NSEGTA is committed to safeguarding and promoting the welfare of children and vulnerable adults.  The term ‘apprentices / learners’ is used throughout this Policy to cover all ages of individuals as NSEGTA work with post 16 learners who have left full-time education and Adults.

All staff who come into contact with apprentices / learners have a role to play in identifying concerns, sharing information and have a duty to take prompt action.

NSEG promotes this safeguarding policy to all its staff and encourages members, employers and key stakeholders to read and understand the policy.  This policy can be found on our website www.nsegta.co.uk  and is also available on request.

This policy is committed to following the following statutory guidance:

• Working Together to Safeguard Children 2018, which sets out the statutory functions of the local authority under the 1989 and 2004 Children’s Acts (recognising that we are an important part of the local authorities’ wider safeguarding systems).
• Keeping Children Safe in Education 2024, statutory guidance from the Department of Education, including, What to Do if You are Worried a Child is being Abused.
• Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012, which aims to help avoid harm, or risk of harm, by preventing people who are deemed unsuitable to work with children from gaining access to them through their work.
• Counterterrorism and Security Act 2015, which under section 26 requires NSEGTA, as a Training Provider, to have due regard to the need to prevent people from being drawn into terrorism, along with Revised Prevent Duty Guidance: for England and Wales and Prevent Duty Guidance: for further education institutions in England and Wales.

Principles

NSEGTA Safeguarding policy and procedure is based on the following principles:

• An ethos that promotes a positive, supportive and secure environment where apprentices / learners feel protected and valued at both NSEGTA and in their place of work.
• All allegations and suspicions of abuse towards staff, apprentices / learners, employers or key stakeholders will be taken seriously, and responded to swiftly and appropriately.
• Liaison with other agencies that support learners, such as social/children’s services

There are five main elements to this policy:

• Ensuring that NSEGTA practices safe recruitment in checking the suitability of staff to work with young people and vulnerable adults
• Raising awareness of child protection issues amongst staff
• Developing and implementing procedures for identifying and reporting cases or suspected cases of child abuse and how to record / investigate them
• Supporting the young person or vulnerable adult who has been abused
• Establishing a safe environment in which young people and vulnerable adults can learn and develop, where they are able to talk and be listened to.

Definitions

The following definitions apply throughout the Safeguarding policy and associated procedures:

Child or Children:

The Children Act 1989/2004 defines a child as a person under eighteen for most purposes.

Vulnerable Adult or Adults:

The Protection of Vulnerable Adults Scheme (PoVA 2004) defines a vulnerable adult as a person aged 18 or over who has a condition of the following type:

• A substantial learning or physical disability
• A physical or mental illness or mental disorder, chronic or otherwise including addiction to alcohol or drugs
• A significant reduction in physical or mental capacity

Definitions and Indicators of Abuse

Physical Abuse:

Physical abuse may take many forms e.g. hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. This unusual and potentially dangerous form of abuse is now described as fabricated or induced illness.

The following may be indicators of physical abuse (but not limited to):

• Multiple bruises in clusters, or of uniform shape
• Bruises that carry an imprint, such as a hand or a belt
• Bite marks
• Round burn marks
• Multiple burn marks on unusual areas of the body such as the back, shoulders, or buttocks
• An injury that is not consistent with the account given
• Changing or different accounts of how an injury occurred
• Bald patches
• Symptoms of drug or alcohol intoxication or poisoning
• Unaccountable covering of limbs, even in hot weather
• Fear of going home or parents being contacted
• Fear of medical help
• Fear of changing for PE
• Inexplicable fear of adults or over-compliance
• Violence or aggression towards others including bullying; or
• Isolation from peers

Emotional Abuse:

Emotional abuse is persistent emotional maltreatment causing severe and persistent effects on the child’s emotional development.  It may involve conveying the message that they are worthless or unloved, inadequate or valued only in so far as they meet 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 expectation being imposed on a child.  These may include interactions that are beyond the 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 also involve seeing or hearing the ill-treatment of another person.  It may involve serious bullying (including cyber bullying), causing children to feel frightened or in danger.

The following may be indicators of emotional abuse (but not limited to):

• The child consistently describes him/herself in very negative ways – as stupid, naughty, hopeless, ugly, fat
• Over-reaction to mistakes
• Delayed physical, mental, or emotional development
• Sudden speech or sensory disorders
• Inappropriate emotional responses, fantasies
• Neurotic behaviour: rocking, banging head, regression, tics and twitches
• Self-harming, drug, or solvent abuse
• Fear of parents being contacted
• Running away
• Compulsive Stealing
• Appetite disorders – anorexia nervosa, bulimia; or
• Soiling, smearing faeces, enuresis

Some level of emotional abuse is involved in most types of ill treatment, although emotional abuse may occur alone.

Sexual Abuse:

Sexual abuse involves forcing or enticing a child to take part in sexual activities, not necessarily involving a high level of violence, whether they are 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 (including via the internet).  Sexual abuse is not solely perpetrated by adult males.  Women can also commit acts of sexual abuse, as can other children.

The following may be indicators of sexual abuse (but not limited to):

• Sexually explicit play or behaviour or age-inappropriate knowledge
• Anal or vaginal discharge, soreness, or scratching
• Reluctance to go home
• Inability to concentrate, tiredness
• Refusal to communicate
• Thrush, persistent complaints of stomach disorders or pains
• Eating disorders, for example anorexia nervosa and bulimia
• Attention seeking behaviours, self-mutilation, substance abuse
• Aggressive behaviour including sexual harassment or molestation
• Unusual compliance
• Regressive behaviour, enuresis, soiling
• Frequent or open masturbation, touching others inappropriately
• Depression, withdrawal, isolation from peer group
• Reluctance to undress for PE or swimming: or
• Bruises or scratches in the genital area

Refer to Appendix 1 – Sexual violence and sexual harassment between children.

Domestic Abuse

Any incident or pattern of incidents of controlling, coercive or 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. This can encompass but is not limited to the following types of abuse:

• Psychological
• Physical
• Sexual
• Financial
• 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) Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and 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. Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.

We will signpost and support any Child when domestic abuse is disclosed.

Child on child abuse:

Child on child abuse can occur, both physically and verbally, either online or face to face, between two children of any age and sex, with a single child or group of children and can happen both inside and outside of our training centre.  Children, who are victims of this abuse, will find the experience stressful and distressing and it is likely to have an adverse effect on their educational attainment.  This type of abuse can exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are not acceptable behaviour.

The following may be indicators of child on child abuse (but not limited to):

• bullying (including cyberbullying, prejudice-based and discriminatory bullying).
• abuse in intimate personal relationships between peers.
• physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse).
• sexual violence such as rape, assault by penetration and sexual assault and may include an online element which facilitates, threatens and/or encourages sexual violence. Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.
• sexual harassment such as sexual comments, remarks about clothes and/or appearance, jokes, taunting and online sexual harassment. This also includes the telling of sexual stories, making lewd comments and calling someone sexual names and physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes, and displaying pictures, photos or drawings of a sexual nature; and online sexual harassment.
• causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.
• consensual and non-consensual sharing of nudes and semi-nude images and or videos (also known as sexting or youth produced sexual imagery) Consensual image sharing, especially between older CYP of the same age, may require a different response. It might not be abusive – but CYP still need to know it is illegal- whilst non-consensual is illegal and abusive.
• upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress, or alarm; and
• initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

All staff are clear to NSEGTA’s policy and procedures with regards to child-on-child abuse and the important role they play in preventing it and responding where they believe a child may be at risk from it.

If staff have a concern about a child, they will follow the safeguarding referral process.  If staff are in any doubt as to what to do, they should speak to the DSL.

The DFE states child on child abuse should be taken as seriously as abuse by adults and should be subject to the same child protection procedures.

Neglect:

Neglect is the persistent failure to meet basic physical and/or psychological needs, likely to result in serious impairment of the child health and development. This may involve failing to:

• Provide adequate food, shelter and clothing
• Protect from physical harm or danger
• Ensure adequate supervision
• Ensure access to appropriate medical care or treatment.

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

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

Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a 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 or facilitator and/or through violence or the threat of violence.

CSE and CCE can affect children, both male and female and can include those who have been moved (commonly known as trafficking) for the purpose of exploitation.

Child Criminal Exploitation (CCE)

Some forms of CCE can include young people being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, or pickpocketing.  They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Individuals can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into dept.  The may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm, from others.  Individuals involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, and they are not treated as victims despite the harm they have experienced.

The experience of girls who are criminally exploited can be different to that of boys.  The indicators may not be the same; however, professionals should be aware that girls are at risk of criminal exploitation too.  It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

The following may be indicators of CCE (but are not limited to):

• Unexplained gifts or new possessions
• Associate with other young people involved in exploitation
• Changes in emotional well-being
• Misuse drugs and alcohol
• Missing for periods of time or regularly come home late
• Regularly miss education or do not take part in education

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.
• 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.

Child Sexual Exploitation (CSE)

CSE is a form of sexual abuse.  Sexual abuse 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 clothing.  It may include non-contact activities, such as to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse including via the internet.

CSE can occur over time or be a one off occurrence and may happen without the immediate knowledge e.g. through others sharing videos or images of them on social media.

CSE can affect and child, who has been coerced into engaging in sexual activities.  This includes 16 and 17 year olds who can legally consent to have sex.  Some children may not realise they are being exploited e.g. they believe they are in a genuine romantic relationship.

The above CCE indicators can also be signs of CSE, as can having older boyfriends or girlfriends and/or suffering from sexually transmitted infections/becoming pregnant.

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 phones or other forms of deal lines.

Exploitation is an integral part of the county lines offending model with Children exploited to move and/or 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 several 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 their place of work or study), when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism (NRF) 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.

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.

Prevent & Promoting British Values

NSEGTA is committed to protecting learners from extreme violent ideologies by:

• Ensuring external speakers and events are appropriately risk assessed
• Establishing effective partnerships with Local Authorities and Staffordshire Counter Terrorism Unit
• Ensuring appropriate safeguarding / prevent training is provided to all staff and regular refresher training is provided (at least every 2 years)
• Ensuring there is a clear, documented response to any concerns raised, including the referrals to Channel
• Developing an awareness of prevent in NSEGTA

Please refer to NSEGTA’s Prevent Policy for further information on protecting children at risk of radicalisation.

Duty to report

All members of staff at NSEGTA are responsible for safeguarding and promoting the welfare of children.

All Staff:

All staff that come into contact with children in their everyday work has a duty to safeguard and promote the welfare of children. Staff are trained to understand their responsibilities and to act without delay. Failure to comply with their responsibilities will be seen as a serious matter which may lead to disciplinary action.

All Staff are:

• Expected to attend safeguarding training as required (every two years as a minimum)
• To familiarise themselves with the Safeguarding Policy and associated procedures at induction and after any update
• To read and have a good understanding of at least part 1 of Keeping Children Safe in Education 2024
• Aware of their responsibility to provide a safe environment in which apprentices / learners can learn.
• Know who the Designated Safeguarding Lead or Designated Safeguarding Officer is, and know that as well as being the expert in this field; they are there to support staff.
• Are aware of indicators / signs of abuse and neglect and understand that apprentices / learners can be at risk of harm inside and outside of their workplace and / or NSEGTA, inside and outside of their home and online. Staff know what to look for which is vital for identifying early signs of abuse and neglect for individuals that may be in need of our help or protection.
• Know what to do if a student tells them they are being abused, exploited, or neglected. Staff know how to maintain an appropriate level of confidentiality by only involving those who need to be involved, such as the SDL / DSO.  Staff never promise an apprentice / learner that they will not tell anyone about a report of abuse, as this may ultimately not be in their best interest.
• Know how to reassure victims that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting any form of abuse and/or neglect nor should a victim ever be made to feel ashamed for reporting abuse and/or neglect.

In all cases, if our staff are unsure, they know that they should always speak to the DSL/SDO.

NSEGTA Designated Safeguarding Lead (DSL) / Designated Safeguarding Officer (DSO)

Sarah Stanway, Chief Executive Officer (CEO), is the Designated Safeguarding Lead (DSL) is responsible for safeguarding children and acting on safeguarding issues and reporting issues to external agencies.

The DSL acts as a source of support, advice, and expertise for staff.  Risk assessments / safety plans will be completed as required and where appropriate will involve other agencies.

The ultimate responsibility for safeguarding and child protection remains with the DSL; however, the DSL may delegate activities to the DSO.

The DSL ensures all staff and regular visitors have appropriate safeguarding training and information to equip them for their role.

Duncan Maydew, Head of Operations, is the Deputy Safeguarding Officer (DSO) is responsible for safeguarding children and acting on and reporting safeguarding issues to the CEO or relevant external agencies.  In the absence of the DSL, the DSO will take the lead on safeguarding.

The DSL / DSO have received appropriate safeguarding training to provide them with an understanding of their role and the knowledge and skills to carry out the role.  The DSL and DSO are both trained to the same level.  This training is updated at least every 2 years and in addition to this, they regularly refresh their knowledge and skills.

For full details of the DSL / DSO roles and responsibilities please refer to Part 2 & Annex C of keeping Children Safe in Education 2024.

The DSL / DSO are responsible for referring individuals to external agencies such as:

• Children’s Advice and Duty Service, (ChAd) Stoke on Trent – Tel 01782 235100 (office hours) or

01782 234234 (out of office hours) or email CHAD.Referrals@stoke.gov.uk

• Staffordshire Children’s Advice and Support Team – Tel 0800 1313 126 (office hours) or

0345 6042 886 (out of office hours)

• Police – 999
• Child Line – Tel 0800 1111 helpline
• NSPCC – Tel 0808 800 5000 helpline

Local Authority Designated Safeguarding Officer

The Designated Safeguarding Officers are responsible for providing support, advice and expertise on safeguarding issues, and are responsible for dealing with allegations or suspicions of reported abuse.

The DSO’s attend regular safeguarding training (every two years as a minimum) including Multi-Agency Level 2 working together to safeguard children.

Other aspects of their role include:

• Obtaining information from staff, volunteers, children, parents, carers who have concerns relating to the protection of children, and to formally record this information
• Assessing information quickly and carefully and asking for further information where appropriate
• Consulting with a statutory child protection agency e.g. the local social services department, to clarify doubts and worries
• Making referrals to statutory child protection agencies or the police without delay
• Designated Safeguarding Officers have contact numbers for the local Area Safeguarding Children’s Board and other statutory agencies.

The Chief Executive Officer:

The CEO is responsible for:

• Ensuring that all apprentices / learners receive an induction and an induction booklet prior to starting their programme. As part of the induction staff must make all apprentices / learners aware of the procedure for reporting a safeguarding concern or how they can access support or guidance.  They are also provided with the contact details for the Designated Safeguarding Lead and the confidential safeguarding email address (which is accessed by the CEO) should they need to report any incident.
• Ensuring that staff make all apprentices / learners and employers aware of NSEGTA’s Safeguarding Policy and the process for reporting an incident.
• Ensuring the policy is readily available on our website for apprentices / learners, employers and key stakeholders to access.
• Ensuring NSEGTA Safeguarding Policy and Procedures are reviewed annually or sooner should legislation / guidance change and all staff are fully committed to support and follow the policy and procedures.
• Ensuring all staff receive appropriate safeguarding training (at least every 2 years) and are aware of the organisation’s procedures.
• Ensuring all staff have read and have a good understanding of at least part 1 of Keeping Children Safe in Education 2024.
• Identifying deputy designated safeguarding staff and ensure they are appropriately trained.
• Ensuring the designated safeguarding lead or a deputy is available at all times to allow staff, apprentices / learners to discuss / report safeguarding concerns.
• Ensuring that adequate and appropriate cover is available for out of hours activities.
• Ensuring Safeguarding Officers have sufficient time and resources to carry out their role effectively.
• Making sure that all staff feel able to raise concerns about the safety of children.
• Providing advice and support to other staff on issues relating to child or adult at risk protection.
• Ensuring concerns are dealt with sensitively, effectively and in a timely manner.
• Maintaining a proper record of any child/adult protection referral, complaint or concern, even where that concern does not lead to an external referral.
• Carrying out a risk assessment (if deemed necessary) for reported incidents of sexual harassment.
• Overseeing the referral of cases of suspected abuse or allegations to proper authorities i.e. liaising with The Stoke on Trent Children’s Safeguarding Board, Local Authority, Social Services, Police and The Midlands Partnership Foundation NHS Trust for Adults and any other appropriate agencies.
• Ensuring that parents of children and young people within the organisation are aware of the organisations safeguarding policy.
• Ensuring all children are safe whilst visiting NSEGTA. Internet safety training will be provided prior to learners using their IT equipment to accesses online resources.  Internet filters and IT support is managed offsite by our IT provider.

Confidentiality

Staff should never give absolute guarantees of confidentiality to children wishing to tell them about something serious. They should however guarantee that they will only pass on information to the minimum number of people who must be told in order to ensure that the proper action is taken to protect the child.

What to do if you suspect someone is being abused

All staff working in direct contact with learners must be alert to the signs of abuse. Anyone who suspects that abuse is taking place inside or outside of the setting, or to whom a learner discloses issues relating to safeguarding, should contact the CEO. If the problem concerns the CEO, any problem should be reported to the Chairman of the Group.

Staff who are not the Designated Safeguarding Lead (DSL) or Designated Safeguarding Officer (DSO), but who are approached with concerns about a child, must bring the concerns raised to the attention of the DSL immediately or the DSO. All staff to whom a learner discloses issues that may be related to safeguarding must keep written records of concerns. Such records must be kept securely, separate from the main learner files and in locked locations.

The DSL / DSO will develop effective links with relevant agencies and co-operate as required with any enquiries regarding child protection matters, including attendance at case conferences.

If an allegation reported is of a learner abusing another learner, then the accused learner will be suspended pending investigations by NSEGTA whom may involve social services or the police.

Allegations of abuse against members of staff

Allegations of abuse, or concerns raised against members of staff, will always be treated seriously.  The allegation must always be referred to one of the Designated Safeguarding Officers who will follow the Safeguarding Procedure in the same way as for other safeguarding allegations.

The Designated Safeguarding Officer will take the appropriate steps to ensure the safety of the child, and any others who may be at risk. The Designated Safeguarding Officer will ensure that all procedures are followed when managing a disclosure from the learner and a Disciplinary Investigation will be carried out by the CEO.

If the allegation or concern is against one of the DSL or DSO, it should be reported to the Chairman.  Where a member of staff does not feel confident to raise their concerns with the CEO or Chairman they know to contact the LADO on 0300 111 8007.

Where there is a complaint against a member of staff there may also be criminal (police) investigations and/or a child protection investigation carried out by Social Services.

All allegations that are made against a member of staff must be reported to the CEO in the first instance.  The CEO will seek advice from the Local Authority Designated Officer (LADO) within one working day on (0300 111 8007).

If a concern means an apprentice / learner is at immediate risk, then the individuals needs to contact Staffordshire Children’s Advice and Support Team on (0300 111 8007).

Reporting cases to the Independent Safeguarding Authority

NSEGTA has a statutory duty to make reports, and provide relevant information to the Independent Safeguarding Authority (ISA) where there are grounds for believing, following an investigation, that an individual is unsuitable to work with children, or may have committed misconduct. The responsibility for reporting cases to the ISA lies with the CEO.

The Independent Safeguarding Authority make barring decisions for Section 142 of the Education Act (formally known as List 99), The Protections of Children Act List (PoCA) and the Protection of Vulnerable Adults List (PoVA).

Safe recruitment of staff

NSEGTA undertakes too ensure that staff are fit to work with children. We also reserve the right to refuse to employ staff who we believe may pose a risk to our learners.

NSEGTA has systems in place to prevent unsuitable people from working with children and to promote safe practice. These systems apply to contractors working on site, volunteers and all new staff.  The following scrutinising checks are made prior to their appointment:

• Firstly, an interview will be undertaken to identify their suitability
• A minimum of 2 professions references, one of which should be from their previous employer and 1-character reference
• Documentary evidence checks to verify their identity, confirm nationality, residency and ‘right to work’ status
• Enhanced DBS checks* / compliance with the Disclosure & Barring Service (DBS) regulations
• Documentary evidence of academic or vocational qualifications
• Satisfactory completion of the probationary period as defined in their letter of appointment
• Ensuring the individual has the health and physical capacity for the job

*The Further Education (Providers of Education) England Regulations 2006 place a duty on colleges and FE training providers to undertake an Enhanced Criminal Records Bureau Disclosure for all new staff providing education, training or care to children, young people or vulnerable adults. An Enhanced Disclosure is carried out for staff who regularly care for, supervise, train or are in sole charge of children or vulnerable adults.

For individuals who have lived outside of the UK, further checks are carried out, where appropriate, if a CRB Disclosure is not felt to be sufficient to establish suitability to work with children, young people or vulnerable adults.

In accordance with the Regulations, records of all checks carried out are kept centrally by the HR Manager.

On appointment, all staff receive a full induction, which includes:

• A copy of this policy is provided to all staff, alongside our staff code of conduct policy.
• All staff who work directly with our apprentices / learners, are provided with safeguarding / prevent training, any other training that may be identified. All staff are encouraged to undertake CPD to update their skills and knowledge and are provided with refresher training (at least every 2 years).
• All staff who work directly with our apprentices / learners have read at least part one of keeping Children Safe in Education 2024.

Vetting and barring scheme

The Vetting and Barring Scheme is a system run by the government and may be subject to change. For up-to-date information and further explanation, please visit https://www.gov.uk/government/organisations/disclosure-and-barring-service/about

Apprenticeship courses may involve regular access to children and/or vulnerable adults, also known as regulated activity.

NSEGTA is committed to safeguarding children and vulnerable adults. All staff working with children or vulnerable adults will be registered with the Governments Vetting and Barring Scheme to complete a DBS check.  This DBS check will be completed at least every 3 years. It is the responsibility of all staff to report to the CEO immediately any changes in circumstance that could affect future DBS checks.

Staff Training and Development

All staff who come into direct contact with learners must undertake training (at least every two years) on the subject of safeguarding and the centre procedures. This Safeguarding policy, procedure and accompanying guidance will be issued to all new staff as part of their induction.

Registrations:

If, during the course of an investigation relating to safeguarding, an employee tenders his/her resignation, or ceases to provide their services, NSEGTA is not prevented from following up an allegation in accordance with these procedures. Every effort will be made to reach a conclusion in cases relating to the welfare of children or vulnerable adults, including those where the person concerned refuses to co-operate with the process.

Support for staff:

NSEGTA is aware that safeguarding cases can be distressing and that staff who have been involved may find it helpful to talk about their experiences, in confidence, with our Designated Safeguarding Officer.

Equality of Opportunity:

All children and vulnerable adults, have the right to be safeguarded from harm and exploitation whatever their race, religion, gender, sexuality, age or disability. This policy relates to NSEGTA legal obligation to protect children who are suffering forms of abuse as defined in the Children Act 1989-2004 and is therefore in line with the centres equality and diversity policies.

Learners

To safeguard children and vulnerable adults whilst visiting NSEGTA all learners must:

• Sign in on arrival and wear a learner lanyard at all times
• Be supervised on site at all times
• Only be allowed access to the control room, workshops and classrooms and will not be allowed access to restricted areas unless accompanies by a member of staff

Visitors

To safeguard children and vulnerable adults whilst visiting NSEGTA all visitors must:

• Sign in on arrival and wear a visitor lanyard at all times
• Be supervised on site at all times
• Only be allowed access to meeting rooms and will not be allowed access to restricted areas unless accompanied by a member of staff.

Employers

To safeguard our apprentices / learners NSEGTA visit all new employers to complete a risk assessment for Health & Safety.

All employers are made aware of our safeguarding policy prior to any apprentice / learner being signed up on programme.  Managers / Mentors also attend regular progress review meetings with their apprentice / employee and the NSEG Training Officer / Tutor where safeguarding is a topic for discussion.  This discussion will raise the awareness of safeguarding and hopefully prevent any abuse towards the apprentice / learner in the company.

Approved and signed by:

Sarah Stanway

Sarah Stanway

Chief Executive

Reviewed 1^st April 2025

(to be reviewed January 2026)

Addendum:

Primes to be made aware of any incidents (if applicable).

Appendix 1

                    Sexual violence and sexual harassment between children

Context

• Sexual violence and sexual harassment 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 physically and verbally) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support.
• Reports of sexual violence and sexual harassment are extremely complex to manage. It is essential that victims are protected, offered appropriate support and every effort is made to ensure their education is not disrupted. It is also important that other children, adult learners and staff are supported and protected as appropriate.

NSEG will:

• make clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up.
• not tolerate or dismiss sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”.
• challenge behaviour (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia and flicking bras and lifting up skirts.
• understand that all of the above can be driven by wider societal factors beyond NSEGTA, such as everyday sexist stereotypes and everyday sexist language.

SEND

• Children with Special Educational Needs and Disabilities (SEND) are three times more likely to be abused than their peers. Additional barriers can sometimes exist when recognising abuse in SEND children. These can include:

• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child’s disability without further exploration.
• the potential for children with SEND being disproportionately impacted by behaviours such as bullying and harassment, without outwardly showing any signs.

• Any reports of abuse involving children with SEND will therefore require close liaison with the Designated Safeguarding Officer (or deputy).
• Children who are lesbian, gay, bi, or trans (LGBT) can be targeted by their peers. In some cases, a child who is perceived by their peers to be LGBT (whether they are or not) can be just as vulnerable as children who identify as LGBT.

Definitions

Children: When referring to children, we are referring to both children and vulnerable adults.

Sexual violence: When referring to sexual violence, we do so in the context of child on child sexual violence.

When referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003 as described below:

Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents.

Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents.

Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents.

What is consent? Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g.to vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.

• a child under the age of 13 can never consent to any sexual activity
• the age of consent is 16
• sexual intercourse without consent is rape

Sexual harassment

• Sexual harassment refers to ‘unwanted conduct of a sexual nature’ that can occur online and offline and is referred to in the context of child on child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. Whilst not intended to be an exhaustive list, sexual harassment can include:
• sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names.
• sexual “jokes” or taunting.
• physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes and displaying pictures, photos or drawings of a sexual nature.
• online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence.

Online sexual harassment may include:

• non-consensual sharing of sexual images and videos
• sexualised online bullying
• unwanted sexual comments and messages, including, on social media
• sexual exploitation; coercion and threats
• Sexual harassment creates an atmosphere that, if not challenged, can normalise inappropriate behaviours and provide an environment that may lead to sexual violence

Harmful sexual behaviour

• Children’s sexual behaviour exists on a wide continuum, from normal and developmentally expected to inappropriate, problematic, abusive and violent. Problematic, abusive and violent sexual behaviour is developmentally inappropriate and may cause developmental damage.
• Harmful sexual behaviour can occur online and/or offline and can also occur simultaneously between the two and should be considered in a child protection context.
• When considering harmful sexual behaviour, ages and the stages of development of the children are critical factors to consider. Sexual behaviour between children can be considered harmful if one of the children is much older, particularly if there is more than two years’ difference however, a younger child can abuse an older child, particularly if they have power over them, for example, if the older child is disabled.
• Children displaying harmful sexual behaviour have often experienced their own abuse and trauma. It is important that they are offered appropriate support.

The immediate response to a report

Responding to the report

• The initial response to a report from a child is important. It is essential that all victims are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report.
• In some cases, the victim may not make a direct report. For example, a friend may make a report or a member of staff may overhear a conversation that suggests a child has been harmed. It is important that in such instances staff take appropriate action personally by reporting these concerns to the Designated Safeguarding Officer (or deputy) In such cases, the basic safeguarding principles remain the same, but it is important to understand why the victim has chosen not to make a report themselves. This discussion should be handled sensitively and with the support of children’s social care if appropriate.
• Where reports of alleged sexual violence or sexual harassment involves learners from NSEGTA, but is alleged to have taken place away from NSEGTA premises, or online appropriate information sharing and effective multi-agency working will be especially important.

Considering confidentiality and anonymity

Confidentiality

• Staff taking a report should never promise confidentiality as it is very likely that it will be in the best interests of the victim to seek advice and guidance from others in order to provide support and engage appropriate agencies.
• The designated safeguarding lead (or a deputy) will consider the following:

• parents or carers should normally be informed (unless this would put the victim at greater risk).
• the basic safeguarding principle is: if a child is at risk of harm, is in immediate danger, or has been harmed, a referral should be made to children’s social care.
• rape, assault by penetration and sexual assaults are crimes. Where a report of rape, assault by penetration or sexual assault is made, this should be referred to the police.

Anonymity

• NSEGTA will do all it reasonably can to protect the anonymity of any children involved in any report of sexual violence or sexual harassment. Amongst other things, this will mean carefully considering, based on the nature of the report, which staff should know about the report and any support that will be put in place for the children involved.

Risk Assessment

• When there has been a report of sexual violence, the designated safeguarding officer (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.

The risk and needs assessment will consider:

• the victim, especially their protection and support
• the alleged perpetrator
• all the other children (and, if appropriate, adult learners and staff), especially any actions that are appropriate to protect them

• Risk assessments will be recorded (written or electronic) and will be kept under review.
• At all times NSEGTA will actively consider the risks posed to all learners and putting adequate measures in place to protect them and keep them safe.
• The designated safeguarding officer (or deputy) will ensure engagement with children’s social care and specialist services as required. Where there has been a report of sexual violence, it is likely that professional risk assessments by social workers and or sexual violence specialists will be required.
• Professional assessments will be used to inform NSEGTA’s approach to supporting and protecting learners and updating NSEGTA risk assessment.

Action following a report of sexual violence and/or sexual harassment

What to consider

• The designated safeguarding officer (or deputy) is likely to have a complete safeguarding picture and be the most appropriate person to advise on NSEGTA’s initial response.

Important considerations will include:

• the wishes of the victim in terms of how they want to proceed. This is especially important in the context of sexual violence and sexual harassment. Victims should be given as much control as is reasonably possible over decisions regarding how any investigation will be progressed and any support that they will be offered.
• the nature of the alleged incident(s), including: whether a crime may have been committed and consideration of harmful sexual behaviour.
• the ages of the children involved.
• the developmental stages of the children involved.
• any power imbalance between the children. For example, is the alleged perpetrator significantly older, more mature or more confident? Does the victim have a disability or learning difficulty?
• is the alleged incident a one-off or a sustained pattern of abuse?
• are there ongoing risks to the victim, other children, adult learners or NSEGTA staff?

Children sharing a classroom / premises: Initial considerations when the report is made

• Any report of sexual violence is likely to be traumatic for the victim. However, reports of rape and assault by penetration are likely to be especially difficult with regard to the victim and close proximity with the alleged perpetrator is likely to be especially distressing. Whilst NSEGTA establishes the facts of the case and starts the process of liaising with children’s social care and the police, the alleged perpetrator will be removed from any classes they share with the victim.

• NSEGTA will also consider how best to keep the victim and alleged perpetrator a reasonable distance apart on NSEGTA premises and on transport to and from NSEGTA, where appropriate. These actions are in the best interests of both children and should not be perceived to be a judgment on the guilt of the alleged perpetrator.
• For other reports of sexual violence and sexual harassment, the proximity of the victim and alleged perpetrator and considerations regarding shared classes and sharing premises should be considered immediately.

Options to manage the report

• Each report will be considered on a case by case basis and will include careful consideration of when to inform the alleged perpetrator. Where a report is going too made to children’s social care and/or the police NSGETA will seek advice on when and how the alleged perpetrator will be informed. This will not stop NSEGTA taking immediate action to safeguard children where required.
• There are four likely scenarios for NSEGTA to consider when managing any reports of sexual violence and/or sexual harassment:

1. Manage internally
2. Early help
3. Referrals to children’s social care
4. Reporting to the police

Ongoing response

For information on good practice in managing the ongoing response to reports of sexual violence and sexual harassment NSEGTA will use the advice published in the Department for Educations in their document ‘Sexual violence and sexual harassment between children in schools and colleges’ May 2018.

The advice in this document will be used to inform actions around:

1. Safeguarding and supporting the victim
2. Safeguarding and supporting the alleged perpetrator
3. Discipline and the alleged perpetrator
4. Working with parents and carers
5. Safeguarding other children