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Child Protection Policy 2013 PDF
Child Protection Policy 2013 PDF
Aim:
To inform British Study Centres staff of their responsibilities when working with
children and vulnerable adults.
To ensure that all students aged under 18 are protected from potential abuse from
hosts, staff and other suppliers and fellow students.
To offer a variety of social activities of interest to the needs of younger students
To practice our commitment to safe recruitment, selection and vetting of staff,
accommodation providers and other suppliers.
To ensure that all members of staff are aware if any student is under 18 and that
staff are also aware of any consequent special procedure(s) which are applicable.
Applies to: British Study Centres staff, including students and volunteers, who work with
children and vulnerable adults
Background
Whilst there is currently no specific directive relating to private language schools, legal
opinion is that there are a number of statutory and other provisions relating to child
safeguarding that apply to private language schools, just as they would apply to other
education providers and to other organisations in general. Furthermore, obligations,
although not based in statute also affect private language schools as a result of common
law, e.g as a result of the contracts between student or parent and the college, or under the
law of negligence.
British Study Centres deem it prudent, and indeed best practice, to have detailed and
rigorous control measures in place to safeguard children and vulnerable adults.
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• The Children Act 1989 states the legal definition of a child is “a person under the age
of 18”.
• Section 115(4) of the Police Act 1997 states that a person can be considered to be
vulnerable if they are
“substantially dependent upon others in performing basic physical functions, or his
ability to communicate with those providing services, or to communicate with others, is
severely impaired, and, as a result, he would be incapable of protecting himself from
assault or other physical abuse, or there is a potential danger that his will or moral
well-being may be subverted or overpowered”.
N.B: on 1 December 2012 the Criminal Records Bureau (CRB) and Independent
Safeguarding Authority (ISA) merged to form the Disclosure and Barring Service (DBS).
British Study Centres takes the view that in the interests of good practice there should be a
clear policy and associated practices to guide work with under-18s and vulnerable adults.
Principles
British Study Centres believes that children/young people have rights as individuals and
should be treated with dignity and respect. British Study Centres will strive to provide a safe
environment for any young people (under 18) in its care while they are studying at British
Study Centres, visiting British Study Centres or participating in
British Study Centres activities.
• The welfare of young people and vulnerable adults is of primary concern
• All young people and vulnerable adults, whatever their age, culture, disability, gender,
language, racial origin, socio-economic status, religious belief and/or sexual identify have the
right to safeguarding from abuse
• It is everyone’s responsibility to report any concerns about abuse to the Designated
Safeguarding Officer, and the responsibility of the Social Services Department and the Police
to conduct, where appropriate a joint investigation
• All incidents of alleged poor practice, misconduct and abuse will be taken seriously and
responded to swiftly and appropriately
• All personal data will be processed in accordance with the requirements of the Data
Protection Act 1998.
Definition of Abuse
Abuse is any behaviour towards a person that deliberately or unknowingly causes harm,
endangers life or violates their rights. Abuse may be:
• Physical
• Sexual
• Psychological – repeatedly being made to feel unhappy, humiliated, afraid or devalued by
others
• Financial or material – stealing or denying access to money or possessions
• Neglect
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• Discriminatory – abuse motivated by discriminatory attitudes towards race, religion,
gender, disability or cultural background
Accommodation:
To visit and vet all applicants before accepting as a homestay. All members of the
family and any regular visitors to the household must be declared to the college on
the initial questionnaire.
To ensure that there is a bank of DBS-checked homestays that can be used for 16-17
year olds.
The main carer in each homestay must have a current and enhanced DBS disclosure.
To re-visit homestays who host 16-17 year olds annually.
To check host details and profile annually to ensure that details have not changed.
To ensure that all under-18s and their hosts follow the school’s agreed evening
curfew, 11pm Sunday – Thursday and 12pm on Friday & Saturday.
Homestays, which prove to be unsuitable for whatever reason, are to be removed
from the homestay register. Serious concerns will be immediately reported to the
local authorities.
To ensure that the main carer in homestays sign and return a copy of the Children’s
Act 1989 (Part 1X), declaring any convictions or offences against children on behalf
of all other adults in the home.
To ensure that the main carer in homestays receiving under 18 students has a
current and enhanced DBS disclosure.
To ensure that students’ parents or guardians provide written consent for activities
outside of the agreed curfew. The school has the right to amend or refuse such
requests in accordance with school policy, ISI and British Council guidelines.
To offer only homestay half or full board homestay accommodation to under 18 year
olds to ensure that they are not forced to eat take-away or cook for themselves in
the evenings.
To ensure that residential accommodation (including student houses) is not made
available to under-18s.
Administration:
To ensure that all under 18s are marked with an asterisk on class registers and all
teachers are instructed to inform the course manager immediately of any absences.
To meet with 16-17 year-old students during their first week for an interview to
check that they are happy and safe
Staff/Students:
All British Study Centres staff and students are required to take shared responsibility
for the safeguarding and safety of any young people and vulnerable adults in school.
They must be aware of and abide by the British Study Centres Safeguarding Children
and Vulnerable Adults Policy. Staff are in a position of trust, in particular those staff
who teach, support, guide or in any way interact with students, young people and
vulnerable adults visiting the school.
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To ensure that all existing and new staff including all unpaid interns sign and return
a copy of the Children’s Act 1989 (Part 1X), declaring any convictions of offences
against children.
To ensure that all staff have a current and enhanced DBS disclosure.
Social Programme:
The managerial responsibility for any programme or activity rests with, firstly, the Social
Programme Coordinator and secondly the individual who is directing or organising the
activity. Staff are expected:
To ensure that the activity is planned, organised and delivered in accordance with
the Safeguarding Children and Vulnerable Adults Policy.
To arrange the checking, training, induction and guidance for all staff and
volunteers.
To inform the British Study Centres Designated Safeguarding Officer and complete
the appropriate documentation if any under 18s are involved in their activity.
To complete a health and safety risk assessment for each activity.
To ensure that there is a variety of social programme activities suitable for under 18
year olds. Please see the ‘Under-18s Club’ detailed above.
To ensure that students are familiar with 24 hour emergency telephone number,
and that they feel happy to be able to call this number at any time.
To take all allegations of abuse seriously and to respond appropriately.
To ensure that all suppliers (taxi drivers, excursion company staff) who have regulated
activity with under-18’s have also signed disclaimer forms with their employers.
The School Director has responsibility for the oversight of the College’s Safeguarding
Children and Vulnerable Adults Policy with delegated responsibility to relevant members of
the Management Team.
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The School Director has nominated the Accommodation Manager as the senior member of
staff responsible for child and vulnerable adult safeguarding issues within the school (the
Child and Vulnerable Adult Safeguarding Officer (CVAO)) and they will liaise directly with the
School Director as deemed necessary.
British Study Centres expects anyone who comes into the school building or into school-
managed student houses to adhere to the school’s Safeguarding Children and Vulnerable
Adults Policy. All visitors on signing in at school will confirm that the policy has been made
available to them to see.
All British Study Centres staff are in a position of trust, in particular those staff who teach,
support, guide or in any way interact with students, children and vulnerable adults. It is
incumbent all staff to be aware of this and to act accordingly at all times.
British Study Centres already has processes in place to check the suitability of staff working
directly with children and young people. British Study Centres is committed to ensuring that
all such staff have a satisfactory current and enhanced Disclosure and Barring Service (DBS)
check.
British Study Centres has a rigorous recruitment process that includes safeguarding
measures to ensure that candidates have been suitably vetted.
See Appendix D Recruitment Policy
British Study Centres will additionally ensure that all homestay providers who are in regular
or significant occasional contact with under-18s or vulnerable adults must have had a
satisfactory enhanced DBS check undertaken by British Study Centres before allowing them
to work with children or vulnerable adults.
A ‘satisfactory’ check is defined as having no criminal convictions (including cautions,
reprimands and final warnings) relevant to the post. Should the school be informed of a
previous conviction which does not indicate a direct threat to the safety of the students, BSC
will interview the homestay provider or staff member to garner more information.
British Study Centres will consider any convictions which have been recorded in terms of the
following:
If the CVAO or School Director consider that there is no threat, a rationale will be provided
and kept on file stating the reasons.
All staff or host families still employed to look after children must report any subsequent
criminal convictions to the School Director. Failure to do so will result in disciplinary action
being taken.
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All staff are responsible for making British Study Centres a safe and caring environment for
all including young people and vulnerable adults.
• in which the health, safety and welfare of young people has been assessed and catered
for.
• in which staff are alive to the possibility of abuse and take measures to prevent that
possibility.
• where there is a sound and known reporting system for any incident
• where staff take reasonable and practical precautions to avoid any suspicions of abuse
being brought against them.
Where under-18s are concerned there are statutory responsibilities for any organisation to
follow regarding the safety of young people.
British Study Centres has a Designated Safeguarding Officer to be the lead person with
regard to child safeguarding issues. At British Study Centres the Designated Safeguarding
Officer is the Under 18s club organiser.
All school staff must contact the Designated Safeguarding Officer or the School Director if
they have any cause to believe the student or young person involved in any activity in British
Study Centres, covered by this policy is in any way at risk. The Designated Safeguarding
Officer will follow the relevant procedures.
Records will be kept of all such incidents and their outcomes and held by the Designated
Safeguarding Officer in accordance with the Data Protection Act.
All staff should be aware that in accordance with statutory requirements where child
safeguarding issues are involved, it is not possible to offer confidentiality to a person under
18 as any disclosures must be reported.
Vulnerable Adults
Where possible British Study Centres will identify vulnerable adults and ensure that there
are appropriate support measures in place. This is most likely to be when the student
presents to, or is referred to, Student Services and clearly has mental health difficulties or a
disability that puts them into the legal definition of ‘vulnerable’.
Any member of staff across British Study Centres with concerns regarding an adult student
whom they believe or know to be vulnerable must contact the Designated Safeguarding
Officer.
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• To receive information about events that are planned in British Study Centres that may
involve young people or vulnerable adults, and plans that indicate how safeguarding will be
covered.
• To receive information from any staff, volunteers, children, parents or carers who have
child safeguarding concerns and record it.
• To assess the information promptly and carefully, clarifying and obtaining more
information about the matter as appropriate
• To consult initially with a statutory child safeguarding agency to test out any doubts or
uncertainty
• To make a formal referral to a statutory child safeguarding agency or the police
• To record statements from any member of staff who feels that a young person has
indulged in inappropriate behaviour or made sexually suggestive comments or approaches.
All members of staff working closely with children have to be alert to possibilities of abuse
and any concerns about the behaviour of any adult with respect to that child should be
reported to the Designated Safeguarding Officer who will decide what further action to take.
It is the duty of staff to inform only not to investigate – this is the role of the Police and
Social Services.
If staff, in the course of their work at British Study Centres, have a child safeguarding issue
brought to their notice, this must be treated as a priority over all other work.
Guidance with regard to a specific incident may be obtained from the Designated
Safeguarding Officer.
An oral, and then written report should be provided to the Designated Safeguarding Officer
who will keep a confidential record of any such incidents.
Allegations involving a member of staff and a person under-18 or a vulnerable adult should
be reported to the School Director and to the Designated Safeguarding Officer.
Consideration will be given as to whether the situation falls within the definition of abuse.
Training
In accordance with good practice British Study Centres will ensure that the Designated
Safeguarding Officer, officers deputed to act on their behalf and other staff likely to be in
regular contact with under-18s and vulnerable adults receive appropriate training provided
within our sector.
British Study Centres will also provide information to raise awareness to ensure that all staff
understands what to do if a student or visitor covered by this policy discloses abuse or any
other safeguarding issue.
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It should be noted that whilst a young person can consent to sexual activity once they reach
the age of 16, the Sexual Offences (Amendment) Act 2000 makes it a criminal offence for a
person to engage in any kind of sexual activity with a person under 18 where the adult is in a
position of trust.
Media Relations
For any British Study Centres activity involving young people, parents or guardians must be
given the opportunity to refuse permission for photographs, videos or other images to be
made of their children and for the children to be interviewed by press, broadcasters or other
media.
All users of British Study Centres must be made aware of Health and Safety requirements
and be prepared to abide by them.
All staff must be familiar with British Study Centres’ Code of Practice for Staff attached as
Appendix A
All staff must be familiar with British Study Centres’ Code of Behaviour attached as Appendix
B.
Data Safeguarding
It should be noted that although technically a “child”, consent is still required from young
people in the same way as for an adult with regard to matters of data protection.
Review
• In accordance with changes in legislation and guidance on the safeguarding of children and
vulnerable adults or any changes within British Study Centres
• Following any issues or concerns raised about the safeguarding of children or vulnerable
adults within British Study Centres • In all other circumstances, at least annually.
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SAFEGUARDING CHILDREN AND VULNERABLE ADULTS POLICY Appendix A
CODE OF GOOD PRACTICE FOR STAFF, STUDENTS and VOLUNTEERS
The following guidelines are intended to be a common sense approach that both reduce
opportunities for the abuse of young people and vulnerable adults and help to protect staff,
students and volunteers from any false allegation.
You SHOULD:
• Treat all young people and vulnerable with respect and respect their right to personal
privacy
• Ensure that, whenever possible, there is more than one adult present during activities or
that you are within sight or hearing of others
• Exercise caution when discussing sensitive issues with children or vulnerable adults
• Exercise caution in initiating any physical contact with a young person or vulnerable adults
• Operate within the guidance offered by this Code
• Challenge all unacceptable behaviour and report all allegations or suspicions of abuse
• Spend excessive time alone with young people or vulnerable adults away from others
• Take young people or vulnerable adults alone in a car journey, however short
• Take young people or vulnerable adults to your home
• Engage in physical or sexually provocative games including horseplay
• Allow or engage in inappropriate touching of any form
• Make over-familiar or sexually suggestive comments or approaches to a young person or
vulnerable adult even as a ‘joke’
• Let allegations, over familiar or sexually suggestive comments or approaches made by a
young person or vulnerable adult go unchallenged or unrecorded.
• Do things of a personal nature that young people or vulnerable adults can do for
themselves.
• Take photographs, videos or other images of a young person without the express
permission of their parents
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SAFEGUARDING CHILDREN AND VULNERABLE ADULTS POLICY Appendix B
CODE OF BEHAVIOUR FOR YOUNG PEOPLE AND VULNERABLE ADULTS
British Study Centres is a language school for the education of students, including children
aged under 18. All people visiting British Study Centres, either privately or with an organised
group, are expected to respect British Study Centres, its staff, students and its buildings and
grounds.
British Study Centres seeks to offer visitors a safe and caring environment.
In return, you must:
• Respect the rights and dignity of each other and of the staff and other helpers
• Respect the rules of British Study Centres which include:
• Purchase, sale and consumption of alcohol, recreational/nontherapeutic drugs and
substances for abuse is forbidden
• Smoking is banned in all buildings at British Study Centres and is only allowed
within outdoor areas specifically designed for this practice.
• All rules and safety/emergency procedures such as fire drills must be followed
• Participants in organised events are expected to attend all timetabled activities
unless they have been granted specific leave of absence.
• Inappropriate physical intimacy among participants is not permitted
• Serious incidents of misbehaviour such as fighting, racial/sexual abuse, damage to
property, indecent language and failure to obey instructions will normally lead to
expulsion from the activity and British Study Centres
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SAFEGUARDING CHILDREN AND VULNERABLE ADULTS POLICY Appendix C
RECOGNISING ABUSE
Sexual abusers:
- Some arrive in a job with a pre-meditated desire to abuse children; others develop it while
in the job. Therefore safer recruitment alone is not enough to provide adequate
safeguarding for children.
Physical abusers:
- Are not usually pre-meditated (unless sadists) but are usually reactive abusers.
- They typically lack self-restraint and don’t have appropriate strategies for managing
conflict and/or difficult children
Emotional abusers:
- All sexual abusers are emotional abusers
- Other forms of emotional abuse include failing to provide support to children needing it,
and through constantly directing negative attention to a particular child.
- Bullying is the classic form of emotional abuse
- Therefore, to be checked at interview
* applicant's attitude to staff responsibilities in protecting children
* applicant's attitudes to using positive reinforcement
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SAFEGUARDING CHILDREN AND VULNERABLE ADULTS POLICY Appendix D:
RECRUITMENT & INDUCTION POLICY
Procedures
1) All posts will be advertised both within the company as well as externally.
2) All job advertisements will comprise a short job description and refer enquirers to the
job page of the company website. The website will detail where to send a covering letter
and CV and a full job description will be available to download. All applicants will be sent
a copy of the school’s Safeguarding Children and Vulnerable Adults policy as part of the
application process.
3) The job page of the website will have the following information for all potential
applicants to read:
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a sound relationship with pupils, earning their respect and trust but maintaining
proper professional boundaries………( by not deliberately courting popularity or
friendship.)
All employees will be expected to undergo an enhanced Criminal Records Bureau
check and should be reminded that providing any false information is a criminal
offence.
4) Interviewing should be done by those with training and/or experience in this area as far
as is possible. Whenever possible 2 staff members will conduct interviews. All
interviews for candidates who will be working with children to be carried out face to
face.
5) Questions asked during the interview should be relevant to the job description.
Interviews must include questions that probe candidate's attitudes to safeguarding
children.
6) Applicants to be given a tour of the building. The person carrying out the tour will be
asked for their opinion on the applicant and this view will also be considered by the
interviewing panel in making their decisions. A cover sheet for interview appraisal to be
completed and attached to the applications.
7) Attention should be paid at all times to the equal opportunity policy as outlined in the
Employee’s Handbook. This states:
“We maintain a positive and proactive attitude to issues of equality in the workplace. You
will not be treated any more or less favourably in terms of access to opportunities regardless
of sex, sexual orientation, age (if under the age of retirement), race, colour, religion etc..”
The equal opportunities policy is not simply contractual but is seen as integral to the
culture of the organisation. All interviewing staff must be aware of this policy.
8) References will be taken up. Written references will also be verified by telephone by
speaking to the referee (not a colleague) and this will be noted for the employee’s file by
the person who has carried out the verification by initialling and dating the written
reference. Reference requests will contain the following question:
“Have there been any disciplinary procedures / allegations or concerns expressed about the
candidate during his or her employment that relate to the safety and welfare of children and
young people?”
9) Job offers will be confirmed in writing to suitable applicants and a copy of the contract
sent for perusal before signing.
10) Staff will receive an orientation as well as a full induction preferably before they start.
Each new staff member will be issued with their own induction checklist which will
comprise two sections:
a) a general list of topics all staff must be aware of (e.g. fire evacuation policy), to be
completed with the employee, their line manager and the school director.
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b) the second section will be based on the job description and will be completed with
the new employee and line manager and other team members if appropriate.
11) All staff will be required to sign a declaration stating that they have not been convicted
of a crime against a minor at the appropriate level of contact we deal with students
under the age of 18.
12) All staff will undergo an enhanced DBS check paid for by the company. In the case of
temporary summer teachers, the cost of the DBS check will be deducted from their final
salary.
13) All the data on file is subject to the Data Protection act of 1998.
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