The Association will use its best endeavours to safeguard learners deemed to be ‘children’ through the implementation of this policy. Children are learners under 19 years of age taking part in vocational training with the Association.
The Association will ensure, so far as is reasonably practicable, that any Employer placement used is aware of, and complies with the requirements of this Safeguarding policy.
Staff and placement providers will receive guidance and where appropriate, training on child protection issues.
This policy is provided for all HWGTA staff and apprentice learners.
- Chief Executive
- Senior Management Team (SMT)
- Designated Safeguarding Lead (DSL)
- Safeguarding Team
- All staff
As a training provider we have a legal responsibility to safeguard all learners in our care. In order to do this, we will ensure that all employees have an enhanced Disclosure and Barring Service (DBS) check and it is obtained before any appointment is made. Those already in employment at HWGTA, have had enhanced DBS checks undertaken.
Part of our commitment to Safeguarding is ensuring that everyone is aware of the organisation’s policies, procedures and systems. Every allegation that is made, must be taken seriously and the correct action and steps must be taken.
As a Training Provider, we have certain obligations that we must carry out to ensure the safest working environment we can, for both learners and employees. We must make sure that:
- There is a comprehensive and effective safeguarding policy in place
- There is a designated person who deals with safeguarding
- There are effective measures to ensure safer recruitment for staff
Staff at HWGTA will all go through formal safeguarding training, and procedures will be in place to ensure that the dissemination of safeguarding information is effective and efficient.
Learners and employers will receive an information booklet on safeguarding, whenever a new start occurs.
Promotion, Engagement and Staff Training
The following areas will seek to promote and engage Safeguarding (including Prevent) , to staff, learners and employers:
- Staff induction
- Learner induction
- DSL Training for DSL and CE
- Safeguarding team ongoing training and CPD record
- Bimonthly Newsletters to staff and learners
- Biannual Newsletters to employers and other customers
- Learning reviews – reinforcement questions
- Dedicated Safeguarding email address – email@example.com
- Social Media Posts
- Posters at training sites
- Embedded promotion to learners from training staff during the training programme
- A member of the SMT is given responsibility for leading and championing this area
The following activities are designed to train staff on Safeguarding:
- Staff induction
- Bimonthly Newsletters to staff to highlight key areas and reinforce the fundamental facts
- Ongoing Staff CPD programme
- Staff meeting updates
The Designated Safeguarding Lead (DSL)
The DSL is a member of the Senior Management Team, who will take responsibility for safeguarding in the Company. The Quality and Continuous Improvement Manager, Jo Jones, has overall responsibility for safeguarding and a member of the Board, Debbie Gittoes, also holds Safeguarding accountability.
The other Designated People at Herefordshire and Worcestershire Group Training Association, who make up the Safeguarding team, are Andrew Lewis, Jo Hopcutt, Scarlet Hopcutt and Donna Harper-Edwards.
They will deal with and be responsible for all safeguarding procedures and will act on any concerns that are raised. If the designated person decides to further investigate any allegation that is raised, they will appoint a member of staff to conduct the process.
The Designated Person’s responsibilities will include:
- Taking responsibility for promoting positive safeguarding procedures and practices within the organisation.
- Ensure the safeguarding team and all staff have the appropriate initial training and CPD in relation to Safeguarding
- Ensure apprentice learners have appropriate initial and reinforcement training in relation to safeguarding.
- Ensure apprentice learners are clear on who to contact on the event of a safeguarding concern.
- Receiving information from, and offer advice to staff, learners and employers.
- Maintaining secure records in relation to safeguarding issues and allegations.
- Assessing information promptly and taking appropriate action.
- Being familiar with national and local safeguarding legislation.
- Knowing who to contact and establish links with their local Safeguarding Board and the relevant people within children and adult services or police.
- Refer cases to outside agencies as appropriate.
- Ensure policies and documentation relating to Safeguarding are reviewed annually.
- Ensure the CE, Board and Management team are kept informed of any relevant safeguarding concerns, whilst maintaining confidentiality as appropriate.
- Carry out and document a risk assessment in relation to the Prevent Agenda.
If there is a problem regarding the DSL, the Chief Executive or any one of the current management team can be approached, or the Association’s Whistleblowing Policy can be followed.
In the absence of the DSL, staff or learners can approach any member of the Safeguarding team, who would be supported by the Chief Executive.
The Employers’ Obligations
Each employer has a responsibility to ensure the safeguarding of learners in their employment. We accept that learners will take part in one-to-one contact when in company and it would be impractical to expect the employer to DBS check every employee that may come into contact with the learners, but we will require an assurance that the employer is committed to safeguarding and has all the relevant information required to enable them to identify the signs and know how to act. If an employer has any concerns, they can report it to any member of HWGTA staff (e.g. field/reviewing officer) or directly to a Designated Person. If HWGTA has a concern, they will raise the issue with the company representative and agree a course of action.
HWGTA can refuse to work with and withdraw the services provided to any employer who breaches their commitment to safeguarding. They will also inform the relevant external agencies of any concerns.
As part of initial Health and Safety Checks, employers will be asked to declare their main point of contact for Safeguarding.
The Learners’ Obligations
Whilst there are not any obligations by law, HWGTA will expect all learners to be vigilant and aware of the signs of potential abuse and report anything they feel is suspicious. We will expect all learners to report issues related to themselves and also related to their fellow learners.
Reporting a Concern
Staff, learners and employers should report a safeguarding concern to the safeguarding team using the methods outlined in the safeguarding procedure.
This can be in relation to an individual of any age on the apprenticeship programme.
For staff who may have a concern about themselves or a colleague - approach the DSL or their Line Manager.
As part of training, most Apprentices will attend a five day personal development residential course. The safeguarding procedures in place for this are:
- Risk assessment is carried out by the outdoor centres used on their activities and environment, this is checked annually before the residential weeks commence, by the member of HWGTA staff who has been appointed as a lead on the residential week.
- Sleeping arrangements in the centres for learners are divided by gender.
- HWGTA members sleep separately to learners, but in close enough proximity to monitor safety. HWGTA Staff will be located near to same gender learners for monitoring purposes.
- Sleeping arrangements when whole group is together in an outdoor environment is divided by gender. There will always be at least one member of HWGTA staff plus one or more members of activity centre staff present when learners are sleeping in an outdoor environment.
- Where a learner is deemed as having potential or actual safeguarding issues, a risk assessment will be carried out prior to attending and appropriate support measures put in place.
- HWGTA will ensure that where we have female learners present on residential week, we have female members of staff also present.
- HWGTA will ensure that where we have male learners present on residential week, we have male members of staff also present.
- Learners will be issued with and expected to sign a Code of Conduct relating to safeguarding issues and expected conduct. Alcohol is prohibited for all apprentices when attending residential, regardless of age. Drug and Alcohol testing may be carried out during this training to ensure the safety of all attendees.
- HWGTA staff will work with centre staff, to ensure a safe environment including regular reviews on weather and environmental conditions.
Abuse outside of the training programme and/or premises is difficult to control by HWGTA and in these instances, the expectation on staff and apprentices is to remain vigilant and report any concerns (big or small) to the safeguarding team.
In order to assist prevention of any form of abuse, that could take place within the training programmes:
- Not have physical contact with any apprentices, unless it can be justified as part of training activity or if dealing with an emergency (eg giving first aid). Shaking hands in a professional manner is acceptable.
- Avoid situations where there is just a member of staff and an apprentice in an enclosed space, that is not visible to others or where others are not in attendance.
- Not use inappropriate language or commentary towards apprentices, especially that which could be deemed to be of a sexual or intimidatory nature.
- Not be present during any occasion where an apprentice may be changing clothes or showering, for example after physical training or on the residential course.
- Not enter an apprentice’s home without being invited to and in the presence of a colleague.
- Not socialize with an apprentice, unless as part of a sanctioned HWGTA event or where a declared personal relationship already exists e.g. family member.
- Follow the rules on E-communication, transporting an apprentice, use of IT, residential week, health and safety and reporting of concerns.
Apprentice learners must:
- Avoid physical contact with other apprentices and HWGTA staff, unless it can be justified as part of training activity or if dealing with an emergency (eg giving first aid). Shaking hands in a professional manner is acceptable.
- Not use inappropriate language or commentary towards apprentices or staff, especially that which could be deemed to be of a sexual or intimidatory nature.
- Do not send or request photos from other apprentices or staff unless they directly relate to training or assessment activity.
- Show tolerance, kindness and patience towards other apprentices.
- Not discriminate against any apprentice or staff member, either through verbal or physical actions.
- Avoid situations where there are just two apprentices in an enclosed space, that is not visible to others or where others are not in attendance.
- Follow the rules on E-communication, transporting an apprentice, use of IT, residential week, health and safety and reporting of concerns.
Communication between staff and Apprentices using personal social networking platforms such as Facebook, Snapchat and Twitter are strictly prohibited. Staff may only use official company social networking accounts to communicate one way with Apprentices, ie to send out or publish information rather to engage in any “chat” or conversation.
Staff must declare a prior personal relationship with an Apprentice who joins the programme, for example family member, family friend etc. Where prior relationships exist, staff are strongly encouraged to avoid any electronic communication with that apprentice, unless not practical, for example where the apprentice is a son or daughter of a staff member.
HWGTA staff may use text messaging and email to contact Apprentices for matters relating to their Apprenticeship only.
Apprentices who are employed directly by HWGTA (in a non-training role) may use social networking with their peer group. However, this must be undertaken with caution and company business should not be discussed under any circumstances. If through their use of social media, any apprentice employed by HWGTA identifies a potential safeguarding issue, they must report this immediately to their line manager.
Use of IT
Staff and apprentices will be made aware in initial training what is acceptable in terms of using HWGTA equipment to access online content. This also applies to online content accessed on their own devices during working hours.
Online content should only be accessed when it specifically relates to the work or training being undertaken by the staff member or learner.
Online content that should not be accessed, includes (but is not limited to):
- Extremist groups or materials
- Offensive material
- Material that contravenes UK law
- Illegal websites
HWGTA’s IT infrastructure has been setup to flag where access to inappropriate content has been attempted and to block access to inappropriate content.
Physical training occurs within the first-year engineering programme, predominantly through road running with additional time spent in a gymnasium environment. In order to protect the safeguarding of participant learners:
- Risk assessment of individual participant abilities
- Risk assessment of running routes
- Risk assessment of gymnasium or other environments used for PT
- Separate changing facilities for staff and learners
Transporting an apprentice to any destination should only be undertaken in the event of an emergency. If the journey is essential and a taxi or emergency transportation (eg ambulance) cannot be secured, then the following rules apply:
- A company vehicle is used or if using own vehicle, appropriate business travel insurance is in place
- There are at least 2 staff in the vehicle with the apprentice (one of these staff members should be of the same gender as the learner)
- The apprentice should always sit in the rear of the vehicle
As well as the reporting requirements outlined in the safeguarding procedure, the DSL must also:
Where a safeguarding concern related to sexual violence is reported to Local Authority children’s social care/adult social care and/or the police, or an allegation of abuse made against a teacher or other member of staff HWGTA must, as soon as practicable, inform the ESFA.
Such notification must include the name of the institution, a high level summary of the nature of the incident (without sharing personal information about victims or alleged perpetrators) and confirmation of whether it is, or is scheduled to be, investigated by the Local Authority and/or the police.
Learner Risk Assessment
Any learners that are flagged through the initial assessment process as being potentially vulnerable will be referred to the DSL for review and risk assessment/action planning where appropriate. In this event the DSL will ensure the principles of Equality, Diversity and inclusion policy are adhered to.
This policy will be reviewed annually to ensure the Association is compliant with legislation and best practice expectations.
Background to Prevent
The revised Prevent Strategy was launched in June 2011 and is an integral part of the Counter Terrorism Strategy and its aim is to stop individuals becoming drawn into, promoting or supporting terrorism.
Prevent will address all forms of terrorism but continue to prioritise according to the threat they pose to our national security. Preventing terrorism will mean challenging extremist (and non-violent) ideas that are also part of a terrorist’s ideology. Prevent will also mean intervening to try to stop people moving from extremist groups or extremism into terrorist-related activity.
The three Prevent objectives are:
Respond to the ideological challenge of terrorism and the threat we face from those who promote it. This means using teaching and learning to help learners and staff to develop the knowledge and skills to challenge extremist narratives.
Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support. This means identifying how to prevent harm to learners by individuals, groups or others who promote terrorism and violent extremism. Provide programmes to support learners who are vulnerable.
Supporting sectors and institutions where there are risks of radicalisation This means increasing the resilience of educational communities by encouraging engagement with management, staff and learners through training and awareness raising. Encourage staff training and use curriculum opportunities for learners which allow grievances to be aired and dealt with. Ensure that learning resources are not used by extremist groups.
A Counter Terrorism and Security Bill was introduced to Parliament by the Home Secretary on 26 November 2014. The Bill includes provision to place the Prevent element of the national counter terrorism strategy on a statutory footing. This has implications for educational establishments including work based training providers.
Who is responsible for pursuing terrorists?
There are other elements within the government’s counter terrorism strategy which focus on pursuing and disrupting terrorists. This is not the role of Prevent, which operates in what is called the ‘pre-criminal space’, similar to other preventative initiatives that protect and safeguard vulnerable individuals at risk of being drawn into harm such as drugs, gang culture and gun and knife crime.
Objectives of Policy
- To promote, implement and monitor the Associations responsibilities under the Prevent Duty to all learners, staff, board members and visitors to HWGTA
- To promote and embed British Values into the organisation’s procedures and curriculum offer
- To set a strategy, objectives and an action plan to achieve the Prevent Duty
- To ensure learner and staff safety
- To ensure that the Association promotes a culture of zero tolerance of bullying, harassment and discrimination.
- To provide support for learners who may be at risk and develop appropriate sources of advice and guidance.
- To ensure that learners and staff are aware of their roles and responsibilities in preventing violent extremism and radicalisation.
The Prevent Duty states the British Values that are expected to be embedded into the curriculum offer and into the ethos of the Association, they are:
• The rule of law
• Individual liberty
• Mutual respect
• Tolerance of those with different faiths and beliefs
Prior to the Prevent duty, these values already formed the key and ethos to how the Association delivers training.
A Prevent risk assessment will be carried out and reviewed annually to ensure all measures are in place to reduce risk.
Learners will receive training and information in order to inform them of, and raise their awareness of, the Prevent agenda as part of their safeguarding training.
This will be supported by reinforcement questions and guidance at learner reviews
Staff will receive regular training and guidance on how to deal with:
• Inappropriate material and behaviours
• Disclosures by learners about their exposure to extremist actions, views or materials
• Accessing extremist material on line
• Parental or peer concerns
• Intolerance of difference
• Anti-Western or Anti-British views
The Association will ensure that all staff are familiar with the Prevent agenda, be able to promote British Values, understand how they can recognise practice and behaviours in learners and colleagues and are aware of the course of action to take if they are concerned.
Board members will be required to undergo Prevent training in order to understand their responsibilities and monitor that all staff and managers are meeting their responsibilities with regards to Prevent.
What support is available for people at risk of becoming involved in extremism?
Channel is a joint initiative that offers help and guidance to people who may be at risk of becoming involved in extremism. Extremist organisations sometimes try to recruit people who are susceptible or vulnerable, in person or through the internet. If the early signs are spotted and acted upon, it safeguards the person concerned and helps protect all of us who live and work in the city.
Concerns that an individual may be vulnerable to radicalisation does not mean that you think the person is a terrorist: it means that you are concerned that they are prone to being exploited by others.
It is important that staff trust their professional judgement – if they are concerned that someone is at risk of getting involved in extremism, they should in the first instance contact the safeguarding lead at the Association who should, if required, contact their Channel coordinator. They will, in partnership with other safeguarding professionals, investigate further to assess the nature and extent of the risk and the Channel panel will develop the most appropriate support package for the individual concerned.
Internal referral procedure
All staff should be aware of signs of radicalisation and have the confidence to report their concerns the Designated Safeguarding Lead, Jo Jones, or a member of the Safeguarding Team, who will discuss the matter with other Senior Managers and external agencies as necessary.
The Designated Safeguarding Lead and/or Panel Member will decide what action is necessary which will include a discussion with the Prevent Officer within Warwickshire and West Mercia Police. This discussion may be for advice purposes or for a referral.
External referral procedure
A link with the Regional Prevent Lead Further and Higher Education (West Midlands), Mrs Hifsa Haroon-Iqbal is well established and any concerns regarding Prevent are referred to Mrs Haroon-Iqbal for consultation and advice.
The Designated Safeguarding Lead will be in regular contact with Mrs Haroon-Iqbal and will pass on updates to the wider team as appropriate.
Staff and apprentice training is organised through this contact.
Warwickshire and West Mercia Police have a Channel procedure in place.
The Police Channel procedure is a partnership focused structure and is similar to existing, successful initiatives which aim to support individuals and protect them from harm - such as involvement in drug, knife or gun crime.
Channel is about supporting those most at risk of being drawn into violent extremism and about diverting people away from potential threat at an early stage - which prevents them from being drawn into criminal activity.
Partnership involvement ensures that vulnerable individuals have access to a wide range of support from diversionary activities through to providing access to specific services such as education, housing and employment. Each multi-agency panel varies according to local circumstances but partners (who are all signed up to an Information Sharing Protocol) can include:
• Statutory partners such as education, NHS, probation, housing and the police service
• Social Care
• Children’s services (e.g. Common Assessment Framework co-ordinators)
• Youth offending services
• Credible and reliable members of the community
All members of staff will engage in the Channel process as necessary and will contact the safeguarding contact should it have any concerns about a student, member of staff, board member or visitor.