Policy Reference: PV1
Date Written: September 2018
Review Version: 5

Applies To: Everyone within the company, including students and associates.

Author: Melissa Mcilhiney, Company Director
Review Approved By: Sophie Dye-Walton

Implementation Date of Reviewed Document: 19 May 2025
Next Review Date: 19 May 2026

This policy has been reviewed to ensure it promotes safeguarding and does not present barriers to participation or disadvantage any protected groups

Summary of Changes since last version of the policy:

Full policy review as a result of updated KCSIE 2023 – please ensure you read, understand and adhere to this version and discard any older versions.

The latest update to Keeping Children Safe in Education (KCSIE) 2023 was released on the GOV.UK website on 6th June 2023.

Important Changes within Powerful Voices Ltd:

Safeguarding Key Contacts

If you have an urgent concern about a child or young person, call 999 or 101.

In the event of an allegation against the site lead then you are to directly contact the relevant council safeguarding team. If the allegation is against the DSL then please inform the site lead.

Aims

Powerful Voices aims to ensure that:

Appropriate action is taken in a timely manner to safeguard and promote children’s welfare.

All staff are aware of their statutory responsibilities with respect to safeguarding.

Staff are properly trained in recognizing and reporting safeguarding issues

Legislation and statutory requirements

This policy is based on the Department for Education’s statutory guidance, Keeping Children Safe in Education (2022) and Working Together to Safeguard Children (2018), and the NHS Clinical Guidelines.

We comply with this guidance and the arrangements agreed and published by our 3 local safeguarding partners.

This policy is also based on the following legislation:

• Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015, which places a statutory duty on health professionals to report to the police where they discover that female genital mutilation (FGM) appears to have been carried out on a girl under 18. Statutory guidance on FGM, which sets out responsibilities with regards to safeguarding and supporting girls affected by FGM.

The Rehabilitation of Offenders Act 1974, which outlines when people with criminal convictions can work with children, Schedule 4 of the Safeguarding Vulnerable Groups Act 2006, which defines what ‘regulated activity’ is in relation to children.

Statutory guidance on the Prevent duty, which explains professionals’ duties under the Counter-Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism.

The Human Rights Act 1998, which explains that being subjected to harassment, violence and/or abuse, including that of a sexual nature, may breach any or all of the rights which apply to individuals under the European Convention on Human Rights (ECHR) The Equality Act 2010, which makes it unlawful to discriminate against people regarding particular protected characteristics (including disability, sex, sexual orientation, gender reassignment and race).

This means those acting in a position of governance should carefully consider how they are supporting their Clients with regard to these characteristics.

The Act allows our company to take positive action to deal with particular disadvantages affecting Clients (where we can show it is proportionate). This includes making reasonable adjustments for disabled Clients. For example, it could include taking positive action to support girls where there is evidence that they are being disproportionately subjected to sexual violence or harassment

Where Clients are aged under 8:

The Childcare (Disqualification) and Childcare (Early Years Provision Free of Charge) (Extended Entitlement) (Amendment) Regulations 2018 (referred to in this policy as the “2018 Childcare Disqualification Regulations”) and Childcare Act 2006, which set out who is disqualified from working with children.

Where early years provision is offered: This policy also meets requirements relating to safeguarding and welfare in the statutory framework for the Early Years Foundation Stage.

Please see section 18 for locally agreed multi-agency procedures that have been put in place by the Local Children’s Safeguarding Board (LCSB)/ 3 safeguarding partners.

Scope

This policy should be implemented for children and young people who are under the age of 18. There is a separate policy for safeguarding adults.

Roles and responsibility:

Safeguarding and child protection is everyone’s responsibility. This policy applies to all staff, volunteers and those acting in a governance capacity in the site and is consistent with the procedures of the 3 safeguarding partners. Our policy and procedures also apply to extended site and off-site activities. Our therapy plays a crucial role in preventative education. This is in the context of a holistic approach to preparing children for life in modern Britain, and a culture of zero tolerance of sexism, misogyny / misandry, homophobia, biphobia, and sexual violence / harassment.

All staff

All staff will:

• Read and understand part 1 and Annex B of the Department for Education’s statutory safeguarding guidance, Keeping Children Safe in Education, and review this guidance at least annually, undertaking annual online safeguarding training.
• Place in writing every year to say that they have reviewed the guidance, that they understand it and that they will adhere to it.
• Reinforce the importance of online safety when communicating with parents. This includes making parents aware of what we ask children to do online (e.g. sites they need to visit or who they’ll be interacting with online).
• Provide a safe space for clients who are LGBT to speak out and share their concerns.

All staff will be aware of:

Our systems which support safeguarding, including this child protection and safeguarding policy, the staff code of conduct, the role and identity of the designated safeguarding lead (DSL) and their deputies, the behaviour policy, the online safety policy, the safeguarding response to children who go missing from education and how to record clinical notes in WriteUpp.

The early help process (sometimes known as the common assessment framework) and their role in it, including identifying emerging problems, liaising with the DSL, and sharing information with other professionals to support early identification and assessment The process for making referrals to local authority children’s social care and for statutory assessments that may follow a referral, including the role they might be expected to play.

What to do if they identify a safeguarding issue or a child tells them they are being abused or neglected, including specific issues such as FGM, and how to maintain an appropriate level of confidentiality while liaising with relevant professionals

The signs of different types of abuse and neglect, as well as specific safeguarding issues, such as child-on-child abuse, child sexual exploitation (CSE), child criminal exploitation (CCE), indicators of being at risk from or involved with serious violent crime, FGM, radicalisation and serious violence (including that linked to county lines).

The importance of reassuring victims that they are being taken seriously and that they will be supported and kept safe.

The fact that children can be at risk of harm inside and outside of their home, at school and online.

The fact that children who are (or who are perceived to be) lesbian, gay, bi or trans (LGBT) can be targeted by other children What to look for to identify children who need help or protection.

The rainbow code/ tag on the clinical note system and how to contact the DSL team if they have concerns.

Safeguarding and child protection training must now include an “understanding of the expectations, applicable roles and responsibilities in relation to filtering and monitoring”. As specified last year, this training must also be regularly updated, and all staff “should receive safeguarding and child protection (including online safety) updates as required…to continue to provide them with relevant skills and knowledge to safeguard children effectively.”

Filtering and monitoring technology is also highlighted as a vital part of ensuring pupils are not accessing harmful or illegal content on school owned devices.

The designated safeguarding lead (DSL):

The DSL is a member of the Powerful Voices Team. Our DSL is named in the important contacts sheet on page 3 of this policy. The DSL takes lead responsibility for child protection and wider safeguarding. The DSL will be available 9-5.30 on her/his working days and then the out of hours contact will take over.

Details of how the DSL can be contacted out of hours if necessary is outlined on page 3.

When the DSL is absent, the deputies outlined on page 3 will act as cover.

The DSL will be given the time, funding, training, resources, and support to: Provide advice, support, and training to other staff on child welfare and child protection matters.

Take part in strategy discussions and inter-agency meetings and/or support other staff to do so.

Contribute to the assessment of children. Refer suspected cases, as appropriate, to the relevant body (Local authority children’s social care, Channel programme, Disclosure and Barring Service, and/or police), and support staff who make such referrals directly via WriteUpp notes and ensure it is up to date and completed correctly.

Open cases should be reviewed at least weekly with updates recorded. When a case is closed, the DSL must ensure all fields have been fully completed and that the narrative, chronology and all actions are clear and robust.

Any member of the team with a safeguarding concern will need to write the concern within the clinical notes straight away.

Have a good understanding of harmful sexual behaviour:

 The DSL will also:

• Keep the site lead informed of any issues
• Liaise with local authority case managers and designated officers for child protection concerns as appropriate
• Discuss the local response to sexual violence and sexual harassment with police and local authority children’s social care colleagues to prepare the site’s local procedures and policies
• Be confident that they know what local specialist support is available to support all children involved (including victims and alleged perpetrators) in sexual violence and sexual harassment, and be confident as to how to access this support
• Be aware that children must have an ‘appropriate adult’ to support and help them in the case of a police investigation or search.

In relation to the emphasis on filtering and monitoring systems and standards, there is added clarification that the Designated Safeguarding Lead has chief responsibility for this within their school/college.

Governing bodies and proprietors have also been specified as responsible members for ensuring “all staff undergo safeguarding and child protection training” which includes the new outlines of filtering and monitoring systems. This training should be regularly updated, as in line with KCSIE 2023

The Company Lead:

The Company Lead is responsible for the implementation of this policy, including:

Ensuring that staff (including temporary staff) and volunteers:  Are informed of our systems which support safeguarding, including this policy, as part of their induction.

Understand and follow the procedures included in this policy, particularly those concerning referrals of cases of suspected abuse and neglect.

Communicating this policy to parents when their child joins the school/college/home.

Ensuring that the DSL has appropriate time, funding, training and resources, and that there is always adequate cover if the DSL is absent.

Reviewing WriteUpp every two weeks and hold DSLs/deputies to account where it is not up to date or records indicate non-compliance.

Ensuring that all staff undertake appropriate safeguarding and child protection training, and updating the content of the training regularly Acting as the ‘disciplining and investigating manager’, or appointing an appropriate ‘investigating manager’, in the event of an allegation of abuse made against another member of staff or volunteer, where appropriate (see A142 Allegations of Abuse Against Staff Policy).

Making decisions regarding all low-level concerns, though they may wish to collaborate with the DSL on this Ensuring consultation with the local authority designated officer (LADO) if there is any doubt as to whether a safeguarding concern around staff conduct meets the harm threshold.

Definitions

Safeguarding and promoting the welfare of children means: Protecting children from maltreatment, Preventing impairment of children’s mental and physical health or development.

Ensuring that children grow up in circumstances consistent with the provision of safe and effective care.

Taking action to enable all children to have the best outcomes.

Child protection is part of this definition and refers to activities undertaken to prevent children suffering, or being likely to suffer significant harm.

Abuse is a form of maltreatment of a child, and may involve inflicting harm or failing to act to prevent harm.

Appendix 1 explains the different types of abuse.

Neglect is a form of abuse and is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.

Appendix 1 defines neglect in more detail.

Sharing of nudes and semi-nudes (also known as sexting or youth produced sexual imagery) is where children share nude or semi-nude images, videos or live streams. Children includes everyone under the age of 18.

The 3 safeguarding partners are identified in Keeping Children Safe in Education (and defined in the Children Act 2004, as amended by chapter 2 of the Children and Social Work Act 2017). They will make arrangements to work together to safeguard and promote the welfare of local children, including identifying and responding to their needs:  The local authority (LA), A clinical commissioning group for an area within the LA, The Chief Officer of Police for a police area in the LA area.

Victim is a widely understood and recognised term, but we understand that not everyone who has been subjected to abuse considers themselves a victim, or would want to be described that way.

When managing an incident, we will be prepared to use any term that the child involved feels most comfortable with.

Version: 5 Child Protection and Safeguarding Policy, Author: Powerful Voices. Implementation date: January 2023 ref: PV1.

Alleged perpetrator(s) and perpetrator(s) are widely used and recognised terms. However, we will think carefully about what terminology we use (especially in front of children) as, in some cases, abusive behaviour can be harmful to the perpetrator too. We will decide what’s appropriate and which terms to use on a case-by-case basis

Equality statement

6.1 Some children have an increased risk of abuse, and additional barriers can exist for some children with respect to recognising or disclosing it. We are committed to anti-discriminatory practice and recognise children’s diverse circumstances. We ensure that all children have the same protection, regardless of any barriers they may face.

6.2 We give special consideration to children who:

Have special educational needs (SEN) or disabilities or health conditions (see section 11)

Are young carers

May experience discrimination due to their race, ethnicity, religion, gender identification or sexuality.

Have English as an additional language.

Are known to be living in difficult situations – for example, temporary accommodation or where there are issues such as substance abuse or domestic violence.

Are at risk of FGM, sexual exploitation, forced marriage, or radicalisation.

Are asylum seekers.

Are at risk due to either their own or a family member’s mental health needs.

Are looked after or previously looked after (see section 13).

Are missing from education.

Whose parent/carer has expressed an intention to remove them from school to be home educated.

Confidentiality

7.1 Powerful Voices Ltd is committed to conducting its business in accordance with all applicable Confidentiality and Data Protection laws and regulations and in line with the highest standards of ethical conduct. Staff should refer to the Confidentiality Policy, Data Protection Policy and their associated forms and guidance.

7.2 Powerful Voices recognises: Timely information sharing is essential to effective safeguarding. Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare, and protect the safety, of children.

The Data Protection Act (DPA) 2018 and UK GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe.

If staff need to share ‘special category personal data’, the DPA 2018 contains ‘safeguarding of children and individuals at risk’ as a processing condition that allows practitioners to share information without consent if it is not possible to gain consent, it cannot be reasonably expected that a practitioner gains consent, or if to gain consent would place a child at risk.

Staff should never promise a child that they will not tell anyone about a report of abuse, as this may not be in the child’s best interests. If a victim asks the site not to tell anyone about the sexual violence or sexual harassment: There’s no definitive answer, because even if a victim doesn’t consent to sharing information, staff may still lawfully share it if there’s another legal basis under the UK GDPR that applies.

The DSL will have to balance the victim’s wishes against their duty to protect the victim and other children

The DSL should consider that:

• Parents or carers should normally be informed (unless this would put the victim at greater risk)
• The basic safeguarding principle is: if a child is at risk of harm, is in immediate danger, or has been harmed, a referral should be made to local authority children’s social care
• Rape, assault by penetration and sexual assault are crimes. Where a report of rape, assault by penetration or sexual assault is made, this should be referred to the police. While the age of criminal responsibility is 10, if the alleged perpetrator is under 10, the starting principle of referring to the police remains

Regarding anonymity, all staff will:

• Be aware of anonymity, witness support and the criminal process in general where an allegation of sexual violence or sexual harassment is progressing through the criminal justice system
• Do all they reasonably can to protect the anonymity of any children involved in any report of sexual violence or sexual harassment, for example, carefully considering which staff should know about the report, and any support for children involved
• Consider the potential impact of social media in facilitating the spreading of rumours and exposing victims’ identities The government’s information sharing advice for safeguarding practitioners includes 7 ‘golden rules’ for sharing information, and will support staff who have to make decisions about sharing information (see Powerful Voices Data Protection Policy) If staff are in any doubt about sharing information, they should speak to the designated safeguarding lead (or deputy).

7.3 Confidentiality is also addressed in this policy with respect to record-keeping in section 15, and allegations of abuse against staff in appendix 3.

Recognising abuse and taking action

Staff and volunteers must follow the procedures set out below in the event of a safeguarding issue. Please note – in this and subsequent sections, you should take any references to the DSL to mean “the DSL (or deputy DSL)”.

8.1 If a child is suffering or likely to suffer harm, or in immediate danger tell your DSL immediately, they will make a referral to children’s social care or the police. If a DSL is not available, make a referral to children’s social care and/or the police immediately if you believe a child is suffering or likely to suffer from harm, or in immediate danger. Anyone can make a referral. Tell the DSL (see section 8.2) as soon as possible if you make a referral directly.

See section 18 Local Procedures for making a referral, as per the arrangements put in place by the LCSB/3 safeguarding partners Guidance on how to refer to a local council can be found here: https://www.gov.uk/report-child-abuseto-local-council

8.2 If a child makes a disclosure to you, you should: Listen to and believe them. Allow them time to talk freely and do not ask leading questions.

• Stay calm and do not show that you are shocked or upset.
• Tell the child they have done the right thing in telling you. Do not tell them they should have told you sooner.
• Explain what will happen next and that you will have to pass this information on.
• Do not promise to keep it a secret.

Write up your conversation (this can be done directly on WriteUpp or written up as a note and scanned) as soon as possible in the child’s own words. Stick to the facts, and do not put your own judgement on it. The written notes should be kept securely by the DSL or destroyed securely once these have been uploaded. Sign and date the write-up and upload it to WriteUpp or pass it on to the DSL. Alternatively, if appropriate, make a referral to children’s social care and/or the police directly (see 8.1), and tell the DSL as soon as possible that you have done so.

Aside from these people, do not disclose the information to anyone else unless told to do so by a relevant authority involved in the safeguarding process Report via WriteUpp as soon as possible.

Bear in mind that some children may:

• Not feel ready, or know how to tell someone that they are being abused, exploited or neglected
• Not recognise their experiences as harmful
• Feel embarrassed, humiliated or threatened. This could be due to their vulnerability, disability, sexual orientation and/or language barriers.

None of this should stop you from having a ‘professional curiosity’ and speaking to the DSL if you have concerns about a child.

8.3 If you discover that FGM has taken place or a child is at risk of FGM: Keeping Children Safe in Education explains that FGM comprises “all procedures involving partial or total removal of the external female genitalia, or other injury to the female genital organs”. FGM is illegal in the UK and a form of child abuse with long-lasting, harmful consequences.

It is also known as ‘female genital cutting’, ‘circumcision’ or ‘initiation’. Possible indicators that a child has already been subjected to FGM, and factors that suggest a child may be at risk, are set out in appendix 4.

Any regulated health and social care professional or teacher who either:

• Is informed by a girl under 18 that an act of FGM has been carried out on her; or
• Observes physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth Must immediately report this to the police, personally. This is a mandatory statutory duty, and staff members will face disciplinary sanctions for failing to meet it.

Unless they have been specifically told not to disclose, they should also discuss the case with the DSL, report via WriteUpp and involve children’s social care as appropriate.

Any other member of staff who discovers that an act of FGM appears to have been carried out on a child under 18 must speak to the DSL and follow our local safeguarding procedures. The duty for health professionals mentioned above does not apply in cases where a child is at risk of FGM or FGM is suspected but is not known to have been carried out. Staff should not examine children.

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

Figure 1 below illustrates the procedure to follow if you have any concerns about a child’s welfare. Report via WriteUpp and where possible, speak to the DSL first to agree a course of action. If in exceptional circumstances the DSL or another member of the safeguarding team is not available, this should not delay appropriate action being taken.

Speak to a member of the senior leadership team and/or take advice from local authority children’s social care.

You can also seek advice at any time from the NSPCC helpline on 0808 800 5000.

Share details of any actions you take with the DSL as soon as practically possible.

Make a referral to local authority children’s social care directly, if appropriate (see ‘Referral’ below).

Share any action taken with the DSL as soon as possible.

Early help

If early help is appropriate, the DSL will generally lead on liaising with other agencies and setting up an inter-agency assessment as appropriate. Staff may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead practitioner. We will discuss and agree, with statutory safeguarding partners, levels for the different types of assessment, as part of local arrangements.

The DSL will keep the case under constant review and the site will consider a referral to local authority children’s social care if the situation does not seem to be improving. Timelines of interventions will be monitored and reviewed. Any local procedures for early help can be found in section 18 Referral.

The DSL will make a referral where appropriate. If the DSL or a member of the safeguarding team is unavailable, you should refer the case to local authority children’s social care or the police. If you make a referral directly (see section 7.1), you must tell the DSL as soon as possible.

The local authority will make a decision within 1 working day of a referral about what course of action to take and will let the person who made the referral know the outcome. The DSL or person who made the referral must follow up with the local authority if this information is not made available, and ensure outcomes are properly recorded. If the child’s situation does not seem to be improving after the referral, the DSL or person who made the referral must follow local escalation procedures to ensure their concerns have been addressed and that the child’s situation improves. Local procedures for referral and escalation can be found in section 18.

If a child is not suffering or likely to suffer from harm, or in immediate danger, Report via WriteUpp and where possible speak to the DSL first to agree a course of action. If in exceptional circumstances the DSL is not available, this should not delay appropriate action being taken. Speak to a member of the senior leadership team and/or seek advice from local authority children’s social care. Make a referral to local authority children’s social care directly, if appropriate (see ‘Referral’ above). Inform the DSL or deputy as soon as practically possible after the referral.

8.5 If you have concerns about extremism

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

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

Where there is a concern, the DSL will consider the level of risk and decide which agency to make a referral to. This could include Channel, the government’s programme for identifying and supporting individuals at risk of being drawn into terrorism, or the local authority children’s social care team.

The Department for Education also has a dedicated telephone helpline, 020 7340 7264, which site staff and governors can call to raise concerns about extremism with respect to a child. You can also email counter.extremism@education.gov.uk. Note that this is not for use in emergency situations. In an emergency, call 999 or the confidential anti-terrorist hotline on 0800 789 321, If you think someone is in danger or you think someone may be planning to travel to join an extremist group, see or hear something that may be terrorist-related

 8.6 If you have a mental health concern

Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

Staff will be alert to behavioural signs that suggest a child may be experiencing a mental health problem or be at risk of developing one. If you have a mental health concern about a child that is also a safeguarding concern, take immediate action by following the steps in section 8.4.

If you have a mental health concern that is not also a safeguarding concern, speak to the DSL to agree a course of action who can refer to your site’s local arrangements for identifying and supporting individuals who may have possible mental health problems.

8.7 Concerns about a staff member, student, volunteer or contractor.

If you have any concerns about a member of staff (including a supply teacher, volunteer or contractor), or an allegation is made about a member of staff (including a supply teacher, volunteer or contractor) posing a risk of harm to children, speak to the company lead as soon as possible.

If the concerns/allegations are about the company lead, speak to the DSL. The Allegations Against Staff Policy (A142) gives more detail about concerning behaviours.

The company lead/ DSL will then follow the procedures set out in A142 Allegations Against Staff Policy, if appropriate. Where you believe there is a conflict of interest in reporting a concern or allegation about a member of staff (including a student, volunteer or contractor) internally, report it directly to the local authority designated officer (LADO). If there is any doubt as to whether a safeguarding concern around staff conduct meets the harm threshold the LADO should be consulted, this should be reported up to the company directors within 24 hours.

If the concern is about a member of school staff on a visit then the Powerful Voices employee will raise it with both the school safeguarding lead and the company lead.

8.8 Allegations of abuse made against other Clients/students/young people.

We recognise that children are capable of abusing their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up” as this can lead to a culture of unacceptable behaviours and an unsafe environment for children.

We also recognise the gendered nature of child-on-child abuse. However, all child-on-child abuse is unacceptable and will be taken seriously.

This might include where the alleged behaviour: Is serious, and potentially a criminal offence.

Could put children/young people in the care of the therapist at risk, Is violent,  Involves children/young people being forced to use drugs or alcohol,  Involves sexual exploitation, sexual abuse or sexual harassment, such as indecent exposure, sexual assault, upskirting or sexually inappropriate pictures or videos (including the sharing of nudes and seminudes) See Appendix 2 for more information about child-on-child abuse.

Procedures for dealing with allegations of child-on-child abuse:

You must record the allegation on WriteUpp and tell the DSL, but do not investigate it.

The DSL will contact the local authority children’s social care team and follow its advice, as well as the police if the allegation involves a potential criminal offence.

The DSL will put a risk assessment and support plan into place for all children involved (including the victim(s), the child(ren) against whom the allegation has been made and any others affected) with a named person they can talk to if needed.

The DSL will contact the children and adolescent mental health services (CAMHS), if appropriate If the incident is a criminal offence and there are delays in the criminal process, the DSL will work closely with the police (and other agencies as required) while protecting children and/or taking any disciplinary measures against the alleged perpetrator. We will ask the police if we have any questions about the investigation.

Creating a supportive environment and minimising the risk of child-on-child abuse

We recognise the importance of taking proactive action to minimise the risk of child-on-child abuse, and of creating a supportive environment where victims feel confident in reporting incidents.

To achieve this, we will: Challenge any form of derogatory or sexualised language or inappropriate behaviour between peers, including requesting or sending sexual images Be vigilant to issues that particularly affect different genders – for example, sexualised or aggressive touching or grabbing towards female Clients, and initiation or hazing type violence with respect to boys.

Ensure our therapy helps to educate children about appropriate behaviour and consent. Be alert to reports of sexual violence and/or harassment that may point to environmental or systemic problems that could be addressed by updating policies, processes and the curriculum, or could reflect wider issues in the local area that should be shared with safeguarding partners.

• Support children who have witnessed sexual violence, especially rape or assault by penetration. We will do all we can to make sure the victim, alleged perpetrator(s) and any witnesses are not bullied or harassed
• Consider inter familial harms and any necessary support for siblings following a report of sexual violence and/or harassment Ensure children are able to easily and confidently report abuse using our reporting systems (as described in section 8.10 below).
• Ensure staff reassure victims that they are being taken seriously.

Ensure staff are trained to understand:

• How to recognise the indicators and signs of child-on-child abuse, and know how to identify it and respond to reports
• That even if there are no reports of child-on-child abuse, it does not mean it is not happening – staff should maintain an attitude of “it could happen here”
• That if they have any concerns about a child’s welfare, they should act on them immediately rather than wait to be told, and that victims may not always make a direct report. For example: ▪ Children can show signs or act in ways they hope adults will notice and react to
• ▪ A friend may make a report
• A member of staff may overhear a conversation
• A child’s behaviour might indicate that something is wrong
• That certain children may face additional barriers to telling someone because of their vulnerability, disability, gender, ethnicity and/or sexual orientation
• That a child harming a peer could be a sign that the child is being abused themselves, and that this would fall under the scope of this policy
• The important role they have to play in preventing child-on-child abuse and responding where they believe a child may be at risk from it
• That they should speak to the DSL if they have any concerns
• That social media is likely to play a role in the fall-out from any incident or alleged incident, including for potential contact between the victim, alleged perpetrator(s) and friends from either side The DSL will take the lead role in any disciplining of the alleged perpetrator(s). We will provide support at the same time as taking any disciplinary action. Disciplinary action can be taken while other investigations are going on, e.g. by the police. The fact that another body is investigating or has investigated an incident doesn’t (in itself) prevent our company from coming to its own conclusion about what happened and imposing a penalty accordingly.
• We will consider these matters on a case-by-case basis, taking into account whether: Taking action would prejudice an investigation and/or subsequent prosecution – we will liaise with the police and/or LA children’s social care to determine this.
• There are circumstances that make it unreasonable or irrational for us to reach our own view about what happened while an independent investigation is ongoing.

If these incidents occur within a school environment, then the school safeguarding policy will be followed as well as the company’s and the school safeguarding lead will be informed. Powerful Voices DSL will then communicate directly with the school DSL to manage the case as deemed necessary. IF the company DSL and School DSL can not agree on a path of action, then the local safeguarding team will be contacted for advice.

8.9 Sharing of nudes and semi-nudes (‘sexting’):

Powerful Voices Ltd bases its policy on guidance from the UK Council for Internet Safety for all staff and for DSLs and senior leaders. Your responsibilities when responding to an incident: If you are made aware of an incident involving the consensual or non-consensual sharing of nude or semi-nude images/videos (also known as ‘sexting’ or ‘youth produced sexual imagery’), you must report it to the DSL immediately and record this on WriteUpp.

You must not:

• View, copy, print, share, store or save the imagery yourself, or ask a Client to share or download it (if you have already viewed the imagery by accident, you must report this to the DSL).
• Delete the imagery or ask the Client to delete it.
• Ask the Client(s) who are involved in the incident to disclose information regarding the imagery (this is the DSL’s responsibility).
• Share information about the incident with other members of staff, the Client(s) it involves or their, or other, parents and/or carers.
• Say or do anything to blame or shame any young people involved.
• You should explain that you need to report the incident and reassure the Client(s) that they will receive support and help from the DSL.

Initial review meeting:

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

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

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

• The incident involves an adult.
• There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs).
• What the DSL knows about the images or videos suggests the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent.
• The imagery involves sexual acts and any Client in the images or videos is under 13.
• The DSL has reason to believe a Client is at immediate risk of harm owing to the sharing of nudes and semi-nudes (for example, the young person is presenting as suicidal or self-harming).
• If none of the above apply then the DSL, in consultation with the company head and if in education the settings DSL and other members of staff as appropriate, may decide to respond to the incident without involving the police or children’s social care. The decision will be made and recorded in line with the procedures set out in this policy.

Further review by the DSL:

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

They will hold interviews with the children/young people involved (if appropriate). If at any point in the process there is a concern that a child/young person has been harmed or is at risk of harm, a referral will be made to children’s social care and/or the police immediately.

If the child is an education setting the company DSL will work with the setting DSL on this part of the policy.

Informing parents/carers:

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

Referring to the police:

If it is necessary to refer an incident to the police, this will be done through by following local procedures in section 18.

Recording incidents

All incidents of sharing of nudes and semi-nudes, and the decisions made in responding to them, will be recorded. The record-keeping arrangements set out in section 15 of this policy also apply to recording these incidents.

8.10 Reporting systems for our children

Where there is a safeguarding concern, we will take the child’s wishes and feelings into account when determining what action to take and what services to provide. We recognise the importance of ensuring children feel safe and comfortable to come forward and report any concerns and/or allegations.

To achieve this, we will:

• Put systems in place for children to confidently report abuse
• Ensure our reporting systems are well promoted, easily understood and easily accessible for children
• Make it clear to children that their concerns will be taken seriously, and that they can safely express their views and give feedback

See local procedures in section 18 for specific site support

Online safety and the use of mobile

We recognise the importance of safeguarding children from potentially harmful and inappropriate online material, and we understand that technology is a significant component in many safeguarding and wellbeing issues. To address this, we aim to: Have robust processes in place to ensure the online safety of children, staff, volunteers and visitors.

Protect and educate the Powerful Voices Ltd community in its safe and responsible use of technology, including mobile and smart technology (which we refer to as ‘mobile phones’) Set clear guidelines for the use of mobile phones for the whole Powerful Voices Ltd community Establish clear mechanisms to identify, intervene in and escalate any incidents or concerns, where appropriate.

The 4 key categories of risk

Our approach to online safety is based on addressing the following categories of risk:

• Content – being exposed to illegal, inappropriate or harmful content, such as pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism.
• Contact – being subjected to harmful online interaction with other users, such as child-on-child pressure, commercial advertising and 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, such as making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and seminudes and/or pornography), sharing other explicit images and online bullying; and Commerce – risks such as online gambling, inappropriate advertising, phishing and/or financial scams

To meet our aims and address the risks above we will:

Use therapy to support children to be able to access information about online safety as part of our curriculum. For example:

• The safe use of social media, the internet and technology
• Keeping personal information private
• How to recognise unacceptable behaviour online
• How to report any incidents of cyber-bullying, ensuring Clients are encouraged to do so, including where they are a witness rather than a victim.

Train staff, as part of their induction, on safe internet use and online safeguarding issues including cyber-bullying and the risks of online radicalisation

All staff members will receive refresher training at least once each academic year.

Educate parents/carers about online safety via our website, communications sent directly to them and during parents’ evenings.

We will also share clear procedures with them so they know how to raise concerns about online safety.

Make sure staff are aware of any restrictions placed on them with regards to the use of their mobile phone and cameras, for example that:

• Staff are allowed to bring their personal phones to work for their own use, but will limit such use to non-contact time when clients are not present
• Staff will not take pictures or recordings of Clients on their personal phones or cameras.

Make all children, parents/carers, staff and volunteers aware that they are expected to sign an agreement regarding the acceptable use of the internet, use of Powerful Voices Ltd’s ICT systems and use of their mobile and smart technology.

Explain the sanctions we will use if a child is in breach of our policies on the acceptable use of the internet and mobile phones.

Make sure all staff, Clients and parents/carers are aware that staff have the power to search children’s’ phones, as set out in the DfE’s guidance on searching, screening and confiscation. If this in an education setting the school DSL should be alerted and present when the phone is looked at.

Put in place robust filtering and monitoring systems to limit children’s exposure to the 4 key categories of risk (described above) from Powerful Voices Ltd’s IT systems.

Carry out an annual review of our approach to online safety, supported by an annual risk assessment that considers and reflects the risks faced by the Powerful Voices Ltd community.

Notifying parents or carers

Where appropriate, we will discuss any concerns about a child with the child’s parents or carers. The DSL will normally do this in the event of a suspicion or disclosure. Other staff will only talk to parents or carers about any such concerns following consultation with the DSL.

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

In the case of allegations of abuse made against other children, we will normally notify the parents or carers of all the children involved. We will think carefully about what information we provide about the other child involved, and when.

We will work with the police and/or local authority children’s social care to make sure our approach to information sharing is consistent.

The DSL will, along with any relevant agencies (this will be decided on a case-by-case basis):

• Meet with the victim’s parents or carers, with the victim, to discuss what’s being put in place to safeguard them, and understand their wishes in terms of what support they may need and how the report will be progressed
• Meet with the alleged perpetrator’s parents or carers to discuss support for them, and what’s being put in place that will impact them, e.g. moving them out of classes/groups with the victim, and the reason(s) behind any decision(s)

Children with special educational needs, disabilities or health issues.

We recognise that children with special educational needs (SEN) or disabilities or certain health conditions can face additional safeguarding challenges, and are 3 times more likely to be abused than their peers.

Additional barriers can exist when recognising abuse and neglect in this group, including:

• Assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child’s condition without further exploration
• Children being more prone to peer group isolation or bullying (including prejudice-based bullying) than other Clients
• The potential for children with SEN, disabilities or certain health conditions being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs
• Communication barriers and difficulties in managing or reporting these challenge

Children and young people with a social worker

Children and young people may need a social worker due to safeguarding or welfare needs. We recognise that a child’s experiences of adversity and trauma can leave them vulnerable to further harm as well as potentially creating barriers to engagement, attendance to education, learning, behaviour and mental health.

The DSL and all members of staff will work with and support social workers to help protect vulnerable children. Where we are aware that a child/young person has a social worker, the DSL will always consider this fact to ensure any decisions are made in the best interests of the child’s safety, welfare, care and educational outcomes. For example, it will inform decisions about: Responding to unauthorised absence or missing education where there are known safeguarding risks.

Looked-after and previously looked-after children.

We will ensure that staff have the skills, knowledge and understanding to keep looked-after children and previously looked-after children safe. In particular, we will ensure that:

• Appropriate staff have relevant information about children’s looked after legal status, contact arrangements with birth parents or those with parental responsibility, and care arrangements.
• The DSL has details of children’s social workers and relevant virtual school heads.
• We have appointed an appropriately trained teacher, to take the lead on promoting the educational achievement of looked-after and previously looked-after children.

As part of their role, they will: Work closely with the DSL to ensure that any safeguarding concerns regarding looked-after and previously looked-after children are quickly and effectively responded to.

Complaints and concerns about Companies safeguarding policies

14.1 Complaints against staff

Complaints against staff that are likely to require a child protection investigation will be handled in accordance with our procedures for dealing with allegations of abuse made against staff (see PV142 Allegations of Abuse Against staff Policy).

This update to the existing section now clarifies that staff should follow school’s and the company’schild  safeguarding policies and procedures, in the event of an allegation regarding an “incident that happened when an individual or an organisation was using their school premises for the purposes of running activities for children.” This includes events such as community groups, sports associations, and more.

It also specifies that records should be “retained at least until the accused has reached normal pension age or for a period of 10 years from the date of the allegation if that is longer.”

14.2 Other complaints

Other complaints will be handled in accordance with Powerful Voices Ltd’s Complaints Policy

14.3 Whistle-blowing

Staff are able to refer to Powerful Voices Ltd’s Whistleblowing policy. (In staff handbook)

General guidance on whistleblowing can be found at: Advice on whistleblowing https://www.gov.uk/whistleblowing. The NSPCC whistleblowing helpline is also available for staff who do not feel able to raise concerns regarding child protection failures internally.

Staff can call: 0800 028 0285. The line is available from 8:00 AM to 8:00 PM, Monday to Friday and Email: help@nspcc.org.uk.

Record-keeping

We will hold records in line with our records retention schedule and the clinical guidance on medical notes.

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

Records will include:

• A clear and comprehensive summary of the concern
• Details of how the concern was followed up and resolved
• A note of any action taken, decisions reached and the outcome
• The rationale for closing the case
• Non-confidential records will be easily accessible and available.
• Confidential information and records will be held securely and only available to those who have a right or professional need to see them.
• Safeguarding records relating to individual children will be retained for a reasonable period of time after they have left the school/college/home.
• Safeguarding records which contain information about allegations of sexual abuse will be retained for the Independent Inquiry into Child Sexual Abuse (IICSA), for the term of the inquiry.

The WriteUpp system in a cloud based medical note system has security assurances built in and access is secured by password.

The DSL shares information with other agencies verbally or by encrypted email when this is appropriate.

Training

16.1 All staff members will undertake safeguarding and child protection training at induction, including on whistle-blowing procedures and online safety, to ensure they understand the site’s safeguarding systems and their responsibilities, and can identify signs of possible abuse or neglect.

This training will be annually updated and will: Be integrated, aligned, and considered as part of the Powerful Voices Ltd-wide.

The training will be in line with advice from the 3 safeguarding partners, and have regard to the HCPC Standards to support the expectation that all health care professionals:

• Manage behaviour effectively to ensure a good and safe environment
• Have a clear understanding of the needs of all children.

All staff will have training on the government’s anti-radicalisation strategy, ‘Prevent’ to enable them to identify children at risk of being drawn into terrorism and to challenge extremist ideas.

Staff will also receive regular safeguarding and child protection updates, including on online safety, as required but at least annually (for example, through emails and staff meetings). Contractors who are provided through an associate contract or similar contract will also receive safeguarding training.

Volunteers will receive appropriate training, if applicable.

16.2 The DSL and deputies

The DSL and deputies will undertake level 3 child protection and safeguarding training at least every 2 years. In addition, they will update their knowledge and skills at regular intervals and at least annually (for example, through e-bulletins, meeting other DSLs, or taking time to read and digest safeguarding developments).

Appendices

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

Appendix 1: types of abuse

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

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

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

Emotional abuse may involve:

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

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

• Physical contact, including as sault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.
• Non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet).

Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

With some name changes to contact titles (such as change from ‘Child Exploitation and Online Protection’ – or CEOP – to ‘National Crime Agency’s CEOP Safety Centre’), changes were made to policies to align them with the Department for Education’s ‘behaviour in schools’ guidance and statutory guidance titled ‘School suspensions and permanent exclusions’. There are also additions for relevant new guidance that has been published throughout the year, such as guidance on digital and technology standards and keeping children safe in out-of-school settings.

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.

Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

• Provide adequate food, clothing and shelter (including exclusion from home or abandonment)
• Protect a child from physical and emotional harm or danger
• Ensure adequate supervision (including the use of inadequate care-givers)
• Ensure access to appropriate medical care or treatment
• It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Appendix 2: Specific safeguarding issues

Please see section 18 where our local procedures highlight the issues below which have been risk assessed as most relevant to our service and any specific local support and procedures which apply.

Children missing from education or care

A child going missing from education or care, particularly repeatedly, can be a warning sign of a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation, or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage. There are many circumstances where a child may become missing from education, but some children are particularly at risk.

These include children who:

• Are at risk of harm or neglect
• Are at risk of forced marriage or FGM
• Come from Gypsy, Roma, or Traveller families
• Come from the families of service personnel
• Go missing or run away from home or care
• Are supervised by the youth justice system
• Cease to attend a school
• Come from new migrant families

We will follow our procedures for unauthorised ‘do not attends’ to appointments and for dealing with children who go missing from education or care, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual exploitation, and to help prevent the risks of going missing in future. This includes informing the local authority if a child leaves the school without a new school being named, and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points.

Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being missing, such as travelling to conflict zones, FGM and forced marriage. If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries

We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger.

Child criminal exploitation

Child criminal exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity, in exchange for something the victim needs or wants, and/or for the financial or other advantage of the perpetrator or facilitator, and/or through violence or the threat of violence. The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse. The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. For example, young people may be forced to work in cannabis factories, coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.

Indicators of CCE can include a child:

• Appearing with unexplained gifts or new possessions
• Associating with other young people involved in exploitation
• Suffering from changes in emotional wellbeing
• Misusing drugs and alcohol
• Going missing for periods of time or regularly coming home late
• Regularly missing school or education
• Not taking part in education

If a member of staff suspects CCE, they will discuss this with the DSL.

The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate. If the child is in an education setting the DSL will contact the education settings DSL at first instance unless the child is deemed at immediate risk of harm.

Child-on-child abuse

Child-on-child abuse is when children abuse other children. This type of abuse can take place inside and outside of school and online. It can also take place both face-to-face and online, and can occur simultaneously between the 2.

Powerful Voices Ltd has a zero-tolerance approach to sexual violence and sexual harassment. We recognise that even if there are there no reports, that doesn’t mean that this kind of abuse isn’t happening.

Child-on-child abuse is most likely to include, but may not be limited to:

• Bullying (including cyber-bullying, prejudice-based and discriminatory bullying)
• Abuse in intimate personal relationships between children (this is sometimes known as ‘teenage relationship abuse’)
• Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)
• Sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence)
• Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse
• Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party • Consensual and non-consensual sharing of nudes and semi nudes images and/or videos (also known as sexting or youth produced sexual imagery)
• Upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm
• Initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

Where children abuse their peers online, this can take the form of, for example, abusive, harassing, and misogynistic messages; the non-consensual sharing of indecent images, especially around chat groups; and the sharing of abusive images and pornography, to those who don’t want to receive such content.

If staff have any concerns about child-on-child abuse, or a child makes a report to them, they will follow the procedures set out in this policy, as appropriate. When considering instances of harmful sexual behaviour between children, we will consider their ages and stages of development. We recognise that children displaying harmful sexual behaviour have often experienced their own abuse and trauma, and will offer them appropriate support.

Domestic abuse

Children can witness and be adversely affected by domestic abuse and/or violence at home where it occurs between family members. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse (abuse in intimate personal relationships between children) and child/adolescent to parent violence and abuse.

It can be physical, sexual, financial, psychological or emotional. It can also include ill treatment that isn’t physical, as well as witnessing the ill treatment of others – for example, the impact of all forms of domestic abuse on children. Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home.

Children who witness domestic abuse are also victims.

Older children may also experience and/or be the perpetrators of domestic abuse and/or violence in their own personal relationships.

This can include sexual harassment.

Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children and affect their health, wellbeing, development and ability to learn.

Older children may also experience and/or be the perpetrators of domestic abuse and/or violence in their own personal relationships. This can include sexual harassment.

Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children and affect their health, wellbeing, development and ability to learn.

So-called ‘honour-based’ abuse (including FGM and forced marriage)

So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes committed to protect or defend the honour of the family and/or community, including FGM, forced marriage, and practices such as breast ironing.

Abuse committed in this context often involves a wider network of family or community pressure and can include multiple perpetrators. All forms of HBA are abuse and will be handled and escalated as such. All staff will be alert to the possibility of a child being at risk of HBA or already having suffered it. If staff have a concern, they will speak to the DSL, who will activate local safeguarding procedures. FGM The DSL will make sure that staff have access to appropriate training to equip them to be alert to children affected by FGM or at risk of FGM.

Section 8.3 of this policy sets out the procedures to be followed if a staff member discovers that an act of FGM appears to have been carried out or suspects that a Client is at risk of FGM. Indicators that FGM has already occurred include:

• A child confiding in a professional that FGM has taken place
• A mother/family member disclosing that FGM has been carried out

A family/child already being known to social services in relation to other safeguarding issues

• A girl: Having difficulty walking, sitting or standing, or looking uncomfortable
• Finding it hard to sit still for long periods of time (where this was not a problem previously)
• Spending longer than normal in the bathroom or toilet due to difficulties urinating
• Having frequent urinary, menstrual or stomach problems
• Avoiding physical exercise or missing PE
• Being repeatedly absent from school, or absent for a prolonged period
• Demonstrating increased emotional and psychological needs – for example, withdrawal or depression, or significant change in behaviour
• Being reluctant to undergo any medical examinations
• Asking for help, but not being explicit about the problem
• Talking about pain or discomfort between her legs.

Potential signs that a Client may be at risk of FGM include:

• The girl’s family having a history of practising FGM (this is the biggest risk factor to consider)
• FGM being known to be practised in the girl’s community or country of origin
• A parent or family member expressing concern that FGM may be carried out • A family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues
• Having a mother, older sibling or cousin who has undergone FGM
• Having limited level of integration within UK society
• Confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”
• Talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents/carers stating that they or a relative will take the girl out of the country for a prolonged period
• Requesting help from a teacher or another adult because she is aware or suspects that she is at immediate risk of FGM
• Talking about FGM in conversation – for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)
• Being unexpectedly absent from school
• Having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication The above indicators and risk factors are not intended to be exhaustive.

Forced marriage

Forcing a person into marriage is a crime. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats, or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. Staff will receive training around forced marriage and the presenting symptoms. We are aware of the ‘one chance’ rule, i.e. we may only have one chance to speak to the potential victim and only one chance to save them. If a member of staff suspects that a Client is being forced into marriage, they will speak to the Client about their concerns in a secure and private place. They will then report this to the DSL.

The DSL will:

• Speak to the child about the concerns in a secure and private place
• Activate the local safeguarding procedures and refer the case to the local authority’s designated officer
• Seek advice from the Forced Marriage Unit on 020 7008 0151 or fmu@fco.gov.uk

Preventing radicalisation

Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.

Extremism is vocal or active opposition to fundamental British values, such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs. This also includes calling for the death of members of the armed forces

Terrorism is an action that:

• Endangers or causes serious violence to a person/people;
• Causes serious damage to property; or
• Seriously interferes or disrupts an electronic system The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.

We have a duty to prevent children from being drawn into terrorism. The DSL will undertake Prevent awareness training and make sure that staff have access to appropriate training to equip them to identify children at risk.

We will assess the risk of children in our care being drawn into terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.

We will ensure that suitable internet filtering is in place, and equip our children to stay safe online at school/college and at home. There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology.

Radicalisation can occur quickly or over a long period.

Staff will be alert to changes in clients’ behaviour.

The government website Educate Against Hate and charity NSPCC say that signs that a Client is being radicalised can include:

• Refusal to engage with, or becoming abusive to, peers who are different from themselves
• Becoming susceptible to conspiracy theories and feelings of persecution
• Changes in friendship groups and appearance
• Rejecting activities they used to enjoy
• Converting to a new religion
• Isolating themselves from family and friends
• Talking as if from a scripted speech
• An unwillingness or inability to discuss their views
• A sudden disrespectful attitude towards others
• Increased levels of anger
• Increased secretiveness, especially around internet
• Expressions of sympathy for extremist ideologies and groups, or justification of their actions
• Accessing extremist material online, including on Facebook or Twitter
• Possessing extremist literature
• Being in contact with extremist recruiters and joining, or seeking to join, extremist organisations Children who are at risk of radicalisation may have low self-esteem, or be victims of bullying or discrimination.

It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong. If staff are concerned about a child, they will follow our procedures set out in section 8.5 of this policy, including discussing their concerns with the DSL.

Staff should always take action if they are worried.

Local procedures.

All members of the Powerful Voices team including volunteers, students and contractors will be required to have both a child and adult enhanced DBS that will be placed on the update service and checked once a month by the DSL.

The company lead will allow the DSL assigned time to complete this check.

The team will carry their DBS’s on them at all times and alongside their photo ID badges will present them when requested.

For school contracts the health care professionals will work inside both the school and company safeguarding policy. Concerns will be raised with both DSL’s and notes will be kept on the WriteUpp system.

Any concerns will be recorded immediately either by hand (then scanned) or via WriteUpp.