Adult Education Service Child Protection and Safeguarding Policy

5.1 If a member of staff, parent or member of the public is concerned about a child’s or young person’s welfare, they should report it to the designated safeguarding lead as soon as possible. On occasions when the designated safeguarding lead is not available, it should be reported to the deputy safeguarding lead without delay. Although any member of staff can make a referral to Children’s Services where possible there should be a conversation with the Designated Safeguarding Lead.

5.2 If anyone other than the Designated Safeguarding Lead makes a referral to Children’s Services or to the police, they should inform the DSL as soon as possible.

5.3 All staff will be alert to indicators of abuse and will report any of the following to the Designated Safeguarding Lead immediately -

• Any concern or suspicion that a child or young person has sustained an injury outside what is reasonably attributable to normal play
• Any concerning behaviours exhibited by children or young persons that may indicated that they have been harmed or are at risk of harm, including unusual changes in mood or behaviour, concerning use of language and/or concerning drawings or stories.
• Any significant changes in attendance or punctuality
• Any significant changes in a child’s or young person’s presentation
• Any concerns relating to people who may pose a risk of harm to a child; and/or
• Any disclosures/allegations of abuse that children or a young person have shared.

5.4 There will be occasions where a child or young person discloses/alleges abuse directly to a member of staff. If this happens, the member of staff will -

• listen carefully to the child or young person and believe what they are saying
• not promise confidentiality, as information may need to be passed on so the child or young person and family can receive additional support
• only ask for clarification if something is unclear and will not ask ‘leading’ questions
• report disclosure to the designated safeguarding lead as soon as possible, certainly by the end of the day
• only discuss the issue with colleagues that need to know about it and
• will write up the disclosure and pass it to the designated safeguarding lead. It is likely they will have had a discussion with the DSL prior to this but delay should be avoided

5.5 The designated safeguarding lead will make a decision about the action that needs to be taken following a member of staff raising a concern about a child or following a direct disclosure recording a clear rationale. The DSL may consider the following options:

• Managing support for the child or young person internally within service
• Seek advice from the social worker advice line in the MASH
• Instigate single agency intervention and work directly with the family to improve the situation
• Offer an Early Help Assessment to provide multi-agency help to a family
• In cases where children are deemed to be at significant risk of harm, the DSL will refer cases to the MASH for consideration for statutory intervention. Parental consent will be obtained wherever possible before referring cases to the MASH However, if Coventry Adult Education Service is worried that telling parents will mean the child or young person is at greater risk of harm, we may do this without informing them
• If parents do not consent to a referral but the service believes that a child or young person is at significant risk of harm, a referral will still be made to Children’s Services

5.6 Further information about the Coventry Safeguarding Children Partnership’s ‘Right Help, Right Time’ guidance, which is used by Coventry Adult Education Service to make decisions about protecting children.

5.7 See page 24 for flowchart of actions that will be taken where there are concerns about a child or young person (taken from Keeping Children Safe in Education, September 2022).

5.8 In cases where members of staff become aware that Female Genital Mutilation (FGM) has been carried out on a female below the age of 18, they have a mandatory duty to report this to the police without delay and will do so. Staff should refer this to the DSL first, but the legislation requires regulated health and Children’s Service professionals and teachers in England and Wales to make a report to the police because within the course of their professional duties, they either -

• are informed by a girl under 18 that an act of FGM has been carried out on her or
• observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth

If you believe a child or young person is at risk of FGM, a referral to the MASH is also required.

5.9 Coventry Adult Education Service have a duty to refer any children or young person who are living in a private fostering arrangement to the local authority. Private fostering is when a child or young person under the age of 16 (or under 18 if disabled) is cared for by someone who is not their parent or a close relative. This is a private arrangement made between a parent and a Carer, expected to last 28 days or more, or the service are aware the 28 days has been exceeded.

5.10 All schools and educational providers are subject to a duty under section 26 of the Counterterrorism and Security Act 2015 in the exercise of their functions to have “due regard” to the need to prevent people from being drawn into terrorism. See Appendix B for further information on the service’s Prevent duty

5.11 If any member of staff is unsure about signs of abuse or neglect, they should speak to the Designated Safeguarding Lead

5.12 Child on Child Abuse

5.12.1 Coventry Adult Education Service understands that both adults and other children can perpetrate abuse, and can happen inside and outside of the service, online or face to face. Child on Child abuse is taken very seriously and can include bullying (including cyber-bullying, prejudice-based and discriminatory bullying), abuse in intimate personal relationships between children, physical abuse, sharing of consensual or non-consensual images of videos, causing someone to engage in sexual activity without consent, sexual violence and/or harassment, upskirting, and initiation/hazing ceremonies. The service recognises that safeguarding issues can manifest as child-on-child abuse. The service’s Procedures for the implementation of the Safeguarding policy sets out how the service manages reports of incidents of sexual violence and sexual harassment.

• Violence against Women and Girls
• www.safetotalk.org.uk , the website of the Coventry Domestic Violence and Abuse Partnership. 
• Procedures for the implementation of safeguarding policy with contact details for referrals

5.12.2 All members of staff will be made aware of the service’s policy and procedures with regards to child-on-child abuse. The service will ensure staff understand what is meant by child-on-child abuse and the service policy on child-on-child abuse by the completion of KCSIE 2022 update training and Sexual Harassment Training

5.12.3 The Adult Education service will work to prevent child on child abuse by:

• Educating all members of the steering group, employment and skills team, Senior Leadership Team, staff, learners, and parents/carers about this issue
• Ensuring that all child-on-child abuse issues are fed back to the services’ safeguarding lead so that they can spot and address any concerning trends and identify learners who may need additional support
• Challenging the attitudes that underlie such abuse (both inside and outside the classroom)
• Creating a culture in which our learners feel able to share their concerns openly, in a non-judgmental environment, and have them listened to and responding to cases of child-on-child abuse promptly and appropriately.

5.12.4 Although it is recognised that if there are no reported cases, such abuse may still be taking place. If an allegation of child-on-child abuse is made, the Service will investigate this. The DSL will investigate the concerns or allegations with the member of staff or learner who has reported them and will, where necessary, take any immediate steps to ensure the safety of the child/all children affected. The DSL will take a leading role using their professional judgement and supported by other agencies such as social care or the police as required. In the event of an allegation:

• when possible, two members of staff will be present where the report includes an online element. Staff will not view illegal images of children
• will not promise confidentiality as reports will need to be passed onto Children’s Service (and in some cases, the Police)
• recognises that a child is more likely to disclose to a member of staff they have the strongest relationship with
• an initial disclosure may be the first incident that is reported rather than a singular event
• some children and young people may face barriers to disclosing such as, additional needs, vulnerability, sex, ethnicity, and possibly sexual orientation
• will always listen carefully to the child or young person, whilst being non-judgemental
• write up the factual parts of the disclosure as soon as the child or young person has finished disclosing
• liaise with the MASH (and police if urgent response required).

5.12.5 In the event that an allegation of child-on-child abuse is made, victims, alleged perpetrators and any other children or young person affected will be supported in the following ways and referral to the MASH will be considered:

• Ensuring a dialogue is kept open and the victim and perpetrator can choose to appoint a designated trusted adult
• Ensure both are comfortable to return to the same classroom or make alternative arrangements
• Obtain additional support from relevant agencies where appropriate
• Ensure that everything possible is done to prevent the victim from bullying and harassment as a result of any report they have made
• In some cases, a risk assessment may be required but will be kept under constant review. When there has been a report of sexual violence, the designated safeguarding lead (or deputy) will make an immediate risk and needs’ assessment. Where there has been a report of sexual harassment, the need for a risk assessment should be considered on a case-by-case basis

Harmful Sexual Behaviour resource link and guidelines for DSL’s

• The risk and needs’ assessment should consider - the victim (consider term used), especially their protection and support; the alleged perpetrator (who may also be ‘a victim’; and all the other children (and, if appropriate, adult students and staff) at the Service, especially any actions that are appropriate to  protect them
• Risk assessments will be recorded, filed securely within SMT/Safeguarding secure site and kept under review. The designated safeguarding lead (or deputy) will ensure they are engaging with MASH.

5.12.6 Coventry Adult Education Service will never pass off child on child abuse as ‘banter’, ‘having a laugh. ‘part of growing up’ or other such termination that does not recognise the harm caused. This should be a Zero-tolerance approach as this could lead to a culture of unacceptable behaviours. It is recognised with this, that all child-on-child abuse is unacceptable and will be taken seriously

5.12.8 Coventry Adult Education Service will adhere to guidance set out in Keeping Children Safe in Education (2022) and Sexual Violence and Sexual Harassment in Schools (September 2021) when responding to incidents of child-on-child abuse

5.12.9 All staff will be made aware that ‘upskirting’ is a criminal offence

5.13 Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)

5.13.1 Both CSE and CSE are forms of abuse that occur when an individual or group take advantage of an imbalance in power to coerce, manipulate or deceive a child or young person into taking part in sexual or criminal activity, in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator through violence or threat of violence. CCE and CSE can affect both males and females and can include children that have been moved for the purpose of exploitation (trafficking)

5.13.2 CCE can include children or young person’s being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, or pickpocketing, vehicle crime, threatening violence on others or even carrying weapons

5.13.3 The service is responsible for recognising children or young persons involved in CCE are victims of exploitation and should be recognised as such due to the harm they have experienced even if they appear to have consented to the criminal activity

5.13.4 CSE is a form of child sexual abuse including physical contact and non-contact online activities including the internet or by phone. This can happen over time or as a one off and may happen without the child recognising this as abuse or harmful

5.13.5 The service recognises that children of the age of 16 and 17 who can legally consent to a sexual relationship may also be the victims of CSE but may not recognise this.

5.14 Sharing of consensual or non-consensual nude and semi-nude images or videos

5.14.1   “Sharing of consensual or non-consensual nude and semi-nude images or videos” refers to any sharing of youth-produced sexual imagery between children. This includes -

• A person under the age of 18 creating and sharing sexual imagery of themselves with a peer under the age of 18
• A person under the age of 18 sharing sexual imagery created by another person under the age of 18 with a peer under the age of 18 or an adult
• A person under the age of 18 being in possession of sexual imagery created by another person under the age of 18

5.14.2 Coventry Adult Education Service  has a responsibility to educate children and young people in the risks relating to ‘sharing consensual or non-consensual nude images or videos’ and how to keep themselves safe online, particularly Study programme learners receive face-to-face on-line safety workshops that encompasses, their own safety, the safety of others online, profile development and risks e.g., Catfish and the dangers of social media. This is regularly reinforced through termly quizzes, posters, and activities.

5.14.3 Any incidents or suspected incidents of ‘sharing consensual or non-consensual nude images or videos’ should be reported to the DSL without delay.

5.14.4   Once reported to the DSL, the DSL will decide on the appropriate course of action. This could include -

• Referrals to the MASH in regard to all parties involved (also the police if an urgent response required)
• Confiscation of mobile phones in line with guidance ‘Searching, Screening and Confiscation, (January 2018)
• Support for young people involved to prevent re-occurrence
• Sanctions in accordance with the behaviour policy
• Searching, screening and confiscation in schools - GOV.UK (www.gov.uk)

5.14.5 Any incidents of ‘sharing consensual or non-consensual nude images or videos’ involving the following will result in a MASH and sometimes as a Police referral -

• Adult involvement
• Coercion or blackmail 
• Children under the age of 13
• Extreme, or violent content
• Immediate risk of harm

5.14.6   Staff will not view images or videos on pupil devices. Confiscated devices will be stored securely by the DSL or DDSL and passed to the relevant agencies as required.

5.14.7   We will work with parents as necessary if their child is involved in the sharing of consensual or non-consensual nude images or videos

5.14.8 We operate a culture of safeguarding and young people should feel confident to disclose if they have sent an inappropriate image of themselves. Children and young people will always be supported to retrieve and delete the images

5.15 Domestic Abuse

5.15.1 Domestic abuse can be a single incident or a pattern of incidents. It can also include psychological, physical, sexual, financial, or emotional acts of abuse

5.15.2 The service recognises that children or young persons can be victims of Domestic Abuse by seeing, hearing, or experiencing the effects or suffering domestic abuse in their own personal relationships. These all have a detrimental impact on children’s health, well-being, development, and ability to learn. Coventry Adult Education Service will work with openness and honesty in line with Operation Encompass guidelines – a charitable organisation set up in 2011, to enable effective interventions for many thousands of children who've experienced domestic abuse. 

The Service is currently reviewing how it can effectively share the list of enrolled learners and those who are referred following withdrawal from another organisation. Once this process is established the Service will be provided with updates as part of Police attendance reporting strategies.

5.16 Searching, Screening and Confiscation

5.16.1 Where necessary, searching, screening and confiscation will be used to safeguard a child or young person within the Coventry Adult Education Service.

5.16.2  Coventry Adult Education Service adheres to ‘Searching, screening and confiscation: Advice for Schools (January 2018), providing the authority to search from the Service Lead to the DSL and DDSL for the lawful reasons to search an individual as outlined within the policy linked below on page 4

5.17 Online Safety

5.17.1 Coventry Adult Education service recognises that in today’s world, children and young people need to be safeguarded from potentially harmful and inappropriate online material with many children having unlimited and unrestricted access to the internet via their mobile phone. The breadth of issues can be categorised currently into four areas of risk as taken from Keeping Children Safe in Education 2022

• Content – being exposed to illegal, inappropriate, or harmful content (pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, and extremism)
• Contact – being subject to harmful online interaction with other users (peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit)
• Conduct – online behaviour that increases the likelihood of, or causes, harm (making, sending and receiving explicit images)
• Commerce – risks such as online gambling, inappropriate advertising, phishing and or financial scams

5.17.2 Coventry Adult Education service understand that the above can take place on a learners’ phone or smart device (including smart watches) whilst at the training provider, or elsewhere. The service has responded to this by having a whole service approach to online safety which aims to protect and educate learners, parents, and staff in their use of technology The Study Programme learner conduct policy and CCCs acceptable use of ICT facilities policy, alongside online safety is delivered within the curriculum as part of the Be Safe induction programme for all leaners.

Study Programmes, where learners receive face-to-face online safety workshops that encompasses, their own safety, the safety of others online, profile development and risks e.g., Catfish and the dangers of social media, is regularly reinforced through termly quizzes, posters, and activities. Our Online Safety Policy and Acceptable Use of ICT Policy can be found on our website (link in Annex A).

5.17.3 Coventry Adult Education service has also established mechanisms via the Coventry Councils ‘Smoothwall’ to limit inappropriate website access and where tutors’ express concerns of the material accessed during sessions they will identify, intervene, and escalate these to their line manager and ultimately to the DSL / DDSL. The effectiveness of this is regularly reviewed with processes reiterated as to how to escalate concerns and the effectiveness of solutions is analysed.

5.18 To raise concerns about children or young person, members of staff should contact the Multi-Agency Safeguarding Hub (MASH) by telephone to discuss the referral. They should then complete the online Multi-Agency Referral Form (MARF) and submit this to the MASH. The service will follow up referrals if we do not receive feedback from Children’s Services to ascertain the outcome of all referrals.

MASH Telephone number: 02476 788 555
MASH online referral form: http://www.coventry.gov.uk/safeguardingchildren
Out of hours Emergency Duty Team: 02476 832 222
Prevent/Channel Referrals: Refer to MASH
(mash@coventry.gov.uk) and to CTU_GATEWAY@west-midlands.pnn.police.uk

5.18.1 If a child’s or young person’s situation does not appear to be improving following a referral, the service may re-refer the child. We will also consider using the Coventry Safeguarding Children Partnership’s Managing Professional Disagreements policy to ensure that our concerns have been addressed and that the situation improves for the child.