Safeguarding, Protection and Prevent Policy

Introduction 

Harriet Ellis Training Solutions makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe.

Harriet Ellis comes into contact with adults and young adults through their training courses, in the provision of the Level 3 and Level 4 Apprenticeship programmes. This is via distance learning but requires assessor visits.  Contact with apprentices will include email, go to meeting, skype, telephone & face to face contact.  The face-to-face contact will be with the trained Dental Educationalists, Assessors and Exam Invigilators only, who will hold relevant DBS checks.  Apprentices may have remote contact with IQA, EQA and programme lead. Apprentices will also have contact with an IEPA when they undergo End Point Assessment.

The general aim of this policy is to ensure that Harriet Ellis undertakes its responsibilities with regard to protection of its learners and staff and will respond to concerns appropriately. The policy establishes a framework to support staff in their practices and clarifies the organisation’s expectations.

In line with statutory guidance, all staff are required to read Part One of “Keeping Children safe in education”. All staff must confirm that they have been made fully aware of, and understand the contents of, the Safeguarding Policy and Procedures for Harriet Ellis Training Solutions during their induction & ongoing training which is signed & recorded on file.

Safeguarding is about embedding practices throughout the organisation to ensure the protection of our apprentices and adults at risk wherever possible. Harriet Ellis’s protection procedures are about responding to circumstances that arise where abuse may be suspected.

The specific aims of this policy, to include response to our Prevent Duty, therefore are

• to provide protection for apprentices on programmes managed by Harriet Ellis to ensure their welfare and to ensure the welfare of our staff in the context of their ensuring the safeguarding and the protection of vulnerable groups.
• to provide apprentices (and, as appropriate, their parents or carers), staff and all working on behalf of Harriet Ellis with the overarching principles that guide our approach to safeguarding and the protection of vulnerable groups.
• to identify and support apprentices with potential vulnerabilities to all forms of abuse (including that of indoctrination),

Responsibilities

The Designated Safeguarding Lead, Siobhan Thomas, is responsible for implementation of this policy as part of her role as Delivery Management Team Leader.

How we promote this policy

All staff receive details of our Safeguarding & Prevent Policy Process through their induction and will receive regular training that is documented as part of our Professional Development Process.  Our Policy and Process details are embedded in our Commitment Statement/Training Plan for all of our Apprentices and promoted throughout the delivery of our programme through reviews. This ensures that staff are wholly committed to this policy and further ensures that all our learners are protected.

Our Policies are available at all times on our website.

All of our Assessors / Dental Educationalists will be placed on Certified CPD training as part of our Process for Personal Development and the certificates will be filed on our HR system.

This policy will be reviewed annually by Siobhan Thomas, Safeguarding Lead Officer and Hadley Silver Managing Director.

This policy takes account of all relevant statutory guidance

• Keeping Children Safe in Education” and “Working Together to Safeguard Children” (both revised in 2022)
• the Equality Act (2015)
• Ofsted’s requirements as detailed in “Inspecting safeguarding in early years, education and skills settings” (August 2022) with particular regard to Annex 4.
• Counter terrorism and Security Act 2015
• Prevent duty guidance: for further education institutions in England and Wales

Definitions relevant to this policy

For the purposes of this policy and associated procedures, children and young people are any persons under the age of 18 years. An Adult at Risk is defined by the Care Act 2014 as ’An adult at risk of abuse or neglect is defined as someone who has needs for care and support, who is experiencing or at risk of, abuse or neglect and as a result of their care needs – is unable to protect themselves.

This may include but not exclusive to a person who:

• Is elderly and frail
• Has a mental illness including dementia
• Has a physical or sensory disability
• Has a learning disability
• Has a severe physical illness
• Is a substance misuser
• Is homeless

Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. Abuse can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

It can take a number of forms, including the following:

• Physical abuse
• Sexual abuse
• Emotional abuse
• Bullying
• Neglect
• Financial (or material) abuse

We include as Appendix B some of the more common indicators of abuse that a young person or adult at risk may show. This clear level of staff understanding further ensures the protection of our learners.

The Prevent Duty

Harriet Ellis is committed to helping & identifying the needs & vulnerabilities of individuals. In accordance with the Counter Terrorism and Security Act, Harriet Ellis Training Ltd has a responsibility to prevent people from being drawn into terrorism and participates fully in such work. Prevent is a strand of the Government counter terrorism strategy -CONTEST. The UK faces a range of terrorist threats. All the terrorist groups who pose a threat seek to radicalise and recruit people to their cause. The Prevent strategy seeks to:

• Respond to the ideological challenge of terrorism and aspects of extremism, and the threat faced from those that promote these views.
• Provide practical help to stop people from being drawn into terrorism and ensure they are given appropriate advice and support
• Work with a wide range of sectors where there are risks of radicalisation which needs to be addressed, including education, criminal justice, faith, charities, the internet, social media and health.

As an organisation we are committed to promoting the welfare of individuals and keeping people safe.  All staff must be vigilant at all times and are trained to be able to recognise and respond to neglect and signs of abuse.  All staff know that they must act quickly if they suspect an individual is suffering or likely to suffer from harm.  We are aware that we have a legal responsibility to fulfil the prevent duty statement.

Standards of Good Practice  

To ensure that we meet our responsibilities to individuals, all staff will:

• treat all individuals with respect
• treat young people and adults as individuals
• put the person’s welfare first
• set a good example by conducting ourselves appropriately
• involve people in decisions that affect them
• encourage positive and safe behaviour among all
• be a good listener
• be alert to changes in people’s behaviour
• recognise that challenging behaviour may be an indicator of abuse
• maintain appropriate standards of conversation and interaction with and between young people and avoid the use of sexualised or derogatory language
• be aware and sensitive of different cultures and different communities
• share concerns immediately with the company Safeguarding Leads, Siobhan Thomas/David Martin in an email format marked “confidential”
• always act in the best interests of an individual

Abuse of Trust

All staff understand that inappropriate behaviour is completely unacceptable.  In addition, staff must understand that, under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual. This means that any sexual activity between a member of staff and an apprentice under 18 may be a criminal offence, even if that young person is over the age of consent.

Whistleblowing

Staff that are concerned about the conduct of a colleague or professional towards an apprentice have a duty to protect the welfare of an individual and report the behaviour immediately.  We appreciate that staff will be placed into an unsettling & difficult position if acting under our whistleblowing policy; however, they must remember their duty to respond and inform.

All concerns of poor practice or possible abuse by colleagues should be reported to the Designated Safeguarding Lead, Siobhan Thomas immediately. All staff, including freelanced staff (paid or unpaid) have a responsibility to follow the guidance laid out in this policy and related policies, and to pass on any welfare concerns using the required procedures.

We expect all staff (paid or unpaid) to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The scope of this Safeguarding Policy is broad ranging and in practice. It will be implemented via a range of policies and procedures and staff handbook within the organisation. These policies include:

• Health & Safety Policy
• Equality & Diversity Policy
• Bullying & Harassment Policy
• Data Protection Policy

Our Staff handbook includes:

• Health & Safety
• Whistleblowing
• Capability Procedures
• Personal Harassment and how these allegations will be managed

IT Usage

We believe it is essential for online safety guidance to be given to all staff and learners on a regular and meaningful basis. Online safety is embedded withing the college’s curriculum and we continually look for new opportunities to promote online safety.

As part of the curriculum all the below areas are covered.

• Educating learners on the dangers of technologies that they will encounter.
• Learners are aware of the relevant legislation when using the internet such as data protection.
• Learners are made aware of the impact of online bullying and where they can go to seek help if needed. This includes parents, tutors or a staff member at their employment.
• Learners are advised to be cautious about the information given to other sites for example users not being who they say they are.
• Learners are explained the benefits of web filters being added to their software.
• Every staff member from Harriet Ellis will have their own email account to use. This is to minimise the risk of receiving unsolicited or malicious emails.

Role of Staff and Volunteers

All staff and volunteers working on behalf of the organisation have a duty to promote the welfare and safety of adults at risk. Staff and volunteers may receive disclosures of abuse and observe adults who are at risk. This policy will enable staff/volunteers to make informed and confident responses to specific adult protection issues.

It is important that adults at risk are protected from abuse. All complaints, allegations or suspicions must be taken seriously.  The following procedure must be followed whenever an allegation of abuse is made or when there is a suspicion that an adult at risk has been abused.

Procedure where abuse is suspected

Promises of confidentiality must not be given as this may conflict with the need to ensure the safety and welfare of the individual.

A full record shall be made as soon as possible of the nature of the allegation and any other relevant information.  This must include information in relation to the date, the time, the place where the alleged abuse happened, your name and the names of others present, the name of the complainant and, where different, the name of the adult who it is alleged has been abused, the nature of the alleged abuse, a description of any injuries observed, the account which has been given of the allegation.

Any suspicion, allegation or incident of abuse must be reported to the Designated Safeguarding Lead or Senior Manager on that working day where possible.

The Safeguarding Lead shall telephone and report the matter to the appropriate safeguarding partners which include, but are not limited to The General Dental Council the Police and Social Services. A written record of the date and time of the report shall be made and the report must include the name and position of the person to whom the matter is reported. The telephone report must be confirmed in writing to the relevant local authority adult social services department within 24 hours.

The Role of the Designated Officer

The role of the designated officer is to deal with all instances involving adult and young adult protection that arise within the organisation. They will respond to all adult and young adult at risk protection concerns and enquiries.

The designated Safeguarding Lead for the organisation is Siobhan Thomas. Should you have any suspicions or concerns relating to Adult or Young Adult Protection, contact safeguarding@harrietellis.com.

Training will be provided, as appropriate, to ensure that staff are aware of these procedures. Specialist training is a requirement for the Safeguarding Lead and Senior Management and provided by Harriet Ellis.

Safe Recruitment

Harriet Ellis ensures safe recruitment through the following processes:

Job or role descriptions for all roles involving contact with children and / or vulnerable adults will contain reference to safeguarding responsibilities.

There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding are included within all contracts offered.

Interviews are conducted according to equality & diversity principles and interview questions are based on the relevant job description and person specification and related to Safeguarding.

Disclosure and barring service (DBS) Management

The organisation commits resources to providing a Disclosure and Barring Service check on all staff whose roles involve regulated activity with children and /or adults at risk. DBS checks will be conducted for specific roles for all staff working with children and vulnerable adults. Portable/ carry over DBS checks from another employer will not be deemed to be sufficient unless the update service is current and can be verified. It is a criminal offence for individuals barred by the DBS to work or apply to work with children or vulnerable adults in a wide range of posts.

Harriet Ellis Training Solutions will ensure that their established staff and roles are regularly reviewed through the following:

A 3-year rolling programme of re-checking DBSs is in place for holders of all identified posts. Existing staff who transfer from a role which does not require a DBS check to one which involves contact with children / vulnerable adults will be subject to a DBS check.

No formal job offers are made until after checks for suitability are completed (including DBS where appropriate)

Harriet Ellis Training Solutions commits resources for induction, training of staff, effective communications and support mechanisms in relation to Safeguarding and Prevent Duty.

Training

Staff receive comprehensive induction which includes familiarisation with this policy, the requirements of “Keeping Children Safe in education” and the Prevent Duty.

Training

All staff who, through their role, are in contact with children and /or adults at risk will have access to safeguarding and Prevent Duty training at an appropriate level. The Designated Safeguarding Lead routinely communicates updates to staff by means of emails and verbal briefings. (See ‘Communications’ below)

Support

We recognise that involvement in situations where there is risk or actual harm can be stressful for staff concerned. The mechanisms in place to support staff include:

Debriefing support for paid and unpaid staff so that they can reflect on the issues they have dealt with. This can be provided by the Lead IQA.

Seeking further support as appropriate e.g. access to counselling.

Staff who have initiated protection concerns will be contacted by line manager or Designated Safeguarding Lead within a timescale of one week.

Communications 

Harriet Ellis uses the following mechanisms for enabling effective discussion of safeguarding issues between staff:

• Team/Tutor meetings
• Operation meetings
• Board meetings
• One to one meetings (formal or informal),
• Clinical supervision

Monitoring

The safeguarding aspects that Harriet Ellis Monitor include:

Safe recruitment practices

• DBS checks undertaken
• References applied for new staff
• Records made and kept of supervision sessions
• Training – register and record of all staff training
• Monitoring whether concerns are being reported and acted upon
• Checking that policies are up to date and relevant
• Reviewing the current reporting procedure in place
• Presence and action of Designated Senior Manager responsible for Safeguarding is in post

Safeguarding Apprentices who are vulnerable to Extremism

Since 2010, when the Government published the Prevent Strategy, there has been an awareness of the specific need to safeguard all learners from violent extremism.  There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

We ensure apprentices and employees are resilient to extreme narratives – identify changes in behaviour of apprentices and employees. We do this by providing a curriculum which promotes, knowledge, skills and understanding including:

• Embedding equality, diversity and inclusion including British Values
• Promoting wider skills development such as social and emotional aspects of learning
• Encouraging active citizenship and facilitating apprentices to accept responsibility for their behaviour, show initiative and understand how they can contribute positively to society

Harriet Ellis values freedom of speech and the expression of beliefs / ideology as fundamental rights underpinning our society’s values.  Apprentices and staff have the right to speak freely and voice their opinions.  However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued.  Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism.  The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. Harriet Ellis is clear that this exploitation and radicalisation should be viewed as a safeguarding concern.

Harriet Ellis seeks to protect its apprentices against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right / Neo Nazi / White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

Definitions of radicalisation and extremism, and indicators of vulnerability to radicalisation are in Appendix A.

Procedure concerns are raised

Harriet Ellis, like all other organisations, is required to identify a Prevent Single Point of Contact (SPOC) who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism: this will normally be the Designated Safeguarding Lead.  The SPOC for Harriet Ellis is Siobhan Thomas.

When any member of staff has concerns that a person may be at risk of radicalisation or involvement in terrorism, they should speak with the Designated Safeguarding Lead. A safeguarding log is held securely on the server, password protected and only the safeguarding lead has access to.

Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action.  For this reason, the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

Safeguarding Apprentices who are vulnerable to Exploitation, Forced Marriage, Female Genital Mutilation or Trafficking

Our safeguarding policy through the organisation’s values, ethos and expectations policies provides the basic platform to ensure children, adults and young adults are given the support to respect themselves and others, stand up for themselves and protect each other.

Our organisation keeps itself up to date on the latest advice and guidance provided to assist in addressing specific vulnerabilities and forms of exploitation. Appendix A outlines the most common

Our staff are supported to recognise warning signs and symptoms in relation to vulnerabilities relating to radicalisation and extremism.

Our Designated Safeguarding Lead knows where to seek and get advice as necessary. She has made productive contacts with the local safeguarding partners, other support agencies, for example, for drug misuse, unplanned pregnancy and homelessness and is familiar with the work of the Child Exploitation and Online Protection service.

Appendix A

INDICATORS OF VULNERABILITY TO RADICALISATION

1. Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.
2. Extremism is defined by the Government in the Prevent Strategy as:

Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.  We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.

3. Extremism is defined by the Crown Prosecution Service as:

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

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

4. There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.
5. Apprentices may become susceptible to radicalisation through a range of social, personal and environmental factors – it is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and communities. It is vital that school staff are able to recognise those vulnerabilities.
6. Indicators of vulnerability include:

• Identity Crisis – the student / pupil is distanced from their cultural / religious heritage and experiences discomfort about their place in society;
• Personal Crisis – the student / pupil may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging;
• Personal Circumstances – migration; local community tensions; and events affecting the student / pupil’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;
• Unmet Aspirations – the student / pupil may have perceptions of injustice; a feeling of failure; rejection of civic life;
• Experiences of Criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement / reintegration;
• Special Educational Need – students / pupils may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.

7. However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the purposes of violent extremism.
8. More critical risk factors could include:

• Being in contact with extremist recruiters;
• Accessing violent extremist websites, especially those with a social networking element;
• Possessing or accessing violent extremist literature;
• Using extremist narratives and a global ideology to explain personal disadvantage;
• Justifying the use of violence to solve societal issues;
• Joining or seeking to join extremist organisations; and
• Significant changes to appearance and / or behaviour;
• Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

Appendix B

Signs of Abuse – physical, psychological and behavioural

Signs of physical abuse might commonly include:

• Bruises which are in places on the body where accidental bruising is unusual – particularly if symmetrical or in the shape of an object
• Bites, burns and fractures without an explanation
• Injuries inconsistent with the explanation given or where the account is inconsistent
• Injuries which have not received medical attention, particularly repeated or frequent
• Injury symptoms e.g. difficulty walking, lifting everyday objects, putting on clothing
• Reluctance to seek medical help, avoidance of questioning or examination by a qualified person.

Non-physical signs

Abuse has psychological and behavioural impacts which might include:

• Marked change in behaviour or emotional state not explained by a stressful event, such as a bereavement
• Unexplained depression, denial, aggression or withdrawal, reports of nightmares
• Reluctance to expose the body in any way – e.g. remove outer clothes in summer
• Poor personal hygiene, unwashed or damaged clothing, lack of care of own appearance
• Eating disorders, avoidance of food
• Body rocking, self-harm

Abuse also has impacts upon relationships, communication and interactions with others which might commonly include:

• Abnormal behaviour towards others – fear, withdrawal, lack of eye contact, extreme or subdued emotional reactions
• Under-developed social relationships and lack of interaction with peer group
• Low self-esteem, need to apologise for self, over-reaction to making mistakes
• Repeated absence – avoiding events or appointments where personal welfare may be discussed.

Version 4 – September 2022