Safeguarding

Updated on: Tue May 2, 2023

5.4 DSL/Principal

Is responsible for the implementation of this policy, including:

• Ensuring that staff (including temporary staff/exam invigilators) and volunteers are informed of our systems which support safeguarding, including this policy, as part of their induction
• Communicating this policy to parents when their child joins the school and via the school website/firefly. 
• Ensuring that all staff undertake appropriate safeguarding and child protection training and update this regularly
• Acting as the ‘case manager’ in the event of an allegation of abuse made against another member of staff or volunteer, where appropriate. 

6. Confidentiality

• Timely information sharing is essential to effective safeguarding
• The Data Protection Act (DPA) 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe
• If staff need to share ‘special category personal data’, the DPA 2018 contains ‘safeguarding of children and individuals at risk’ as a processing condition that allows practitioners to share information without consent if it is not possible to gain consent, it cannot be reasonably expected that a practitioner gains consent, or if to gain consent would place a child at risk
• Staff should never promise a child that they will not tell anyone about a report of abuse, as this may not be in the child’s best interest
• If staff are in any doubt about sharing information, they should speak to the designated safeguarding lead (or deputy)

7. Recognising abuse and taking action

Staff must follow the procedures set out below in the event of a safeguarding issue.

Please note – in this and subsequent sections, you should take any references to the DSL to mean “the DSL (or deputy DSL)”.

7.1 If a child makes a disclosure to you

If a child discloses a safeguarding issue to you, you should:

• Listen to and believe them. Allow them time to talk freely and do not ask leading questions
• Stay calm and do not show that you are shocked or upset
• Tell the child they have done the right thing in telling you. Do not tell them they should have told you sooner
• Explain what will happen next and that you will have to pass this information on. Do not promise to keep it a secret
• Complete a disclosure form (Appendix 1) as soon as possible. Stick to the facts, and do not put your own judgement on it. Send to the DSL in all cases, follow-up activities will be conducted in a manner that ensures that information is documented factually and that strict confidentiality is maintained. 

The following procedure will be used:

• Interview staff members as necessary and document information relative to the case.
• Consult with iSAMS to review the child’s history in school.
• Determine the course of follow-up actions, potentially contacting the parents of the child
• Completing a "Child maltreatment detection and notification sheet".

In most circumstances when a child alleges abuse the DSL will notify the parents at the earliest opportunity. However, in certain circumstances (usually in response to an allegation of physical or sexual abuse within the family) referral to Children’s Social Care Services (or to the Police) will be made first and a "Child maltreatment detection and notification sheet" will be completed.

In Spain: Institution: Delegación de Bienestar Social /Marbella: Estefania Martin 

Address: Avenida Velazquez Clavel 25, Marbella Tel: 952 900 493.

All other details, documents, images and any other evidence shall be logged via the iSAMS Wellbeing Module.

All documentation of the investigation will be kept confidential and will be stored.

7.2 If you have concerns about a child (as opposed to believing a child is suffering or likely to suffer from harm, or in immediate danger)

• Please create concern in the WellBeing Manager. This concern should be made regarding a child's wellbeing.  Please assign it to the relevant or connected staff.  The Well Being Unit in ISAMS is used tp log safeguarding concerns and issues for students and assists in the recording of important information which may have an impact on students’ behavior and performance.
• Staff need to respond and record any actions from any assigned concerns. 
• These concerns will be monitored by the WellBeing Team and DSL. 

Early help

If early help is appropriate, the DSL will generally lead on liaising with other agencies.

The DSL will keep the case under constant review and the school will consider a referral to local authority children’s social care if the situation does not seem to be improving. Timelines of interventions will be monitored and reviewed within iSams.

Referral

If it is appropriate to refer the case to local authority children’s social care or the police, the DSL will make the referral or support you to do so.

The DSL or person who made the referral must follow up with the local authority if this information is not made available, and ensure outcomes are properly recorded. 

If the child’s situation does not seem to be improving after the referral, the DSL or person who made the referral must follow local escalation procedures to ensure their concerns have been addressed and that the child’s situation improves.

7.3 If you have concerns about extremism

If a child is not suffering or likely to suffer from harm, or in immediate danger, where possible speak to the DSL first to agree on a course of action.

If in exceptional circumstances the DSL is not available, this should not delay appropriate action being taken. Speak to a member of the senior leadership team and/or seek advice from local authority children’s social care. Make a referral to local authority children’s social care directly, if appropriate (see ‘Referral’ above).

7.4 Concerns about a staff member or volunteer

If you have concerns about a member of staff or volunteer, or an allegation is made about a member of staff or volunteer posing a risk of harm to children, speak to the Principal (DSL).

7.5 Allegations of abuse made against other pupils

We recognise that children are capable of abusing their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”. 

We also recognise the gendered nature of peer-on-peer abuse (i.e. that it is more likely that girls will be victims and boys perpetrators). However, all peer-on-peer abuse is unacceptable and will be taken seriously.

Most cases of pupils hurting other pupils will be dealt with under our school’s behaviour policy, but this child protection and safeguarding policy will apply to any allegations that raise safeguarding concerns. This might include where the alleged behaviour:

• Is serious, and potentially a criminal offence
• Could put pupils in the school at risk
• Is violent
• Involves pupils being forced to use drugs or alcohol
• Involves sexual exploitation, sexual abuse or sexual harassment, such as indecent exposure, sexual assault, or sexually inappropriate pictures or videos (including sexting)

If a pupil makes an allegation of abuse against another pupil:

• You must record the allegation and tell the DSL, but do not investigate it
• The DSL will contact the local authority children’s social care team and follow its advice, as well as the police if the allegation involves a potential criminal offence
• The DSL will put a risk assessment and support plan into place for all children involved (including the victim(s), the child(ren) against whom the allegation has been made and any others affected) with a named person they can talk to if needed

We will minimise the risk of peer-on-peer abuse by:

• Challenging any form of derogatory or sexualised language or behaviour, including requesting or sending sexual images
• Being vigilant to issues that particularly affect different genders – for example, sexualised or aggressive touching or grabbing towards female pupils, and initiation or hazing type violence with respect to boys
• Ensuring our curriculum helps to educate pupils about appropriate behaviour and consent
• Ensuring staff are trained to understand that a pupil harming a peer could be a sign that the child is being abused themselves, and that this would fall under the scope of this policy

7.6 Sexting

Your responsibilities when responding to an incident

If you are made aware of an incident involving sexting (also known as ‘youth produced sexual imagery’), you must report it to the DSL immediately. 

You must not:

• View, download or share the imagery yourself, or ask a pupil to share or download it. If you have already viewed the imagery by accident, you must report this to the DSL
• Delete the imagery or ask the pupil to delete it
• Ask the pupil(s) who are involved in the incident to disclose information regarding the imagery (this is the DSL’s responsibility)
• Share information about the incident with other members of staff, the pupil(s) it involves or their, or other, parents and/or carers
• Say or do anything to blame or shame any young people involved

You should explain that you need to report the incident, and reassure the pupil(s) that they will receive support and help from the DSL.

Initial review meeting

Following a report of an incident, the DSL will hold an initial review meeting with appropriate school staff. This meeting will consider the initial evidence and aim to determine:

• Whether there is an immediate risk to pupil(s)
• If a referral needs to be made to the police and/or children’s social care
• If it is necessary to view the imagery in order to safeguard the young person (in most cases, imagery should not be viewed)
• What further information is required to decide on the best response
• Whether the imagery has been shared widely and via what services and/or platforms (this may be unknown)
• Whether immediate action should be taken to delete or remove images from devices or online services
• Any relevant facts about the pupils involved which would influence risk assessment
• If there is a need to contact another school, college, setting or individual
• Whether to contact parents or carers of the pupils involved (in most cases parents should be involved)

The DSL will make an immediate referral to police and/or children’s social care if:

• The incident involves an adult
• There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs)
• What the DSL knows about the imagery suggests the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent
• The imagery involves sexual acts and any pupil in the imagery is under 16

• The DSL has reason to believe a pupil is at immediate risk of harm owing to the sharing of the imagery (for example, the young person is presenting as suicidal or self-harming)

If none of the above apply then the DSL, and other members of staff, as appropriate, may decide to respond to the incident without involving the police or children’s social care.

Further review by the DSL

If at the initial review stage a decision has been made not to refer to police and/or children’s social care, the DSL will conduct a further review.

They will hold interviews with the pupils involved (if appropriate) to establish the facts and assess the risks. 

If at any point in the process there is a concern that a pupil has been harmed or is at risk of harm, a referral will be made to children’s social care and/or the police immediately. 

Informing parents

The DSL will inform parents at an early stage and keep them involved in the process, unless there is a good reason to believe that involving them would put the pupil at risk of harm.

Recording incidents

All sexting incidents and the decisions made in responding to them will be recorded in iSAMS. 

Curriculum coverage

Pupils are taught about the issues surrounding sexting as part of our PSHE education and computing programmes. Teaching covers the following in relation to sexting:

• What it is
• How it is most likely to be encountered
• The consequences of requesting, forwarding or providing such images, including when it is and is not abusive
• Issues of legality
• The risk of damage to people’s feelings and reputation
• Pupils also learn the strategies and skills needed to manage
• Specific requests or pressure to provide (or forward) such images
• The receipt of such images

This policy on sexting is also shared with pupils so they are aware of the processes the school will follow in the event of an incident.

8. Notifying parents

Where appropriate, we will discuss any concerns about a child with the child’s parents. The DSL will normally do this in the event of a suspicion or disclosure. 

Other staff will only talk to parents about any such concerns following consultation with the DSL. 

If we believe that notifying the parents would increase the risk to the child, we will discuss this with the local authority children’s social care team before doing so.

In the case of allegations of abuse made against other children, we will normally notify the parents of all the children involved.

10. Mobile phones and cameras

Staff are allowed to bring their personal phones to school for their own use but will limit such use to non-contact time when pupils are not present. Staff members’ personal phones will remain in their bags or cupboards during contact time with pupils.

Staff will not take pictures or recordings of pupils on their personal phones or cameras. 

We will follow the General Data Protection Regulation and Data Protection Act 2018 when taking and storing photos and recordings for use in the school.

11. Complaints and concerns about school safeguarding policies

Complaints against staff

EIC is conscious of its duty of care to pupils and will always act, including if alerted to the possibility of abuse arising from situations or persons outside the school setting. The notification and prompt handling of all concerns about adults is fundamental to safeguarding children. 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. Those raising concerns or reporting allegations in good faith will always be supported, and adults in respect of whom concerns or allegations have been raised will not suffer any detriment unless the concern or allegation is found to be substantiated.

12. Record-keeping

All safeguarding concerns, discussions, decisions made and the reasons for those decisions, must be recorded in writing. If you are in any doubt about whether to record something, discuss it with the DSL. 

Non-confidential records will be easily accessible and available. Confidential information and records will be held securely and only available to those who have a right or professional need to see them. 

Safeguarding records relating to individual children will be retained for a reasonable period of time after they have left the school. 

If a child for whom the school has, or has had, safeguarding concerns moves to another school, the DSL will ensure that their child protection file is forwarded promptly and securely, and separately from the main pupil file. In addition, if the concerns are significant or complex, and/or social services are involved, the DSL will speak to the DSL of the receiving school and provide information to enable them to have time to make any necessary preparations to ensure the safety of the child. 

13. Training

13.1 All staff

All staff members will undertake safeguarding and child protection training at induction (National Online Safety) safeguarding systems and their responsibilities and can identify signs of possible abuse or neglect. This training will be regularly updated. 

The School takes a proactive approach to teaching children about safety and safeguarding. In addition to PSHE, this is undertaken across the curriculum. As well as explicit teaching opportunities, staff use incidental opportunities to promote safe messages and teach about how to manage risk.

Staff will also receive regular safeguarding and child protection updates (for example, through emails, e-bulletins and staff meetings) as required, but at least annually.

13.2 The DSL and [deputy/deputies]

The DSL and deputies will undertake child protection and safeguarding training at least every 2 years.  

13.4 Recruitment – interview panels

At least one person conducting any interview for a post at the school will have undertaken safer recruitment training. This will cover, as a minimum, the contents of the Department for Education’s statutory guidance, Keeping Children Safe in Education, and will be in line with local safeguarding procedures. 

14. Monitoring arrangements

This policy will be reviewed annually by the Principal. At every review, it will be approved by the full governing board.

15. Links with other policies

This policy links to the following policies and procedures:

• Behaviour
• Staff Code of Conduct
• Attendance
• Online safety

These appendices are based on the Department for Education’s statutory guidance, Keeping Children Safe in Education.

Appendix 1: types of abuse

Abuse, including neglect, and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap. 

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

Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Emotional abuse may involve:

• Conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person
• Not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate
• Age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as over protection and limitation of exploration and learning, or preventing the child participating in normal social interaction
• Seeing or hearing the ill-treatment of another
• Serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children

Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve:

• Physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing
• 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.

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. 

• Once a child is born, neglect may involve a parent or carer failing to: 
•  provide adequate food, clothing and shelter (including exclusion from home or abandonment); 
•  protect a child from physical and emotional harm or danger; 
• ensure adequate supervision (including the use of inadequate care-givers); or 
• ensure access to appropriate medical care or treatment. 
• It may also include neglect or, or unresponsiveness to, a child's basic emotional needs. 

Signs of possible neglect include: 

•  the child seems underweight or is very small for their age; 
•  they are poorly clothed, with inadequate protection from the weather; 
•  they are often absent from school for no apparent reason; or 
• they are regularly left alone, or in charge of younger brothers or sisters.

Grooming 

Grooming is the process by which an individual prepares a child, significant adults and the environment for abuse of this child. Children and young people can be groomed online or in the real world, by a stranger or by someone they know. Groomers may be male or female. They could be any age.  Many children and young people do not understand that they have been groomed, or that what has happened is abuse. The signs of grooming are not always obvious. Groomers will also go to great lengths not to be identified. 

Children may: 

• be very secretive, including about what they are doing online;  
• have older boyfriends or girlfriends; 
• go to unusual places to meet friends; 
• have new things such as clothes or mobile phones that they can't or won't explain; 
• have access to drugs and alcohol; 
• go missing from home or school; 
• display behavioural changes; o have sexual health issues; or o present as suicidal, self/harming, feeling depressed, unworthy. 

In older children, signs of grooming can easily be mistaken for 'normal' teenage behaviour, but you may notice unexplained changes in behaviour or personality, or inappropriate sexual behaviour for their age. See the NSPCC website for further information about grooming link. 

learning.nspcc.org.uk/research-resources/briefings/grooming

Signs of grooming and/or online abuse 

• A child may be experiencing abuse online if they: 
• Spend lots, much more, or much less time online, texting, gaming or using social media; are withdrawn, upset or outraged after using the internet or texting; 
• Are secretive about who they’re talking to and what they’re doing online or on their mobile phone; and/or o have lots of new phone numbers, texts or e-mail addresses on their mobile phone, laptop or tablet. 

Signs of grooming manifested by sex offenders

It is important to remember that not all sex offenders will exhibit these signs and if an individual exhibits some or all of these signs it does not mean that they are a sex offender. 

• Overly affectionate behaviour with a child 
•  Affording special attention or preferential treatment to a child o
• Excessive time spent alone with a child outside of the classroom/school 
•  Frequently spending time with a child in private or isolated areas 
•  Transporting a child to or from the school 
•  Making friends with a child's parents and visiting their home 
•  Acting as a particular child's confidante 
•  Giving small gifts, money, toys, cards, letters to a child 
•  Using texts, telephone calls, e-mails or social networking sites to inappropriately communicate with a child 
• Flirtatious behaviour or making suggestive remarks or comments of a sexual nature around a child

Modus operandi of institutional grooming 

• Target vulnerable victim - 
• Perpetrators target victims who are vulnerable, isolated, insecure and/or have greater emotional needs. o Gain victim’s trust 
• Offenders may allow a child to do something (e.g. eat ice cream, stay up late, view pornography) which is not normally permitted by the child’s parents or the school in order to foster secrecy. 
• Gain the trust of others – Institutional offenders are often popular with children and parents, successfully grooming not only the victim but also other members of the victim's family and the community at large. 
• Filling a need / becoming more important to the child 
• This can involve giving gifts, rewards, additional help or advice, favouritism, special attention and/or opportunities for special trips or outings. o Isolating the child 
• The perpetrator may encourage dependency and subtly undermine the victim’s other relationships with friends or family members. 
• Sexualising the relationship -
• This can involve playful touches, tickling and hugs. It may involve adult jokes and innuendo or talking as if adults, for example about marital problems or conflicts 
• Maintaining control and secrecy - Offenders may use their professional position to make a child believe that they have no choice but to submit to the offender. 

Signs of grooming for radicalisation 

• There are no known definitive indicators that a young person is vulnerable to radicalisation, but there are a number of signs that together increase their risk of being groomed in this way. 

Signs of vulnerability include: 

•  Underachievement 
•  Being in possession of extremist literature o
• Poverty or Social exclusion 
•  Traumatic events