct of children and young people towards each other will be covered by the school behaviour policy. However, some allegations may be of such a serious nature that they may raise safeguarding concerns. Shell Education recognise that children are capable of abusing their peers. It will not be passed off as ‘banter’ or ‘part of growing up’. The forms of child-on-child abuse are outlined below.
• Child Sexual Exploitation – children under the age of 18 may be sexually abused in the context of exploitative relationships, contexts and situations by peers who are also under 18.
• Harmful Sexual Behaviour – Children and young people presenting with sexual behaviours that are outside of developmentally ‘normative’ parameters and harmful to themselves and others.
• Serious Youth Violence – Any offence of most serious violence or weapon enabled crime, where the victim is aged 1-19 i.e. murder, manslaughter, rape, wounding with intent and causing grievous bodily harm.
‘Youth violence’ is defined in the same way, but also includes assault with injury offences. The term child-on-child abuse can refer to all of these definitions and a child may experience one or multiple facets of abuse at any one time. Therefore, our response will cut across these definitions and capture the complex web of their experiences. There are also different gender issues that can be prevalent when dealing with child-on-child abuse (i.e. girls being sexually touched/assaulted, or boys being subjected to initiation/hazing type violence). Research indicates that young people rarely disclose child-on-child abuse and that if they do, it is likely to be to their friends.
Therefore, we will also educate children and young people that we work with about how to support their friends if they are concerned about them, that they should talk to a trusted adult or someone at their school and what services they can contact for further advice.
Any concerns, disclosures or allegations of child-on-child abuse in any form should be referred to the Designated Safeguarding Lead. Where a concern regarding child-on-child abuse has been disclosed to the DSL, advice and guidance will be sought from Childrens Social Care and where it is clear a crime has been committed or there is a risk of crime being committed the Police will be contacted.
3.1. Further Detail on specific types of abuse
The following information is taken from Keeping Children Safe in Education. Please refer to this document for further details, including additional types of abuse.
https://www.gov.uk/government/publications/keeping-children-safe-in-education--2
Safeguarding issues All staff and host families should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and sexting (also known as youth produced sexual imagery) put children in danger.
Serious violence
All staff and host families should be aware of indicators, which may signal that children are at risk from, or are involved with serious violent crime. These may include increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs.
Children missing from education
All staff and host families should be aware that children going missing, 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 can also be a sign of child criminal exploitation including involvement in county lines. 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 contact the students’ school or college should they suspect a student is missing from education. The school or college will have a procedure for reporting this absence.
Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)
Both CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. 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. In some cases, the abuse will be in exchange for something the victim needs or wants and/or will be to the financial benefit or other advantage (such as increased status) of the perpetrator or facilitator. The abuse 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. It can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence. Victims can be exploited even when activity appears consensual and it should be noted exploitation as well as being physical can be facilitated and/or take place online. More information include definitions and indicators is provided below.
Child Criminal Exploitation (CCE)
CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence. The victim may have been criminally exploited even if the activity appears consensual. CCE does not always involve physical contact; it can also occur through the use of technology. CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.
Some of the following can be indicators of CCE:
• children who appear with unexplained gifts or new possessions;
• children who associate with other young people involved in exploitation;
• 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 sexual exploitation (CSE)
CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child 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. CSE does not always involve physical contact; it can also occur through the use of technology. CSE 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. It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity and 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).
The above CCE indicators can also be indicators of CSE, as can:
• children who have older boyfriends or girlfriends; and
• children who suffer from sexually transmitted infections or become pregnant.
The department provide: Child sexual exploitation: guide for practitioners.
County lines
County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or other form of “deal line”. Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools, further and higher educational institutions, pupil referral units, special educational needs schools, children’s homes and care homes. Children are often recruited to move drugs and money between locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection. Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network. One of the ways of identifying potential involvement in county lines are missing episodes (both from home and school), when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. If a child is suspected to be at risk of or involved in county lines, a safeguarding referral should be considered alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation. Further information on the signs of a child’s involvement in county lines is available in guidance published by the Home Office.
Honour-based abuse (including Female Genital Mutilation and Forced Marriage)
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. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBA, or already having suffered HBA.
Actions
If staff have a concern regarding a child that might be at risk of HBA or who has suffered from HBA, they should speak to the designated safeguarding lead (or deputy). As appropriate, they will activate local safeguarding procedures, using existing national and local protocols for multi-agency liaison with police and children’s social care. In schools, where FGM has taken place, since 31 October 2015 there has been a mandatory reporting duty placed on teachers - 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 to the police.
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.
Forced marriage
Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some perpetrators use perceived cultural practices as a way to coerce a person into marriage. Schools and colleges can play an important role in safeguarding children from forced marriage.
Domestic Abuse
The cross-government definition of domestic violence and abuse is: any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass but is not limited to: psychological; physical; sexual; financial; and emotional. All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.
Upskirting
The Voyeurism (Offences) Act, which is commonly known as the Upskirting Act, came into force on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a person’s clothing (not necessarily a skirt) without their permission and or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. It is a criminal offence. Anyone of any gender, can be a victim.
Online safety
The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation: technology often provides the platform that facilitates harm. The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk:
• content: being exposed to illegal, inappropriate or harmful material; for example, pornography, fake news, racist or radical and extremist views;
• contact: being subjected to harmful online interaction with other users; for example, commercial advertising as well as adults posing as children or young adults; and
• conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images, or online bullying. SHELL EDUCATION recognises the risks posed to students online.
Further information can be found in the e-safety and bullying (including cyber-bullying) policies.
Mental Health
All staff and host families should also be aware that 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. Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Staff and host families, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. Where children have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff and host families are aware of how these children’s experiences, can impact on their mental health, behaviour and education. If staff or host families have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken, following their child protection policy and speaking to the designated safeguarding lead or a deputy.
In addition, this policy aims to protect children and young people from other forms of child abuse by ensuring staff are aware of signs and symptoms of abuse which could include:
● bullying/cyberbullying ● grooming online ● domestic or gang violence ● drug or alcohol abuse ● forced marriage ● gender based violence ● mental health issues ● prostitution ● radicalisation/extremism ● teenage relationship abuse/sexting ● trafficking
Please note: further information on any of the above topics (including child sex exploitation and FGM) can be found on government website. Keeping Children Safe in Education (KCSIE) is statutory guidance from the Department for Education (DfE). The staff, volunteers and host families should read Part 1 or Annex A in the document (for those who do not work directly with children). Part One of “Keeping Children Safe in Education” (2022) and “What to do if you are worried a child is being abused” (2015) outlines the signs and symptoms of the different forms of child abuse.
It sets out the legal duties that govern all schools and colleges in England when carrying out their duties to safeguard and promote the welfare of children under the age of 18. The updated version could be found via link:
https://www.gov.uk/government/publications/keeping-children-safe-in-education--2
The document “Keeping Children Safe in Education” could be found here:
The document “What to do if you are worried a child is being abused” could be found here:
The document “Crime and Policing news” (2015) could be found here
Shell Education is committed to safeguarding and promoting the welfare of children and young people and expects all staff to share this commitment. Shell Education works to ensure that all members of staff are aware the responsibility for specific safeguarding issues and child protection from all forms of abuse belongs to everyone, and that families, communities and professionals must work together to promote their welfare.
4. What to do
4.1. Situation when the concern is raised.
It may be that you or someone else has concerns about a child’s well-being, but the child has not actually said anything to you. All staff and host families should be aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful. This should not prevent staff and host families from having a professional curiosity and speaking to the DSL if they have concerns about the child.
If such a situation arises, you should speak to DSL (Designated Safeguarding Leads) which is
Olga Bernstein
Email: contact@shelleducation.co.uk
Telephone: +447770925045 (line available 24/7)
It is important that staff and host families determine how best to build trusted relationships with children and young people which facilitate communication.
Abuse or neglect can have a damaging effect on a child’s health, educational attainment and emotional well-being. If you have been in contact with a child or group of children over many weeks, you may see changes in behaviour. Such changes may not necessarily indicate that a child is suffering abuse or neglect. In some cases those changes may be as a result of homesickness, bereavement or symptoms of a hidden disability or undiagnosed medical condition, and the need to distinguish those cases reinforces the need for a careful and thorough assessment of the child and his/her needs when concerns are passed on.
It is important that you do not feel afraid about passing on your concerns. The information may be a small piece in a bigger jigsaw and help to get a better understanding of the child’s predicament. Appendix 1 could be used for making notes. Any concerns, however seemingly trivial, should be passed on to the DSL.
It may be that you have a concern which feels very vague and would simply like to discuss your concerns with the DSL. Please feel free to do so.
Shell Education will ensure the child’s wishes and feelings are taken into the account when determining what action to take and services to provide.
4.2. Procedures
When new staff, volunteers or host families join our organisation, they are informed of the safeguarding arrangements in place, the name of the DSL and how to share concerns with them.
Please note that the usual reporting channel is via the DSL, however anyone can make a referral direct to the LSP or LADO. The contact details are included in this document.
Actions to be followed if there are concerns about a child or young person:
• All staff members and host families have a duty to identify and respond to suspected / actual abuse or disclosures of abuse. Any member of staff, volunteer or host families who receives a disclosure or allegation of abuse, or suspects that abuse may have occurred must report it immediately to the DSL.
• Where there is risk of immediate harm, concerns will be referred immediately by telephone to the LSP (0300 123 4043) or the Police.
• Less urgent concerns or requests for support, including for Early Help, will be sent by the DSL to the LSP via 0300 123 4043.
• The DSL may also seek advice from Social Care or another appropriate agency about a concern, if we are unsure how to respond to it.
• The DSL will refer any safeguarding concerns that relate to an incident in school to the school. Concerns will be referred to the school DSL. If an allegation is made against a member of school staff, the guardianship organisation will check the school policy to see who to refer such matters so. This is usually the Head of the School. If the allegation involves the Head, then usually the chair of governors should be informed.
• Where a concern is not seen to reach the threshold for a referral, the DSL will keep the concern on file and will monitor the situation. Should the concern escalate, a referral will be made to the LSP.
• Wherever possible, we will share any safeguarding concerns, or an intention to refer a child to Children’s Social Care, with parents or carers. However, we will not do so where it is felt that to do so could place the child at greater risk of harm or impede a criminal investigation. On occasions, it may be necessary to consult with the LSP and/or Police for advice on when to share information with parents / carers.
• If a member of staff or host family continues to have concerns about a child and feels the situation is not being addressed or does not appear to be improving, the staff member or host family concerned should press for re-consideration of the case with the designated safeguarding lead.
• If, for any reason, the DSL is not available, or you do not feel that your concern is being taken seriously, this should not delay appropriate action being taken. Any individual may refer to the LSP or Police where there is suspected or actual risk of harm to a child. The contact details are included at the beginning of this policy.
• Full records of reports and action taken will be maintained by the DSL and securely stored in a specific safeguarding file.
4.3. Situation of allegation of abuse
An allegation is where someone tells you directly that some kind of abuse has happened (sometimes called a ‘disclosure’).
You may be approached by a child who wants to talk to you about something that has or is happening to them or someone they know. They will tend to choose someone that they trust or know well and this will not always be their personal guardian. It may be any member of staff or other adult with whom they have formed a good relationship.
When you are approached by a child who wants to talk to you, you should listen positively, take their allegation seriously and reassure them. If you can, try and ensure a degree of privacy, but this may not always be possible. Whilst this might be an alarming situation to find yourself in, it is important not to let the moment pass – for every child that does finally disclose information, evidence shows that they have usually tried up to 12 times before.
Reassure the child that they did nothing wrong and that you take what they say seriously. Do not make false promises, e.g. that you will keep the abuse a secret or that the police will not be involved. Tell the child that you will take action to keep them safe and that you may need to tell some people to do this, but only those whose job it is to protect children. Acknowledge how difficult it must have been to talk.
Listen quietly, carefully, and patiently.
Don’t jump to conclusions.
Don’t investigate, interrogate, or ask leading questions.
These might compromise a future criminal investigation. You can ask, "Is there anything else that you want to tell me?" Do not ask the child to repeat what they have told you to another Shell Education adult. Explain to the child what you have to do next and who you have to talk to.
Contact the Designated Safeguarding Lead (Olga Bernstein on 07770925045) immediately, even out of hours to tell them about the allegation. Do not discuss the case with other staff or share the identity of the child or alleged abuser.
Make some very brief notes at the time if you can, but do not stop the child from talking just so you can take notes. Write them up as soon as you can after the disclosure and use the concern/allegation form in Appendix 2. Do not destroy your original notes in case they are required by the Court. Try to record the words used by the child and how the child appeared to you – be specific and do not use different words. Record statements and observable things, not your interpretations or assumptions.
The DSL will decide whether to refer the allegation to the Local Safeguarding Partners. If you are unable to contact the DSL, you may need to refer the allegation to the Local Safeguarding Partners yourself. See section on ‘Making a referral to children’s social care’.
Be aware of your own feelings about abuse and find someone you can share those feelings with once the procedures have been completed (while at the same time maintaining appropriate confidentiality). Dealing with issues of child abuse can be distressing for the adult to whom the abuse is disclosed.
4.4. Guidance for the avoidance of allegations of abuse against staff or host family
These guidelines are adapted from those offered to staff & Host families within Shell Education, and should be viewed within the context of what constitutes child abuse.
Definitions of abuse can include emotional abuse as well as sexual and physical.
Abuse of Trust is a criminal offence whereby any person in a position of responsibility over a ‘child’ (under 18) who is seen to exploit that position can be prosecuted. Please note these are guidelines only – your professional judgement within a given situation should also be exercised.
Non-abusive acts (permitted physical contact):
• Restraint is permissible as long as it is consistent with legislation and guidance. In general terms you are allowed to use reasonable force to remove a dangerous item from a student or take a student away from a dangerous situation
• Shepherding with a hand on back or shoulder
• Comforting with a hand on arm, shoulder or back
• Securing attention – tapping a student’s shoulder
Private Meetings:
• Should be conducted in rooms with visual access and doors should be kept open wherever possible • There should be knowledge of another person that the meeting is taking place
Gratuitous physical contact must be avoided, and it is unwise to attribute touching to your daily life.
Inappropriate discussions must be avoided, and insensitive, disparaging and sarcastic comments are unacceptable. Discussion about another student with a student or group of students is unacceptable
Reporting incidents
• Following any incident where you feel that your actions or comments have been misconstrued you should discuss the incident with Olga Bernstein (DSL)
• You should report any crush or infatuation and seek assistance in dealing with the issue before escalation
4.5. Allegations of abuse against a member of staff and host family
This guidance should be followed where it is alleged that anyone working, volunteering or hosting students for Shell Education has:
• behaved in a way that has harmed a child, or may have harmed a child;
• possibly committed a criminal offence against or related to a child;
• behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children; or
• behaved or may have behaved in a way that indicates they may not be suitable to work with children (transferable risk).
• In the event that there is an allegation against a member of staff, volunteer or host family, Shell Education will follow the guidance in Keeping Children Safe in Education.
• Allegations against a member of guardianship organisation staff, volunteers or host families should be directed to the DSL, Olga Bernstein. Olga Bernstein must contact the LADO immediately and follow their advice. They must not investigate themselves. If the allegation is about the DSL, please contact AEGIS (tel: +44 (0) 1453 821293) who will contact the LADO and follow the advice as above. Alternatively, the allegation can be reported directly to the LADO.
• Shell Education will report promptly to the DBS any person whose services are no longer used for regulated activity because they have caused harm or posed a risk of harm to a child.
• Any historical allegations should be referred to the police.
• Low level concerns: The safety and wellbeing of students in our care is dependent on the vigilance of all our staff, volunteers and host families and their prompt communication to the DSL, Olga Bernstein, of any concerns, no matter how small, about any conduct by an adult which causes you to doubt that adult’s suitability to work with or have access to children.
Shell Education is conscious of its duty of care to students and will always act, including if alerted to the possibility of abuse arising from situations or persons outside our care. The notification and prompt handling of all concerns about adults is fundamental to safeguarding students. It helps to identify and prevent abuse and to protect adults against misunderstandings or misinterpretations. It also encourages openness, trust and transparency and it clarifies expected behaviours. Please refer to our low-level concerns policy for further details.
4.5. Receiving a disclosure from a child or young person
What do I do if a young person tells me about an issue?
• Reassure the child, listen carefully and stay calm - it is important that they know you believe them.
• Do not say, you will not say anything to anyone – in fact you have a duty to disclose this to another person so do not promise confidentiality. Inform the individual that you must pass the information on, but that only those that need to know about it will be told. Inform them who you will report the matter to.
• Ask open questions if appropriate, do not lead the conversation to find out what has happened. Use words such as tell me, explain or describe, and allow the student to speak.
• Avoid words such as what, why, how when – these will be asked by the relevant agency if appropriate.
• Reassure the individual that by telling you, they have done the right thing
• Make sure you take detailed notes, note of the date, time, place, what the individual said, did and your questions etc. Write everything down (it may not be possible to take notes at the time but you should do so as soon as you are able to).
· Contact the DSL (Olga Bernstein) as soon as practicable and in any case within 24 hours.
• Ensure that you notify the police by calling 999 if you believe that the young person is at immediate or serious risk of harm
4.6. Making a Referral to the Local Safeguarding Partners
The DSL has lead responsibility for safeguarding and child protection and is expected to refer cases of suspected abuse to the local authority children’s social care as required.
If, at any time, a Shell Education adult believes that a child is in immediate danger they should call the police immediately on 999.
If you are concerned about a child’s welfare or worried, they are being abused, you can make a referral to local authority.
In Dorset contact the Children’s Advice and Duty Service (ChAD):
Professional’s Telephone Number: 01305 228558
The specific LADO’s for Dorset area is Pan Dorset Safeguarding Children Partnership
Contact: LADO should be contacted by email lado@bcpcouncil.gov.uk or by phone on 01202 817600.
The contact information of local authority children’s social care could be found on this webpage.
4.7. Role of DSL
The DSL will take lead responsibility for safeguarding and child protection (including online safety). This will be explicit in the role holder’s job description. This person has the appropriate status and authority within the guardianship organisation to carry out the duties of the post.
The designated safeguarding lead:
• refers cases of suspected abuse to the local authority children’s social care as required;
• supports staff and host families who make referrals to local authority children’s social care;
• refers cases to the Channel programme where there is a radicalisation concern as required;
• supports staff and host families who make referrals to the Channel programme;
• refers cases where a crime may have been committed to the Police as required;
• acts as a point of contact with the safeguarding partners;
· liaises with staff and host families on matters of safety and safeguarding (including online and digital safety) and when deciding whether to make a referral by liaising with relevant agencies;
· acts as a source of support, advice and expertise for all staff and host families;
· ensures the guardianship organisation’s child protection policies are known, understood and used appropriately;
· ensures the child protection policy is reviewed annually (as a minimum) and the procedures and implementation are updated and reviewed regularly
· ensures the child protection policy is available for all relevant parties;
• links with the safeguarding partner arrangements to make sure staff and host families are aware of any training opportunities and the latest local policies on local safeguarding arrangements.
Contact details of DSL:
Olga Bernstein
Mobile: +447770925045
Email: contact@shelleducation.co.uk
5. Welfare and Implementing Safeguarding Policies
Children under the care of Shell Education are encouraged to look after each other and to pass on concerns to our staff. Children are made aware of this through their first day induction, the Pupil Handbook and reminded through WhatsApp messaging service.
Host Family Allocation
· Children of the opposite sex are not permitted to share a room and suitable safeguarding measure to be put in place to ensure the child has sufficient privacy from other children within the home. Parent/carer must also be made aware of this arrangement and give their consent.
· Children of the same sex are permitted to share a room, but adequate measures should be in place to ensure their privacy and Risk Assess them sharing. Their parent/carer must consent to this.
· Children must have their own bed and not share with another child.
· Children must have access to a bathroom which has a locked door.
· No more than 3 children from any Guardianship Agency can be placed in a host family at any one time unless in emergency circumstances.
· Shell Education will ensure that as far as reasonably practicable that the Host Family will not host any other children from any non-Aegis registered organisation or independent paying guests whilst they have one of our children staying with them.
· Shell Education will ensure as far as reasonably practicable that when our children under the age of 16 are within the host family, no young person over the age of 20 will be hosted either from any other Guardian Agency/organisation or independent person.
· We accept the DBS online facility and encourage our host families to take this on as it enables Shell Education to check their DBS every two years.
· Host Family accommodation for U18s is managed by Shell Education. Each host family is provided with Host Family Handbook and Student Handbook.
· Students are given Student Handbook.
If a child under the age of 16 (under 18 if disabled) is cared for 28 days or more by someone who is not their parent or a close relative this is deemed a private fostering arrangement and Children's Social Care for the relevant area has to be notified. If this is the case for a host family, Shell Education will liaise with them to ensure that Social Care is informed and that all necessary procedures are followed.
All host families are inspected annually to ensure the fire evacuation plan is appropriate, enforced and that all fire prevention is in working order.
A host family can never take the place of a parent in providing physical comfort and should be cautious of any demonstration of affection. Host family members are advised to avoid physical contact with students as even when well intentioned, this contact may be misconstrued by the student, an observer or any person to whom this action is described. There may also be cultural, gender sensitive or religious reasons about touching which the host family member is not aware of. Host family members must be aware that any physical contact with a student may need to be explained and would be open to scrutiny. Where a student is upset or distressed (for example due to homesickness) remember that sympathy and help can be given using kind words. Also, sitting with the student and listening to them until they feel better can also be of great comfort. Host families should, therefore, always use their professional judgement and in cases where this may be unavoidable (for example a young child who has fallen over, makes physical contact with the primary carer first or is crying with homesickness), we would recommend asking a child if physical comfort is wanted before giving it. However, in the majority of cases it would not be appropriate, and we do not recommend physical contact, and would encourage comforting the child as detailed above.
Staff should ensure that only photography, videos, or images of students are taken with their and their parent’s consent and that these are published where such consent has been obtained (please note our terms and conditions ask parents to let us know if they do NOT give their consent so unless you hear otherwise, a Shell Education student’s parents have consented). Images should be securely stored and used only by those authorised to do so. This means staff members who are present on school premises for the purpose of a student visit or parents evening, the parent/student has not objected to images being taken and the images are taken in relation to the purpose of the visit. Under no circumstances should staff take images of students without consent or without the students knowing that the images are being taken. Staff should always be able to justify images of pupils in their possession and avoid making images in one-to-one situations.
Staff members working in one-to-one situations with pupils should ensure that the meetings are on school premises or a recognised workplace. Wherever possible staff should ensure there is visual access and/or an open door. Where a meeting with a pupil is required away from school or work premises (for example for an urgent situation), the necessity for this should be clear and approval should be obtained from a senior member of staff, pupil and their parent/carers.
The Shell Education Whistle Blowing Policy provides guidance to staff on how to deal with malpractice in the workplace where there is concern for the safety of children. Shell Education Safeguarding and Child Protection policies outline to staff the correct procedures for reporting and recording concerns and incidents.
5.1. Travelling as Unaccompanied Minors
If students are travelling as unaccompanied minors, the parents must supply the name and ID/contact details of the person meeting the child at the airport to the airline company. As soon as this is known by the school a few days beforehand, it is passed on to the parents/agent.
Taxi drivers going to the airport to meet a minor are given an unaccompanied minor letter of authorisation, which includes their name, and will have an appropriate ID card as a means of identification.
The taxi company will inform Shell Education via the emergency phone at the time about any minor who fails to arrive as expected and the school will then confirm that the student is safe and being supervised appropriately.
If there are any serious issues, contact is made with a senior member of staff to decide on further action.
Shell Education checks with the taxi company that any vehicle used for the purpose of transporting children is insured, taxed, regularly serviced and MOT checked.
5.2. Missing Child
Refer to the Missing Child Policy for more detailed information.
5.3. First Aid, Medical Conditions and Disabilities
All children/parents/carers are required to give Shell Education information about medical conditions and/or disabilities on the application form. This information is used to draw up an appropriate care plan for the child with their parent/carer and, where appropriate, the family’s own medical practitioners. This plan is agreed upon with the relevant host family, relevant staff, and the child’s parents/carer before the child’s arrival.
5.4. Use of IT and the Internet
Shell Education believes information and communications technology includes all forms of computing, the internet, telecommunications, digital media and mobile phones. This policy is linked to the Online Safety Policy which outlines the guidelines for staff using social media for business and personal use, and to the Shell Education Information and Communications Technology policy which outlines the professional responsibility which staff members have when using any form of ICT.
Any member of the company personnel that uses illegal software or access inappropriate websites when on company premises faces dismissal.
Staff members must be aware of the principles of the Computer Misuse & Copyright Acts 1998, and GDPR and the Data Protection Act 2018.
The use of the internet, web based or mobile communications and social media by staff members must be appropriate to the staff member’s role, lawful, proportionate and ethical.
Staff members must access Shell Education internal information for a legitimate and authorised purpose only, must not disclose internal information to unauthorised recipients and must maintain confidentiality of internal information.
The following list of offences will be considered as misconduct and will lead to a disciplinary review:
- abuse, misuse or neglect of IT systems within the agency
- misuse of the internet and/or email to access or distribute material of a pornographic, offensive, obscene or inappropriate nature
- excessive use of the internet for personal purposes during working time
- accessing information on Shell Education internal systems for unauthorised purposes or persons
- accessing and disclosing information obtained from Shell Education internal systems for unauthorised purposes or persons
- disclosure of confidential information for unauthorised purposes or persons
Staff members have a positive obligation to report any of their own behaviour which has fallen below the standards of professional behaviour in this policy.
Staff members have a positive obligation to report, challenge or take actions against the conduct of colleagues which has fallen below the standards of professional behaviour in this policy.
5.5. Confidentiality and sharing information
All staff will understand that child protection issues warrant a high level of confidentiality, not only out of respect for the child and staff involved but also to ensure that being released into the public domain does not compromise evidence. Staff should only discuss concerns with the Designated Safeguarding Lead Olga Bernstein. She will then decide who else needs to have the information and they will disseminate it on a ‘need-to-know’ basis. Record of concern forms and other written information will be stored securely in a locked storage in the safeguarding folder and only made available to relevant individuals. All relevant information will be stored separately from the child’s Individual and academic file and kept in a separate private folder. The Data Protection Act does not prevent the company’s staff from sharing information with relevant agencies, where that information may help to protect a child.
Sharing Safeguarding Information
Information will be shared with guardianship organisation staff, host families and the school’s DSL (of the school that the student attends) who ‘need to know’. All staff and host families must be aware that they have a professional responsibility to share information with other agencies in order to safeguard children and that the Data Protection Act 1998 and General Data Protection Regulations are not a barrier to sharing information where a failure to do so would place a child at risk of harm. There is a lawful basis for child protection concerns to be shared with agencies who have a statutory duty for child protection. All staff and host families must be aware that they cannot promise a child to keep secrets which might compromise the child’s safety or wellbeing. However, staff and host families are aware that matters relating to child protection and safeguarding are personal to children and families, in this respect they are confidential and the DSL will only disclose information about a child to other members of guardianship organisation staff, host families or the DSL of the school that the student attends on a need to know basis. The DSL will always undertake to gain parent/carers consent to refer a child to Social Care unless to do so could put the child at greater risk of harm or impede a criminal investigation.
5.6. Record keeping
Shell Education will keep full records of any safeguarding concern reported to them. Safeguarding records will be stored securely and separately to the general student files. These will be stored confidentially by the DSL in a password protected file. Only the DSL will have access to these files. Records will be detailed and accurate (either handwritten or using appropriate secure online software). These will include all concerns about a student even if there is no need to make an immediate referral and record the rationale for decisions made and action taken. Copies of any correspondence or notes from conversations with the LSP, school DSL or other external agency will be included in the file. Shell Education will ensure that the indication of the existence of the additional child protection file is marked on the student file record. Information will only be shared in a need to know basis in order to safeguard the student.
5.7. Training and Updates
Shell Education will ensure that all staff and host families receive training and regular updates that is suitable for their roles. A formal record of all safeguarding training will be kept.
The DSL will attend suitable face-to-face training as approved or provided by the Local Safeguarding Partners (LSP), AEGIS, SACPA or the NSPCC. This training will be renewed every two years.
Other staff and host families.
All other members of staff, volunteers and Host Families will receive appropriate safeguarding training to an appropriate basic awareness level (previously referred to as level 1), every three years. This will either be done online or in person. Members of staff, volunteers and Host Families who have already completed suitable safeguarding training for another provider that is still in date will not be required to re-train. In this case the DSL will still need to ensure that the person fully understands Shell Education’s own procedures for safeguarding. All staff and host families will receive regular safeguarding updates, at least once per year – normally in summer months. These will be given by the DSL.
IF YOU HAVE ANY CONCERNS, QUERIES OR QUESTIONS:
Please speak to Olga Bernstein, who is the Designated Safeguarding Lead and the Prevent Lead.
Phone: +447770925045 (available 24/7)
Email: contact@shelleducation.co.uk
CONTACT US
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