Safeguarding Policy

Safeguarding Learners Policy

SAFEGUARDING LEARNERS POLICY

1. Introduction

Colchester Institute is fully committed to the well-being of its learners and apprentices. The College works to actively support and promote the positive welfare of all learners and apprentices including children, adults at risk and those with SEND and expects the workforce, including college staff, agency staff, Governors, contractors, contracted staff, sub- contracted staff, volunteers to share, promote and practise this commitment at all times. Safeguarding and promoting the welfare of our learners and apprentices is everyone’s responsibility.

This Policy represents Colchester Institute’s response to the need to protect all enrolled learners and apprentices especially children and adults at risk and those with SEND at all College Campuses and organisations that carry out work on behalf of Colchester Institute.

The intent of the Safeguarding Policy is to ensure that:

• a safe environment is provided for learners and apprentices at all times;
• learners and apprentices (child or adult) who are at risk of and/or likely to suffer significant harm are identified, and appropriate action taken with the aim of making sure they are kept safe, both at college and at home or elsewhere;
• there exist safe recruitment practices in checking the suitability of college staff, agency staff, Governors, contractors, contracted staff, sub- contracted staff, volunteer staff are made aware of issues relating to the safeguarding and welfare of learners and apprentices;
• this policy applies to all leaners and apprentices regardless of gender, ethnicity, disability, sexuality, or religion.

Working within this policy and linked policies demonstrates Colchester Institute’s compliance to the duty placed on colleges in keeping children, young people, and adults at risk safe and promoting their welfare in these ways:

• Protecting from maltreatment
• Preventing impairment of children’s mental health and physical health or development
• Growing up in a safe and cared for environment
• Taking action to enable the best outcomes

This policy should be read in conjunction with the Colchester Institute Staff Code of Conduct and Safeguarding Protocol for Staff.
In addition to Colchester Institute’s Safeguarding Policy staff must have an awareness of Keeping Children Safe in Education and the Southend, Essex, and Thurrock (SET) Procedures for Safeguarding Children and Adults and use for reference where necessary.

2. Aims and Principles

The College is committed to the rights of learners and apprentices within all its learning locations; it is committed to promoting their welfare, protecting their physical and emotional wellbeing and safeguarding them from all forms of abuse. Colchester Institute expects all college staff, agency staff, Governors, contractors, contracted staff, sub- contracted staff, volunteers to share this commitment.

The College will act in ways that best safeguard the interests of learners and apprentices.

The College is committed to the following safeguarding principles and practices;

• the needs and interests of learners and apprentices are paramount;
• all people working under the auspices of the College carry a responsibility for safeguarding and promoting the welfare of learners and apprentices;
• all College staff should be prepared to identify children and adults at risk (learners and apprentices) who may benefit from early help.

3. Purpose

The purpose of this Policy is to ensure that Colchester Institute has effective systems in place for safeguarding learners and apprentices.

The College fully supports the objectives outlined in the guidance Keeping Children Safe in Education (2024) and Working Together to Safeguard Children (2023), SET Procedures for Children and Young People and SET guidelines for Safeguarding Adults in order to help keep learners safe by contributing to:

• providing a safe environment for learners and apprentices to learn in education settings;
• identifying learners and apprentices who are suffering or who are likely to suffer significant harm and taking appropriate action with the aim of making sure they are kept safe both at home and in College;
• implementing safer recruitment policies and the development of safe and secure environments for learning with appropriate supervision and support for staff;
• creating supportive environments which enable learners and apprentices to be able to speak out;
• managing concerns sensitively and promptly referring to statutory agencies including Children’s Social Care, Adult Social Care and/or Police;
• actively participate when required in Child in Need meetings, Child Protection panels, Channel panels and/or, Counter Terrorism local profile meetings;
• maintain a relationship with the Essex Safeguarding Children Board by attending Local Stay Safe meetings and, when requested, the Local Children’s Partnership Board and subgroups;
• maintaining confidentiality and only sharing information relating to individual learners, apprentices, and families on a strictly ‘need to know’ basis;
• recognising that the College does not have an investigatory role in child protection; the role is to ensure that concerns are passed on without delay to agencies that have a statutory responsibility to investigate i.e., Social Care and the Police;
• ensuring that all employees of the College have access to an appropriate level of information, instruction, and training to ensure that the College’s policies, practices, and procedures are used and understood by all members of staff;
• supporting learners and apprentices who may have been abused, in accordance with their child protection plan;
• ensuring that where the College sub-contracts to outside agencies, the service provider is required to have an up to-date Safeguarding and Child Protection policy or subscribe to the principles of the College’s Safeguarding Learners Policy and is responsible for ensuring that those working closely with, or supervising learners are DBS checked appropriately.

This policy will be subject to continual revision to reflect statutory review.

4. Statutory Framework

The Police and Social Services have primary responsibility in the field of child protection. The Children Act 2004 places a duty on local authorities to take steps to protect learners in appropriate circumstances.

The Education Act 2002 ensures that responsibilities under the Education Acts are carried out with a view to safeguarding and promoting the welfare of learners.

Working Together to Safeguard Children publishes the legislative requirements placed on individual services in relation to inter-agency working to safeguard and promote the welfare of children.

Keeping Children Safe in Education 2024 outlines statutory guidance that specifically schools and colleges must and should have regard to when carrying out their duties to safeguard and promote the welfare of children.

The Sexual Offences Act 2003 makes it an offence for a person over 18 (e.g., a lecturer or other member of staff) to have a sexual relationship with a child under 18 where that person is in a position of trust in respect of that child, even if the relationship is consensual. It can also potentially be an offence under this Act for a staff member to have a sexual relationship with an adult at risk.

To protect all of our learners and apprentices, personal intimate relationships between staff, contractors, sub-contractors, agency staff, volunteers and Governors and learners/apprentices are strictly prohibited. Please see section 20.

The Counter-Terrorism and Security Act 2015, places a duty on specified authorities, including local authorities and childcare, education, and other children’s services providers, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism (“the Prevent duty”).

The College takes account of guidance issued by the Department for Education, the Disclosure and Barring Service and other relevant bodies and groups.

The College is committed to working with and assisting the local children’s departments with regard to child protection matters and is committed to liaising with the Essex Safeguarding Children Board and/or local Stay Safe Groups.

The College are aware of obligations under the Human Rights Act 1998, the Equality Act 2010, including the Public Sector Equality Duty and local multi-agency safeguarding arrangements (SET procedures for Children and Adults)

5. Definitions

For the purposes of this policy the term “learner” or “apprentice” will be used to cover the following categories:

Child: – The definition of ‘child’ in the Children Act of 1989 and 2004 is ‘any person who has not reached their 18th birthday’

Adults at Risk – The Care Act 2014 uses the definition below to highlight who adult safeguarding responsibilities apply to. Within this policy we refer to people who fulfil this definition as adults at risk.

1. Adult has care and support needs, and
2. Is experiencing, or is at risk of, abuse or neglect and
3. Is unable to protect themselves from either the risk of, or the experience of abuse or neglect, because of those needs.

Those who meet the criteria can include:

• Adults with care and support needs regardless of whether those needs are being met by the local authority
• Adults who don’t have clearly identified needs, but who may still be vulnerable
• Adults who manage their own care and support through personal or health budgets
• Adults who fund their own care and support
• Children and young people in specific circumstances (will be supported via Adult Safeguarding agencies)
  (SET Safeguarding Adults Guidelines 2022 V8)

This Safeguarding Policy will also apply to any other adult learner or apprentice deemed to be at immediate risk of harm and therefore needing additional help or support in a crisis situation or over a longer period of time.

Intimate Personal Relationship (From the Office for Students) – a relationship that involves one or more of the following elements:
a) Physical intimacy including isolated or repeated sexual activity; or
b) Romantic or emotional intimacy

Work experience- short (minimum of 30 hours) and clearly defined as work experience which has a focus and aim of improving employability skills.

Industry Placements, including T Levels– a minimum of 315 hours with an external employer in a role relevant to the learner’s course. The placement should be clearly defined, the main aim being to build and develop technical skills and gain industry relevant knowledge, with Employers checked against DfE – Department for Education Guidance.

Work Placements – required on some study programmes as part of the curriculum programme for example: Early Years and Health and Social Care.

6. Scope and Application

The Safeguarding Learners Policy exists to safeguard all Colchester Institute enrolled learners and apprentices, whether they study at the main College campuses, satellite centres or other designated areas. The application of this policy must be applied and followed, by college staff,

Governors, contractors, contracted staff, sub- contracted staff, volunteers whether they work main College campuses, satellite centres or other designated areas. The policy is applicable to all College on and off-site activities undertaken by learners and apprentices whilst they are actively enrolled at Colchester Institute.

The policy applies to learners and apprentices on work experience, work placements and Industry placement programmes and those engaged on any College organised off-site activity.

The policy applies to working arrangements with other agencies including schools, employers, and support agencies.

The policy applies to learners and apprentices who are external candidates and on the premises for the purpose of taking an examination.

The College recognises that safeguarding apprentices, who may not be geographically based near the College or come onto college site is not without its challenges. Where it is not possible to meet the apprentice in person to discuss concerns, due to geographical constraints, safeguarding advice and procedures will be followed by telephone with the apprentice to ensure their safety.

Employers of apprentices are able to access the College’s Safeguarding Officers for advice and signposting, this support from the College supports but does not replace the employers duty of care to their employee (apprentice).

7. Roles and Responsibilities

The Governing Body

The Governing body ensures that the policies, procedures and training in our college are effective and comply with the law at all times. It ensures that all required policies relating to safeguarding are in place, that the Safeguarding Learners Policy reflects statutory and local guidance and that it is reviewed at least annually.

The Governor for safeguarding arrangements is named below. This Governor takes strategic responsibility at Governing body level for safeguarding arrangements in our college. The Governing body ensures there is a named Designated Safeguarding Lead and at least one deputy safeguarding lead in place (also named below)

The Governing body ensures the college contributes to inter-agency working, in line with statutory and local guidance. It ensures that information is shared and stored appropriately and in accordance with statutory requirements.

The Governing body ensures that all adults in our college who work with learners and apprentices undergo safeguarding training at induction as appropriate and that it is regularly updated. All staff members receive regular safeguarding updates, at least annually, to provide them with the relevant skills and knowledge to keep our learners safe.

The Governing body ensures our learners and apprentices are taught about and made aware of safeguarding through personal development opportunities.

The Governing body and College Executive team are responsible for:

• ensuring we fulfil our legal obligations in relation to safeguarding learners
• ensuring we have in place safer recruitment procedures that help to deter, reject or identify people who might abuse children, young people and or adults at risk
• ensuring we meet statutory responsibilities to check adults working with children, young people and adults at risk and have recruitment and selection procedures in place (see Safer Recruitment Policy available from the People and Culture team)
• online safety (including strategic oversight of filtering and monitoring systems to support this)

Designated Governor for Safeguarding

Marco Iciek is the Designated Governor with responsibility for safeguarding learners, apprentices, and adults at risk.
The Designated Governor is responsible for liaising with the Principal and the Designated lead over matters regarding safeguarding learners, apprentices, and adults at risk and takes strategic responsibility for Safeguarding at Governing body level including: –

• ensuring that the College has procedures and policies to meet its legal duties, and which are consistent with Keeping Children Safe in Education, the Essex Safeguarding Children Board and Essex Safeguarding Adults Board procedures;
• ensuring that the Corporation Board considers the College policy on Safeguarding Learners each year;
• ensuring that the Governing body is informed of how the College and its staff have complied with the policy, including but not limited to a report on the training that staff have undertaken.

The Designated Governor is also responsible for overseeing the liaison between Essex County Council Social Services in connection with allegations against the Principal and Governors. This will not involve undertaking any form of investigation but will ensure good communication between the parties and provide information to assist enquiries.

The Designated Safeguarding Lead (DSL)

Ali Davies, Deputy Principal, is the College’s Designated Safeguarding Lead and is the member of the College Executive team with responsibility for safeguarding learners, apprentices, and adults at risk.

The DSL receives appropriate training in Safeguarding, child protection and inter-agency working and will receive refresher training at least every 2 years.

The DSL in College has ultimate lead responsibility for Safeguarding. The DSL with responsibility for Safeguarding is responsible for:

• overseeing the referral of cases of suspected harm or abuse or allegations against staff to Essex County Council Social Services and the relevant investigating agencies;
• ensuring that advice and support is given to staff on issues relating to safeguarding and child protection, including online safety;
• ensuring that a proper record of any safeguarding referral, complaint or concern is maintained (even where that concern does not lead to a referral);
• ensuring that parents of learners and apprentices within the College are aware of the College’s Safeguarding Learners policy;
• ensuring that the College engages with the Local Authority and Essex Safeguarding Children Board and other appropriate agencies;
• ensuring that the College liaises with secondary schools which send learners and apprentices to the College to ensure that appropriate arrangements are made for the learners;
• ensuring that the College liaises with employers and training organisations that receive learners from the college on long term placements to ensure that appropriate safeguards are put in place;
• ensuring that staff receive training, appropriate to their role, in Safeguarding and are aware of the College Safeguarding Policy and Procedures;
• ensuring that staff receive updates on Safeguarding matters at the very minimum annually;
• working with the local authority and the ESCB as required and ensure that information is shared appropriately;
• working with senior leadership colleagues to ensure filtering and monitoring (online safety) remains robust and fit for purpose;
• overseeing (in consultation with the Director of People and Culture) allegations made against the work force, liaising with the Local Area Designated Officer (LADO) where required;
• ensuring robust record keeping of all Safeguarding concerns that are reported to the College.

Deputy Designated Safeguarding Leads (DDSL)

Deputy to the Designated Lead: -responsible for deputising for the Safeguarding Lead (DSL) in their absence:

• Kirsty Russell, Head of Learner Services
• Adam Ward, Assistant Principal, Braintree Campus and STEM

The College Safeguarding Team

The College have a team of dedicated Safeguarding Officers. The list of current safeguarding officers is given in Appendix 7.

The Safeguarding Officers:

• report to the Designated Safeguarding Lead or their Deputy;
• are available to support learners and apprentices who have concerns about their safety and or make disclosures;
• work with and support learners and apprentices where concerns are raised by the learner or apprentice, staff, parents/carers, other agencies;
• know how to make and make appropriate referrals to Social Care, the Police, Prevent Team, CAMHS and other agencies;
• are available to provide advice and support to staff on issues relating to safeguarding;
• deal with individual cases, including case conferences, review meetings, as appropriate;
• keep and safely store accurate records of safeguarding concerns, even when these do not lead to a referral;
• have received training in safeguarding issues and inter-agency working, as required by the Essex Safeguarding Children Board, and refresher training at least every 3 years

All College Staff

• Everyone in our college has a responsibility to provide a safe learning environment where learners and apprentices can learn. All staff are aware of the types of abuse and safeguarding issues that can put learners and apprentices at risk of harm, so we are able to identify learners and apprentices who may be in need of help or protection. We understand that behaviours linked to issues such as drug taking and/or alcohol misuse, missing education and consensual/non-consensual sharing of nudes and semi-nudes images can be signs that children are at risk.
• All staff members are aware of and follow the College safeguarding processes (as set out in this policy). Staff understand that, if they have any concerns about a learner’s or apprentice’s welfare, they must act on them immediately and speak with the College Safeguarding Team – we do not assume that others have taken action.
• Our staff understand that learners and apprentices may not always feel able or know how to tell someone that they are being abused. This may be because they are embarrassed, scared or do not recognise they are experiencing abuse, either at home or out in the community.
• We understand there are many factors which may impact on our learner’s/apprentice’s welfare and safety and we also understand safeguarding in the wider context (contextual safeguarding). We recognise that abuse, neglect and safeguarding issues rarely occur in isolation and that, in most cases, multiple issues will overlap.
• Our staff will always reassure learners and apprentices who report abuse that they are taken seriously and that they will be supported and kept safe. We will never make a learner feel ashamed for reporting abuse, nor make them feel they are causing a problem.

8. Learners and apprentices potentially at greater risk from harm

Children and adults with SEND can face additional safeguarding challenges. It is important that these additional challenges are remembered when recognising abuse and neglect in this group. Keeping Children Safe in Education publishes the additional barriers as:

• assumptions that indicators of possible abuse such as behaviour, mood, injury relate to the child’s disability without further exploration;
• being more prone to peer group isolation than other groups;
• the potential for children with SEND being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs; and
• communication barriers and difficulties in overcoming these barriers;
• cognitive understanding – being unable to understand the difference between fact and fiction in online content and then repeating the content/behaviours in schools or colleges or the consequences of doing so.

• Looked after children and previously looked after children (Children in care): Looked after children mainly become looked as a result of abuse and/or neglect. The College should ensure staff have the skills, knowledge and understanding to keep looked after children safe. At Colchester Institute, we have a Welfare and Safeguarding Officer that supports our Looked After Children, attending reviews, undertaking PEPs, being the point of contact for the learner/apprentice, carers, social worker and liaises with the course area to ensure support is available.
• Care Leavers: Learners/apprentices who have left care may also be more vulnerable. The Local Authority have on- going responsibilities to young people who cease to be looked after and become care leavers. The College’s Welfare and Safeguarding Officer who supports looked after children will work with the local authority personal adviser to support the learner/apprentice to ensure support to participate in education or training.
• Learners and apprentices requiring mental health support: Learners/apprentices who require mental health support whilst at Colchester Institute will be supported, once disclosed, by the College’s Welfare and Safeguarding Team. The team will work together with the learner/apprentice and parents/carers (unless this places the learner at risk) to access support from key agencies including the Child and Adolescent Mental Health Service (CAMHS) or via their GP for Adult Mental Health Services. In College support will be provided by the Welfare and Safeguarding team in collaboration with the learner’s course team.
• LGBTQ+: Staff are aware that learners/apprentices who are lesbian gay, bi, trans (LGBT+) can be targeted by other young people and that learners/apprentices who are perceived by other learners/apprentices to be LGBT+ (whether they are or not) can be just as vulnerable as learners/apprentices who identify as LGBT+.

9. Early help

Keeping Children Safe in Education 2024 states:

Any child may benefit from early help, but all school and college staff should be particularly alert to the potential need for help for a child who:

• is disabled or has certain health conditions and has specific additional needs
• has special educational needs (whether or not they have a statutory Education, Health and Care plan)
• has a mental health need
• is a young carer
• is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement and association with organised crime groups or county lines
• is frequently missing/goes missing from education, home or care
• has experienced multiple suspensions, is at risk of being permanently excluded from schools, colleges and in Alternative Provision or a Pupil Referral Unit
• is at risk of modern slavery, trafficking, sexual and/or criminal exploitation
• is at risk of being radicalised or exploited
• has a parent or carer in custody, or is affected by parental offending
• is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse
• is misusing alcohol and other drugs themselves
• is at risk of so-called ‘honour’-based abuse such as Female Genital Mutilation or Forced Marriage
• is a privately fostered child.

10. Interagency Working

It is important that agencies work together to keep children and adults at risk safe, and there is a legal requirement to do so.

The College works with other agencies to safeguard learners and attends statutory meetings that they are invited to in respect of a learner that is enrolled at the College. This could include Children in Care of the Local Authority, Child in Need Core Groups or Child Protection conference, Multi Agency Child Exploitation meetings (MACE), Channel Panel and or Multi Agency Police Protection arrangement (MAPPA).

11. Abuse and neglect– what to look out for

Keeping Children Safe in Education (DfE, 2024) describes abuse in the following way:

“Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse, including where they see, hear or experience its effects. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can 12 take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children.”

Keeping Children Safe in Education refers to four categories of abuse:

• Physical
• Emotional
• Sexual
• Neglect

Possible indicators of abuse or neglect:

• Neglect: The persistent failure to meet a learner or apprentice’s basic physical and psychological needs, likely to result in the serious impairment of their health or development.
• Emotional Abuse: The persistent emotional ill-treatment of a learner or apprentice such as to cause severe and persistent adverse effects on their emotional development.
• Physical Abuse: Actual or likely physical injury to a learner or apprentice, or failure to prevent physical injury or suffering to a learner or apprentice including deliberate poisoning, suffocation or inducing or fabricating illness (formally known as “Munchausen’s syndrome by proxy”).
• Sexual Abuse: Involves forcing or enticing a learner or apprentice to take part in sexual activities, whether or not the learner or apprentice is aware of what is happening. Includes Child Sexual Exploitation.
• Financial Abuse – financial abuse takes many forms, from denying someone access to funds, to making someone solely responsible for money while the other person is handling money irresponsibly. Money becomes a tool by which the abuser can further control the victim.

Contextual Safeguarding and risk in the Community

Safeguarding incidents and behaviours can be associated with factors outside of college. This is referred to as contextual safeguarding. Staff are alert to look out for wider factors that may be in a child’s or adult at risk’s life that could be a threat to their safety and / or welfare. To this end, we will consider relevant factors when gathering information of any risk to a child or adult at risk and share it with other agencies to support better understanding of the child or adult at risk.

12. Further Safeguarding Issues

a) Radicalisation and Prevent
Radicalisation is the process by which a person comes to support terrorism and forms of extremism leading to terrorism. Keeping Children Safe in Education (September 2024) states:

All schools and colleges are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015 (the CTSA 2015), in the exercise of their functions, to have “due regard” to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty.

The Prevent duty is a part of the College’s wider Safeguarding obligations.

The Counter-Terrorism and Security Act 2015 also places a duty on local authorities to ensure Channel Panels are in place. The panel must include the local authority and chief officer of the local Police. Panels will assess the extent to which identified individuals are vulnerable to being drawn into terrorism, following a referral from the Police, and where considered appropriate and necessary consent is obtained, arrange for support to be provided to those individuals.

The Act will require partners which includes FE Colleges to co-operate with the Channel Panel in the carrying out of its functions and with the Police in undertaking the initial assessment as to whether a referral is appropriate.

Colchester Institute will engage with the Channel Panel, Police Prevent Teams and Counter Terrorism Local Profile Meetings as required.

The College treats all concerns relating to radicalisation and extremism as a safeguarding concern. Children and adults at risk are particularly targeted by groups who may promote extremist activity.

College staff should be aware of the signs of radicalisation and have confidence to report concerns to a Safeguarding Officer.

The College will also promote the ethos of the “Prevent” agenda by encouraging free and open debate but challenging extreme views. It will encourage through its classroom practice, personal development lessons and induction activities, a belief in equality of opportunity and celebration of diversity.

The College will not host or allow its premises to be used by extreme groups and will seek to prevent the distribution of extreme literature.

The College has a legal responsibility to forbid the promotion of partisan political views in the teaching of any subject in the College and must take steps as are reasonably practicable to ensure that where political issues are brought to the attention of learners and apprentices, they are offered a balanced presentation of opposing views. Promotion of any organisations linked to violent extremism is contrary to the values of the College and could constitute misconduct.

The College will provide appropriate support by referral to external agencies or through its own staff for any learner or apprentice vulnerable to radicalisation.

b) So-called ‘honour-based violence’ (including Female Genital Mutilation and forced marriage)
So-called ‘honour’-based abuse (HBA) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM), forced marriage, and practices such as breast ironing. We understand that this form of abuse often involves a wider network of family or community pressure and can include multiple perpetrators.

Female Genital Mutilation (FGM) comprises all procedures involving partial or total removal of the external female genitalia or other injury to female genital organs. It is illegal in the UK and a form of child abuse.

The Serious Crime Act 2015 (Home Office, 2015) introduced a duty on teachers (and other professionals) to notify the police of known cases of FGM where it appears to have been carried out on a girl under the age of 18. Our College operates in accordance with the statutory requirements relating to this issue, and in line with local safeguarding procedures.

A forced marriage is one entered into without the full consent of one or both parties. It is where violence, threats or other forms of coercion is used and is a crime.

From February 2023, it has also been a crime to carry out any conduct whose purpose is to cause a child to marry before their 18th birthday, even if violence, threats or another form of coercion are not used. As with the existing forced marriage law, this applies to non-binding, unofficial “marriages” as well as legal marriages.

Our staff understand how to report concerns to the Safeguarding team.

c) Child or adult at risk Exploitation

• Sexual exploitation
• Criminal exploitation including County Lines
• Modern Slavery
• Online exploitation

All are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child or adult at risk into taking part in sexual or criminal activity, sometimes 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. Exploitation can affect children and adults at risk both male and female and can include children and adults at risk who have been moved (commonly referred to as trafficking) for the purpose of exploitation.

Some specific forms of exploitation can include children and adults at risk 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. Children and adults at risk who are exploited usually do not recognise the coercive nature of the relationship or see themselves as a victim. Exploitation is never the child’s or adult at risk’s fault.

Education has an important part to play in raising the awareness of this issue with learners and apprentices. The College responds to reports or concerns of exploitation of children and adults at risk including direct involvement of a child or adult at risk or being at risk of involvement, as a safeguarding concern

d) Allegations of peer-on-peer abuse and peer on peer sexual abuse
Keeping Children Safe in Education 2024 uses the term child on child sexual abuse, due to the varying age of learners at our college we use the term peer on peer.

The College recognises that some learners and apprentices may abuse their peers and that this may happen in College, or outside of it. Any incidents of peer-on-peer abuse are a safeguarding concern. We will seek advice, support and work with other agencies including the Police and Social Care, as appropriate.

The College recognises that, even though peer on peer abuse, including harmful sexual abuse, may not be reported, it is likely that it is occurring, and the College must have a clear zero tolerance to inappropriate or abusive behaviour. The College also understands the barriers which may prevent a learner or apprentice from reporting abuse and work actively to remove these.

Peer on peer abuse can manifest itself in many ways. This may include bullying, harassment (including online bullying), physical abuse, sexual violence / sexual harassment, ‘up-skirting’, ‘sexting’ or initiation / hazing type violence and rituals. We do not tolerate any harmful behaviour in college and will take swift action to intervene where this occurs, challenging inappropriate behaviours when they occur – we do not normalise abuse, nor allow a culture where it is tolerated.

The College has a separate bullying and harassment, sexual harassment policy and also a harmful sexual behaviour (peer on peer sexual abuse) policy. These policies and procedures follow the guidance set out in Part 5 of Keeping Children Safe in Education 2024.

As stated in the guidance cited above the College adheres to the advice of agencies including the Police and Social Care where allegations of a criminal nature are received.

The College’s challenge of this behaviour may also include the use of the Learner Professional Standards and Conduct Policy (Disciplinary Policy).

e) Upskirting
‘Upskirting’ typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress, or alarm. It is now a criminal offence.

f) Mental Health
Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Staff, however, are well placed to observe learners and apprentices regularly and identify learners or apprentices who may benefit from support from the College’s internal support teams or external support.

Our staff are aware that mental health problems can, in some cases, be an indicator that a learner or apprentice has suffered or is at risk of suffering abuse, neglect or exploitation. We understand that, where learners and apprentices have suffered abuse or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. Where we have concerns, this may impact on mental health, we will seek advice and work with other agencies as appropriate to support a learner/apprentice and ensure they receive the help they need.

Positive mental health is the concern of the whole community, and we recognise that colleges play a key part in this. We understand that there are risk factors which increase someone’s vulnerability and protective factors that can promote or strengthen resilience. The more risk factors present in an individual’s life, the more protective factors or supportive interventions are required to counter- balance and promote further growth of resilience.

g) Online Safety
With young people spending a considerable amount of leisure time online and Colleges utilising the online space to support learning, it is essential that we work together with learnerss and apprentices, parents/carers, and external agencies to safeguard young people from potentially harmful and inappropriate online material.

The College recognise that learners and apprentices live in an increasingly complex world, living their lives on and offline. This presents many positive and exciting opportunities, but we recognise it also presents challenges and risks. Any learner or apprentice can be vulnerable online, and their vulnerability can fluctuate depending on their age, developmental stage, and personal circumstance.

The range of online risks could be categorised as:

• content: being exposed to illegal, inappropriate, or harmful material; for example, pornography, fake news, suicide, racist or radical and extremist views.
• contact: being subjected to harmful online interaction with other users; for example, peer to peer pressure, commercial advertising as well as adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes.
• conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending, and receiving explicit images, or online bullying.
• commerce: risks such as online gambling, inappropriate advertising, phishing and / or financial scams.

The College have systems in place to filter and block internet access to harmful sites and inappropriate content. These systems are monitored and regularly reviewed to ensure that they are effective. Staff have all undertaken online safety training and are aware of their role within online safety and monitoring.

Staff are aware that any concerns about online safety must be reported to the Safeguarding team.

The College has a separate learner online safety and ILT acceptable use agreement which sets out the College’s processes and mechanisms to keep our learners and apprentices as safe as possible in the online world at college and in life outside of college.

h) Domestic abuse
Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. Domestic abuse is not limited to physical acts of violence or threatening behaviour, and can include emotional, psychological, controlling, or coercive behaviour, sexual and/or economic abuse. The College recognises that exposure to domestic abuse can have a serious, long-term emotional and psychological impact on learners and apprentices. We work with other key partners and will share relevant information where there are concerns that domestic abuse may be an issue for a learner, apprentice or family or be placing a child or adult at risk at risk of harm.

i) Serious violence
All staff should be aware of signs and indicators, which may signal that a learner or apprentice is at risk from or are involved with serious violent crime. This may include:

• Increased unexplained, unverified (via parents/carers) absence
• Change in friendships or relationships with older individuals or groups
• Decline in College progress
• Unexplained injuries
• Unexplained gifts or new possessions

The above could indicate that the learber or apprentice has been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk from criminal exploitation.

Staff should be aware of the range of risk factors which increase the likelihood in serious violence, such as being male, having frequent absence, having experience child maltreatment and having been involved in offending, however it must be notes that the risk factors above are not exhaustive.

j) Learners and apprentices missing College
The College recognises that for some children, young people and adults at risk, absence from College may be a potential indicator for abuse or neglect and increase their risk of radicalisation, exploitation, and harm.

The College’s attendance policy and procedures details that learners and apprentices should notify the College of absence (whatever reason, in advance of the absence or on the day) by telling their tutor or Progress and Destination Tutor (PDT) they will be absent or by reporting their absence on the absence reporting form, available on the College’s website.

If the learner or apprentice has failed to notify the College about the absence, either through direct communication with tutor(s) or via the absence reporting button on the website, the tutor or PDT should phone them to establish their whereabouts.

The College requests two parent/guardian/ NOK contact numbers for each learner and apprentice.

If no contact can be made then the absence should be notified to the Course Leader on the same day, so that follow up can be made and the parent/guardian, where age appropriate, is contacted.

If the tutor or PDT is concerned for the absent learner or apprentice’s welfare or feels that they are vulnerable they will refer this concern to a Safeguarding Officer, who will seek the advice of Adult/ Children’s Social Care and/or the Police.

k) Looked after children missing college
The College engages with Welfare Call which is commissioned Local Authorities to collect attendance information relating to Looked After Children.

Further Information on specific Safeguarding Concerns can be found on page 148 of Keeping Children Safe in Education 2024

13. Managing Safeguarding Disclosures: The 5 Rs of Safeguarding – For All Staff.

Colchester Institute uses the 5 Rs of Safeguarding. The 5 Rs are introduced to staff within the initial Safeguarding training delivered during staff induction.

• Recognise – Ability to recognise behaviour which may indicate abuse or concern
• Respond – Promptly, appropriately, and sensitively to the learner and the situation
• Report – Report concerns to a Safeguarding Officer
• Record –
  o Record precisely and promptly what has been alleged, ensuring details are accurate & factual,
  o Do not ask questions and do not investigate
  o Do not record yours or others’ opinions as your report may be used as legal evidence
  o Give notes to the Safeguarding Officer
• Refer – The Safeguarding Officer will decide if referral is appropriate and to which agency referral is made

14. Procedures for reporting concerns – All Staff, contractors, sub-contractors, volunteers and Governors

Allegations or concerns of harm or abuse against learners or apprentices.

Staff may become aware of possible concerns or actual harm or abuse either by observation of behaviour or through direct disclosure by the individual themselves or a third party for example a friend or family member.

If a learner or apprentice starts to be abused, their behaviour may change; a calm person may become loud and disruptive; a lively person may become quiet and withdrawn. Learners and apprentices may:

• present with bruises and injuries that they have difficulty explaining or that are in places where it is difficult to sustain injury accidentally e.g., neck, cheeks, eyes, shoulders and top of the arms;
• be scared, tearful and may present unusual, difficult, or strange behaviour;
• self-harm or place themselves in risky situations;
• attempt suicide

The staff member who receives the concern/has concerns must not investigate but it may be necessary to ask straightforward, non-leading questions of learners and apprentices. If staff take brief factual notes, they can be written on a SGC1 Form (Appendix 1) or plain paper and passed onto a Safeguarding Officer within the relevant time frames. If making a written record it should state date, time, people present as well as what was said. If injuries are present and require treatment a First Aider should be called and injuries should be recorded on a skin map (available from the Safeguarding Team). Referrals can also be made to Safeguarding by telephoning 01206 712828 (operational College hours and term time only). If the learner or apprentice is at immediate risk of harm a referral must be made to the Safeguarding Team immediately in person by accompanying the learner/apprentice to the Safeguarding Team.

Referral to a Safeguarding Officer – what happens next?
Once the Safeguarding Officer receives the details of the concern from the member of staff/learner/apprentice/third party or has met the learner/apprentice and undertaken preliminary enquiries including the nature of the concern the Safeguarding Officer will make a decision about action or referrals to safeguard the learner/apprentice from harm. This may be a direct referral to Social Care by telephone. The referral may need to be followed up in with an Essex Social Care Request for Support Form (for Essex) – available online only (for children) or SET SAF 1 (Adults), a report/referral to the Police, accessing emergency services (Ambulance) or other relevant agencies. If a Safeguarding Officer requires guidance on which agency is best placed to support and safeguard the learner or apprentice, they will seek guidance from Social Care Children and Families Consultation Line, Adult Social Care, CAMHS Single Point of Access, Adult Mental Health, health services or the Police.

A record of concerns about learners and apprentices must be kept even where there is no need to refer the matter immediately.

All records of concern reported to the Safeguarding Team are recorded on a secure online system. Any paper notes and documentation relating to safeguarding and child protection are kept in a locked cabinet and not in the learner or apprentice’s educational file.

Appendix 2 displays a flow chart for referrals to a Safeguarding Officer. Appendix 3 is a flow chart followed by the Safeguarding Officers.

15. Confidentiality

Staff must never give an undertaking of absolute confidentiality. If staff do give an undertaking of absolute confidentiality, this could be regarded as an act of misconduct which would be addressed under the College’s disciplinary procedure.

The College has a professional responsibility to share relevant information about the protection of learners and apprentices with other professionals, particularly investigative agencies such as Social Care the Designated Safeguarding Lead at the relevant school (if appropriate) and the Police (if appropriate). If a learner or apprentice confides in a member of staff and requests that the information is kept secret, it is important that the member of staff tells the them that they have a responsibility to refer safeguarding concerns to the College Safeguarding Team who will then refer to the appropriate agencies. Within that context, the learner or apprentice should, however, be assured that the matter will be disclosed only to people who need to know about it. Staff who receive information about learners, apprentices, and their families in the course of their work should share that information only within appropriate professional contexts.

16. Information Sharing

Where possible, consent to share information with agencies and internal staff should be sought from the learner or apprentice and recorded. However, GDPR and the Data Protection Act 2018 are not barriers to sharing information for the purposes of keeping children, young people, and adults at risk safe.

Information Sharing: Advice for practitioners providing safeguarding services to children, young people, parents, and carers 2024 states.

“Information sharing in a safeguarding context means the appropriate and secure exchange of personal information, between practitioners and other individuals with a responsibility for children, in order to keep them safe from harm.”

“Data protection legislation (the Data Protection Act 2018 (the DPA 2018) and UK General Data Protection Regulation (UK GDPR)) does not prevent the sharing of information for the purposes of safeguarding children, when it is necessary, proportionate and justified to do so. In fact, data protection legislation provides a framework which enables information sharing in that context. The first and most important consideration is always whether sharing information is likely to support the safeguarding of a child. “

Sharing Safeguarding information with parents, carers, next of kin
Where the College has a Safeguarding concern about a learner or apprentice under the age of 18 years of age, or under 25 years if they are an adult at risk or a learner who has turned 18 whilst enrolled at the College (were 17 years old at the point of enrolment), parents or next of kin will be informed of the concern about the learner or apprentice so we can work together to support the learner or apprentice. The College will not contact parents or next of kin if informing them would place the learner or apprentice at risk of harm.

In some cases, the College will be told by Social Care or the Police that the sharing of information with the learner or apprentice, parents/carers/next of kin, staff, other learners involved is prohibited. The College will adhere to Police and Social Care instruction.

Parents/carers/next of kin are encouraged to seek and engage with support for the learner or apprentice outside of college in addition to the support the College can offer. This is vital to safeguard the learner or apprentice both inside and outside of college.

Staff will never guarantee confidentiality to anyone (including parents/carers or pupils) about a safeguarding concern, nor promise to keep a secret.

Life Threatening Situations/concerns for welfare
In situations where a learner or apprentice’s life is at risk (suicide plans/attempts/threats of violence/harm against them/others) or there is concern for the welfare and or safety of a learner, information will be shared with the emergency services, Social Care (where appropriate) and the learners/apprentices named parent/carer/next of kin, (unless this would place the learner or apprentice at risk) regardless of their age.

The College is committed to preserving life.

Sharing Safeguarding information with internal staff
Sharing information with staff internal to Colchester Institute will be assessed by the Safeguarding Officer on a case-by-case basis. Safeguarding Officers will always ask for consent from the learner or apprentice to share safeguarding information with internal staff. Where consent is not given but there is a need for a tutor/support member of staff to know to support the protection of the learner or apprentice, information will be shared. The learner or apprentice will be informed of this and advised with whom the information will be shared and why.

For example: a learner or apprentice who self-harms may be using sharp objects for the purposes of their studies. Extra vigilance would be required by staff directly involved in the teaching and support of the learner or apprentice, in order to safeguard them. In this instance we would need to share information with the course team to safeguard the learner or apprentice.

Situations where learners and apprentices need no additional protection, for example: historic concerns and there is no need for staff directly involved in the teaching and support of the learner/apprentice to know about the safeguarding concern, the staff will not be told unless the learner or apprentice consents to sharing the information.

Staff members should respect the privacy, wishes and confidentiality of learners and apprentices in relation to Safeguarding Officers sharing safeguarding concerns about the learner/apprentice. Staff should be confident that Safeguarding Officers will share if there is a need to share.

Safeguarding Officers will record information sharing decisions and reasons why in relation to cases when consent is not given.

17. Circumstances for referral to agencies by a non- Safeguarding Officer including out of hours

Safeguarding is everyone’s responsibility. The role of Designated Safeguarding Lead, Deputy and Safeguarding Team of Safeguarding Officers exist to ensure a main point of contact, that Safeguarding procedures are followed consistently, records are made and kept and ensure that the safety of the learner or apprentice is paramount.

In exceptional circumstances it may be necessary for staff to make a referral to external agencies (Social Care/Police/Mental Health). These exceptions may be:

If you have concerns about a learner or apprentice:

• outside of college hours or
• if you are unable to contact a Safeguarding Officer/ Designated Safeguarding Lead/Deputy and have exhausted all internal Safeguarding Contacts or
• you have concerns that the DSL, DDSL and or Safeguarding Officer are not executing their role

If the learner or apprentice is at immediate risk from harm, please dial 999. Please notify a Safeguarding Officer as soon as is reasonably possible.

If you do make a referral to Children’s Social Care/Adult Social Care/ EWMHS/Police. Please ensure you notify a Safeguarding Officer as soon as is reasonably possible after the referral has been made.

To make referral you will need:

• Learner or apprentice’s name, address, date of birth, family composition;
• other agencies involved with the learner/apprentice;
• reason for referral;
• name of person receiving the referral and any advice given;
• name and contact details of the person making the referral

Contact numbers for referrals including out of hours
If you are concerned that a child or adult at risk is at immediate risk of harm, please ring 999.

• Essex Children’s and Adult’s Social Care out of hours – 0345 606 1212
• Essex Children’s and Adult’s Social Care 8.45 – 5.30pm Mon-Thu and Fri 8.45 – 4.30
  0345 603 7627 / 0345 603 7630
• Child and Adolescent Mental Health Service up to 18 years of age – 0300 300 1600
• Mental Health referrals for 18 years plus can only be made by a Health Professional i.e.: GP
• Police Non-emergency: 101, Emergency: 999
  NHS Non-emergency advice: 111, Emergency: 999

18. The use of reasonable force in college

Keeping Children Safe in Education defines reasonable force as:

“There are circumstances when it is appropriate for staff in schools and colleges to use ‘reasonable force’ to safeguard children. The term ‘reasonable force’ covers the broad range of actions used by staff that involve a degree of physical contact to control or restrain children. This can range from guiding a child to safety by the arm, to more extreme circumstances such as breaking up a fight or where a child needs to be restrained to prevent violence or injury. ‘Reasonable’ in these circumstances means ‘using no more force than is needed’. The use of force may involve either passive physical contact, such as standing between pupils or blocking a pupil’s path, or active physical contact such as leading a pupil by the arm out of the classroom.”

Staff must always seek to defuse situations with learners/apprentices verbally, where reasonable force is deemed necessary it is advised that two staff members are present, and the reasonable force must be used for the shortest period necessary.

In all cases where reasonable force is used with any learners/apprentices it must:

• Be notified and documented to the relevant CLMG member within one working day of the incident – appendix 6 can be used to record reasonable force including details of the incident, witnesses, times, locations, method used. subsequent actions and aftercare for the learner
• be subject to de-briefing for staff involved and lead to a review of strategies for managing behaviours of learners.

19. Allegations or concerns against a member of staff, volunteer, governor, or contractor

These procedures apply to all College staff, whether they work in the main College campuses, outreach centres or other designated areas, as well as volunteers, governors, and contractors

The College will follow Keeping Children Safe in Education Part Four: Safeguarding concerns or allegations made about staff including supply teachers, volunteers and contractors as its guidance for dealing with such allegations and low-level concerns.

The College has a separate procedure for allegations of concerns and low-level concerns made about staff, volunteers, contractors, sub-contractors and Governors. These can be found in the People and Culture section of the College portal or for non-College learners/staff can be requested from the People and Culture department.

20. Intimate Personal Relationships between Staff, Learners and Apprentices

Please see section 5 for definition of intimate personal relationship

It is vital that all staff, volunteers, contractors, sub contractors and Governor’s at the College understand the level of professional conduct expected of them in respect of intimate personal relationships with learners and apprentices at all times.

The Sexual Offences Act 2003 makes it an offence for a person over 18 (e.g., a lecturer or other member of staff) to have a sexual relationship with a child under 18 where that person is in a position of trust in respect of that child, even if the relationship is consensual. It can also potentially be an offence under this Act for a staff member to have a sexual relationship with an adult at risk.

The Office for Learners (OfS) which regulates the College’s Higher Education provision recommends a ban on intimate personal relationships between staff and learners/apprentices age 18 years and over.

To protect all our learners and apprentices, intimate personal relationships between staff volunteers, contractors, sub-contractors and Governors and learners/apprentices are strictly prohibited at Colchester Institute.

To enter into an intimate personal relationship with any learner or apprentice, will constitute gross misconduct and will lead to a referral to the Police, Local Area Designated Officer, Disclosure and Barring Service and dismissal from the College.

The College understands that there will be occasions where:

A learner’s, existing partner with whom they have a intimate personal relationship, gains employment/volunteering/contractor. sub contractor/Governing position at Colchester Institute or

A staff member, volunteer, contractor, sub contractor, Governor’s, existing partner that they have a intimate personal relationship with enrols at the College as a learner.

If the above situations occur, they must be disclosed as soon as possible to:

• Their College Executive Member
• Their CLMG Manager
• Their Line Manager
• The Director of People and Culture (or their deputy)
• Member of staff that manages the contract

Failure to disclose an existing intimate personal relationship at the earliest opportunity for the staff member with any learner or apprentice will be dealt with under the College’s disciplinary procedure and is likely to constitute gross misconduct.

21. Family and Friend/acquaintance relationships

No staff member, contractor, sub-contractor, volunteer or Governor must use their role at the College to become friends or gain friendship or acquaintanceships with enrolled learners or apprentices. If staff members, contractors, sub-contractors, volunteers or Governors have existing family, friend or acquaintanceship relationship/s with enrolled learners or apprentices this must be declared as soon as possible.

This declaration must be made to:

• Their CLMG Manager
• Their Line Manager
• People and Culture Team
• Member of staff that manages the contract (for contractors/sub contractors)

Failure to disclose such information will be dealt with under the College’s disciplinary procedure and is likely to constitute gross misconduct.

22. Whistleblowing

All staff, contractors, sub-contractors, volunteers and Governors should feel able to raise concerns about poor or unsafe practice and potential failures in the College’s safeguarding regime and know that such concerns will be taken seriously by the Senior Leadership Team. This can be done via the College’s Whistle Blowing Policy available from the People and Culture section of the Portal or by contacting the People and Culture team and requesting the Policy.

Where a staff member, contractor, sub contractor, volunteer or Governor feels unable to raise an issue with their employer via the College’s whistleblowing procedure or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them:

• General guidance can be found at- –
  o The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and email: help@nspcc.org.uk

Alternatively if a staff member has a concern related to an adult working with children and learners and does not wish to raise the concern via the College’s Safeguarding process they can contact the Essex Local Area Designated Officer (LADO) by e-mail: lado@essex.gov.uk (Please note this is not a secure address so any information sent must be password protected).

23. Learner Work Experience, Work Placements, and Industry Placements

The College uses Health and Safety guidance from the DfE and HSE for work experience work placements and industry placements.

Staff who arrange and monitor work experience, work placements, industry placements and apprenticeships must have undertaken the College safeguarding training.

Employers – hosting work placement, work experience and or industry placements will be checked using the DfE guidance to ensure that the locations and environments in which learners will be completing their work experience, industry placement are appropriate, and that the employer understands their statutory responsibilities given a learner on a placement with the employer, always ‘counts as an employee’ for safety law and therefore has a right to all the same Health and Safety protections that one of their employees would have.

The Employer then has a statutory obligation to provide a safe system of work for that learner ‘as an employee’ including any necessary risk assessment and any required policies and procedures.

Our Safeguarding Policy guidelines are given to businesses where they don’t already have a safeguarding policy in place.

All apprentice employers will be monitored as part of the initial sign-up process and the 12 weekly review process.

The HSE is clear in its advice that the management of health & safety for placements rests with the employer and should not be a barrier. Their advice states that ‘there are very few work activities a learner cannot do due to health and safety law’.

The College need to:

• take reasonable steps to satisfy ourselves that the employer is managing any significant risks
• rely on past experience with the employer where no significant change has taken place
• work with parents to ensure employers know in advance about learners who might be at greater risk
• keep checks in proportion to the environment
• check that the employer understands about the specific factors relevant to employing young people
• check that learners and apprentices know how to raise any health and safety concerns
• Ensure that factors relating to individual learners or apprentices are taken into consideration where necessary (medical conditions, allergies, support needs, etc.)

Sole Traders
We are defining a Sole Trader as a person who normally conducts their business on their own and works on a Self-Employed basis by arrangement or under contract to others. All Sole Traders must be given a copy of the Safeguarding Guidance for Sole Traders.

Work Experience can be completed with sole traders, either where the learner is already employed by the sole trader or where it is a new employer and the College have obtained informed consent from the parent/guardian.

Prior to commencing work experience with a sole trader, the parents/carers of a learner who is under the age of 18 years is asked to read and sign a special consent form for their child to commence work experience with the sole trader. The consent form gives information about possible additional risks of working with a sole trader.

As noted above: All learners on work experience and placement count as employees under Health and Safety Law and should be covered by Health and Safety Law and Employment Law and the Employer’s Liability Insurance. Employers Liability Insurance is normally required unless they are a very close family member.

Learners cannot legally enter into any arrangement where they accept nominal ‘Self Employed’ status for themselves to ‘help an employer out’ as they always have the full status of employees and therefore in all cases the person taking them on is or becomes an Employer with full responsibilities to them that cannot be set aside or disregarded.

This is not acceptable, and the College will not place a learner under those circumstances as the College must ensure they are protected as employees under law.

Work Placements
Learners over 16 years whose course work placement includes unsupervised access to children and young people will be required to have a clear enhanced DBS check. If the learner will be working with children under 8 years old, they will also need to complete a Childcare Disqualification Regulation form 2009.

The DfE guidance referenced in the above section issued when working with employers to ensure that the locations and environments in which learners will be completing their work placements are appropriate, and that the employer has sufficient Health and Safety policies in place.

When a workplace check suggests that an employer does not have appropriate safeguarding and child protection policies or awareness of safeguarding and child protection issues or is unwilling to subscribe to the principles of Colchester Institute’s Safeguarding and Child

Protection policy or where there is evidence of risks to child safety, tutors will be instructed to ensure that no learners are placed with that employer.

The College will ensure that:

• Work Experience paperwork is checked by a tutor or course leader;
• Industrial Placements Workplace checklist will be checked by the relevant workplace co-ordinator;
• Apprentice placements paperwork is checked by the Assessors.
• This policy is available online for all Colchester Institute staff involved in placements to refer to and should be used in addition to the Safeguarding Guidance for Sole Traders and the Safeguarding Guidance for Online Home Working.

Through the guidance notes for learners on placements, learners who are placed with employers will be given clear advice about whom to report concerns in relation to Health, Safety or Safeguarding.

If a learner is concerned for their safety whilst on work experience or industry placement, they should call the College Safeguarding Team on 01206 712828 (this is not a 24-hour line, calls will be answered Mon-Thurs 8.30-5.00pm and Fri 8.30 – 4.30pm College Term Time Only). If a learner is at immediate risk of harm at any time, please phone the emergency services on 999.

24. Records

The Designated Safeguarding Lead will be responsible for maintaining records, in a secure place, of all safeguarding referrals.

Documents relating to allegations, concerns, low level concerns, investigations or action taken in relation to staff, volunteers, contractors, governors or any staff disciplinary action and records will be kept by People and Culture Team in accordance with the People and Culture procedures.

25. Awareness of Safeguarding – Learners, Apprentices and Parents

Learners on study programmes will be made aware of safeguarding and potential safeguarding issues, how to keep themselves safe and what to do if they have concerns through: learner induction, personal development lessons, learner services video, cross college awareness events, guest speakers, workshops, their college ID card, posters around College, College Portal, Safeguarding briefings and in the course of studying at the College.

Learners enrolled on a study programme will explore safeguarding topics within their timetabled personal development lessons. The personal development scheme of work includes mandatory safeguarding sessions which are delivered, this forms part of the College’s duty to raise awareness of Safeguarding topics, equipping learners to make good choices, keep themselves and other safe and make a positive difference to their own life experiences. Topics explored include: Prevent and radicalisation, Diversity, Equity and Inclusion, Risky Behaviours, Healthy Relationships including sexual harassment and harmful sexual behaviour, online safety.

Apprentices will be made aware of potential safeguarding issues (including radicalisation, exploitation, online- safety, bullying,), how to keep themselves safe and what to do if they have concerns through: induction, learner services video, assessor visits and reviews, cross college awareness events, guest speakers, workshops, their college ID card, posters around College, College Portal, Safeguarding briefings, in the course of studying at the College and access to the online platform “You Matter” which covers a broad range of topics relevant to apprentices and adult learners to raise awareness of topics.

Adult learners will be made of potential safeguarding issues (including radicalisation, online safety, personal safety) via their induction and access to the online platform “You Matter” (please see above).

Learners and apprentices can access advice and information on welfare and safeguarding issues whilst enrolled by contacting the Welfare and Safeguarding team either by email, phone or in person. Contact details for the Welfare and Safeguarding team are available and communicated as detailed in Appendix 7.

The College will ensure that parents, carers and stakeholders are aware of the College’s commitment to Safeguarding by including its commitment to this in corporate publications including on the College website.

26. Recruitment of Staff and Volunteers

The College will implement procedures to ensure that all appropriate checks are carried out on all staff, contractors, sub-contractors, volunteers and Governors working at the College,. This will be documented in a Single Central Record as set out in Keeping Children Safe in Education guidance. Enhanced DBS disclosures will be obtained, and the barred list checked for all staff appointed to positions where the person will be engaging in regulated activity with children and adult at risk. The College has a separate Recruitment and Selection Policy and Procedure and Vetting Checks and Single Central Register Policy.

Volunteers to the College where regulated activity will be taking place will also require an Enhanced DBS check and the barred list checked.

27. Staff Training and Support

The College will provide safeguarding training for all staff working with learners.

The training will;

• help staff to recognise the signs of possible harm to learners and apprentices.
• ensure that staff know how to proceed when possible harm is suspected and whom to contact;
• inform staff of college procedures and policies in the area, relevant legislation and the role of the designated members of staff for child protection.

Safeguarding training is included within the Induction programme for all new staff.

All College Governors undertake Safeguarding Training.

Safeguarding refresher training for all staff is required at least every 3 years. Failure to complete this refresher training could be deemed an act of misconduct and if so, would initiate actions under the College’s disciplinary procedure.

Safeguarding updates relevant to all staff will be shared when they arise. An annual Safeguarding information update will be communicated to all staff, alongside termly briefings.

Support for staff receiving disclosures
Support is available for members of staff who have received disclosures. In many cases, this can be a painful and disturbing experience for the recipient, who may in some cases require counselling support. Staff Counselling can be arranged via the Employee Assistance Programme.

Informal support can be sought from Safeguarding Officers however it must be made clear that the support is informal and that they are not drawn into a pseudo-counselling relationship with the staff member who received the disclosure.

Support for Safeguarding Officers
Safeguarding Officers will receive monthly supervision with an external supervisor to ensure their emotional wellbeing is supported. Peer support from other Safeguarding Officers, the Designated Safeguarding Lead and their deputies is available daily as and when required either as a way of escalating concerns, talking through options, or sharing difficult cases. Safeguarding Officers can also access Staff Counselling via the Employee Assistance Programme.

28. Communication of this Policy and Safeguarding Officers’ Contact Details

Staff, learners and apprentices, volunteers and visitors will be made aware of the College Safeguarding Policy, Safeguarding Officers, and where and how to seek help through the following communication channels: –

• Portal and email
• Induction procedures for new staff, learners, and apprentices
• Apprentices – Assessor visits
• Apprenticeships – employer Safeguarding document
• Prospectus
• ID cards
• Fold out Z card for Part time learners and visitors
• Posters listing Safeguarding Officer Contact number
• Publication on the College Portal of helpful information accessible to learners and apprentices e.g., Childline, NSPCC
• Promotion of support provided through Learner Services.
• From staff, assessors, and employers

29. Reports to the governing body

The Designated Safeguarding Lead (DSL) will report to the Corporation Board on safeguarding, systems, and statistics. These will include any changes to the policy, training undertaken and numbers of safeguarding incidents.

In addition, the safeguarding incidents will be reported to each Curriculum and Quality Committee (or as they occur if there is nothing to report). Such reports will be made with due regard to confidentiality i.e., names will not be included.

30. Monitoring and Review

This policy will be reviewed annually.

31. Associated Policies and Documents

This policy should not be read in isolation and should be cross-referenced with all relevant College policies, procedures and guidelines including: –
Associated Staff Policies

• Safeguarding Protocol for Staff
• Staff Code of Conduct
• Allegations against about staff, volunteers, contractors, and governors
• Staff Disciplinary Policy
• Diversity, Equity, and Inclusion Policy
• Guidelines for online home working
• Staff Induction procedures
• Staff Dignity at Work Policy (staff
• Prevent Strategy
• Health & Safety Policy
• First Aid Policy
• Recruitment and Selection Policy and Procedure
• Vetting Checks and Single Central Register Policy
• Work experience for Study Programmes policy

Associated Learner Polices

• Learner Criminal Conviction and Pending Prosecution Policy
• Diversity, Equity, and Inclusion Policy
• Safeguarding Guidelines for Sole Traders
• Learner E-Safety policy and ILT Code of Conduct
• Learner bullying/harassment procedures
• Learner Professional Standards and Conduct Policy
• Learner attendance Policy
• Prevent Strategy
• Health & Safety Policy
• First Aid Policy
• Work experience for Study Programmes policy
• Learner Bullying, Harassment Policy
• Learner Sexual Harassment Policy
• Harmful Sexual Behaviours – Peer on Peer Sexual Abuse
• Learner Fitness to Study and Practice Policy

APPENDIX 1

Safeguarding Concerns 1 Record Form
Colchester Institute
When should I complete this form?
This form should be completed when you have a Safeguarding Concern about a learner or have received a disclosure and the learner is not at risk from immediate harm.
This form must be submitted to Safeguarding within one working day of the disclosure/concern.
Submitting the form
Please bring this form to Learner Services: Safeguarding (Colchester and Braintree) or email to sswelfare@colchester.ac.uk. Please password protect the document.
Safeguarding Team Locations Colchester and Braintree Ground Floor B Block (Colchester), Learner Services – Learner Hub (Braintree).
If the learner is at immediate risk from harm, please bring the learner down with you to Learner Services: Safeguarding immediately (Colchester and Braintree) Once the Safeguarding Officer is handling the case and the learner is safe you may be asked to complete this form.
By phone Safeguarding can be contacted on ext. 2828 8.30am – 5pm Monday – Thursday and 8.30am – 4.30pm Friday, Term Time Only. Out of hours, if the learner is at risk, please call the emergency services on 999.
This form can be used by the staff member to record and refer a concern or if they have received a disclosure of concern from a student/third party.

Details of Concern/Disclosure
Date
Time
Name of learner/s
Learner Number
Learner D.o.B.
Learner Age
Learner Course
Staff Member Name:
Details of concern/disclosure: (Please attach extra sheets if required)
Record the following factually using the learner’s words:
Who? What? Where? When (date and time of any incident/s), Any witnesses?
What has been done to ensure the immediate safety of the learner?
Signature of Staff Member:

APPENDIX 2

Flow Chart – Staff referral to a Safeguarding Officer