198 Contemporary Arts and Learning Safeguarding Policy and Procedures
Our practice described below is underpinned by the following documents:
Keeping children safe in education
Statutory guidance for schools and colleges on safeguarding children and safer recruitment. (DfE updated April 2020)
Working Together to Safeguard Children (DCSF updated February 2019).
Safeguarding children and young people who may be affected by gang activity (DCSF March 2010)
London Child Protection Procedures (updated March 2020)
Lambeth Council’s Safeguarding Adults Policy: https://www.lambethsab.org.uk
Safeguarding covers more than the contribution made to child protection in relation to children, young people and vulnerable adults. It also encompasses issues such as health and safety and bullying and a range of other issues, for example, arrangements for meeting the medical needs of children, providing first aid, drugs and substance misuse, positive behaviour etc. There may also be other safeguarding issues that are specific to the local area or population.
198 Contemporary Arts and Learning (198 CAL) is fully committed to safeguarding the welfare of all children, young people and vulnerable adults by taking all reasonable steps to protect them from neglect, physical, sexual or emotional harm. Permanent staff, and volunteers will at all times show respect and understanding for the rights, safety and welfare of all children and young people with whom 198 CAL comes into contact, and conduct themselves in a way that reflects our principles.
All management, staff, and volunteers have a duty of care to safeguard and promote the welfare of children and young people. Everyone working with children and young people should be familiar with these procedures and have a duty to report any child protection or welfare concerns to the Director.
All employees of 198 CAL must recognise and accept that children, young people and vulnerable adults have a fundamental right to be protected from harm. In upholding this fundamental right, we recognise that there are four definitions of abuse, including neglect, as defined in Chapter 4 of the London Child Protection Procedures and as précised in this policy, which should be consulted as a reference document for full details of the definitions and recognition & response.
198 CAL will:
- Ensure that staff and volunteers know how to recognise signs of abuse or neglect.
- Ensure that staff and volunteers know which procedures to follow if there is a suspicion of risk or significant harm.
- Ensure that staff and volunteers know procedures to follow when working with children or vulnerable adults.
- Ensure that all staff and volunteers listen to and respond appropriately to the concerns of children, vulnerable adults, their family, carers and advocates.
- Audit recruitment and staff checking procedures to ensure that references are verified and properly recorded in staff files, a full employment history on file for every member of staff with gaps in employment history checked and accounted for and qualifications checked.
- Take up Enhanced/Plus Barred List Check DBS checks for new staff and all staff and volunteers working with children and vulnerable adults including temporary or contract staff and renew Enhanced/ Plus Barred List Check DBS at least every three years for all staff and volunteers involved in the delivery of activities.
- Treat all convictions, cautions and bind overs identified by the DBS as a risk.
- Determine whether or not to proceed with an offer of employment or volunteering where risks have been identified from a statutory check. In cases where the option is to proceed with employment or volunteering, we will undertake a Risk Assessment using the attached Risk Assessment Form.
- Review existing safeguarding policies to ensure that they take full account of the needs of children and vulnerable adults and assess the professional development needs of staff who work with them to enable them to communicate effectively, identify concerns, track and monitor behaviour patterns and follow appropriate child protection procedures.
- We shall ensure that there is a Single Central Record for collating DBS information.
Defining a ‘child’ and a ‘vulnerable adult’
The Safeguarding Vulnerable Groups Act 2006 defined a ‘vulnerable adult’. This definition has now been amended in the Protection of Freedoms Act 2012. Due to this amendment, adults accessing learning through Adult Learning are not necessarily ‘vulnerable’. However, we have a moral duty to safeguard the wellbeing of all our learners and in particular those who are or may be ‘in need of community care services by reason of disability, age or illness; and who is or may be unable to take care of him or herself against significant harm or exploitation’. (Department of Health 2000).
The Children Act 1989 defines a child as being up to the age of 18 years. 198 works with children and young people within our learning programmes.
Regulated activity relating to children
A child is any person up to the age of 18. Regulated activity relating to children comprises:
- Unsupervised activities: teaching, training, caring for or supervising children; driving a vehicle solely for children; providing advice/guidance on well-being
- Work for a limited range of establishments where there is opportunity for contact (for example children’s homes, schools, childcare premises). This does not include supervised contact by volunteers.
Work undertaken in the two categories above is only a regulated activity if it is done regularly.
Regulated activity relating to adults
Regulated activity in relation to adults no longer refers to ‘vulnerable adults. The focus is on the type of care that the adult requires, rather than the setting within which the adult receives that help. There is no longer a requirement for an activity to be carried out a certain number of times before it is categorised as a regulated activity.
Six categories of people fall within the definition of those carrying out a regulated activity. In addition, anyone supervising those in these six categories falls within the definition. The categories are:
- Those providing health care.
- Those providing personal care (for example help with washing and feeding).
- Those providing social care.
- Those providing assistance with handling cash, paying bills or shopping.
- Those assisting a person in his/her personal management of his/her affairs.
- Those who transport an adult because of their age, illness or disability from their place of residence to a place where they are receiving health or social care. This does not include taxi drivers or family and friends.
Definitions of Abuse
All employees of 198 Contemporary Arts & Learning must recognise and accept that children, young people and vulnerable adults have a fundamental right to be protected from harm. In upholding this fundamental right we recognise that there are four definitions of abuse, including neglect, as defined in Chapter 4 of the London Child Protection Procedures http://www.londonscb.gov.uk/ and as précised in this policy below.
The four categories of abuse are as follows:
The persistent neglect of a child or vulnerable adults is the failure to protect a child or vulnerable adults from exposure to any kind of danger including cold, lack of food, or failure to carry out important aspects of care, resulting in significant impairment of the child’s health or development including non-organic failure to thrive.
Actual or likely physical injury to a child or vulnerable adults is a failure to prevent physical injury (or suffering) to a child including deliberate poisoning, suffocation or Munchhausen Syndrome by proxy.
Actual or likely to have a severe adverse effect on the emotional and behavioural development of a child or vulnerable adults caused by persistent or severe emotional ill treatment (this category also includes bullying).
Actual or likely sexual exploitation of a child or vulnerable adults including exposure to sexually explicit material and sexual harassment as well as all forms of physical sexual contact.
Criminal Exploitation (County Lines)
Criminal exploitation is also known as ‘county lines’ and is when gangs and organised crime networks groom and exploit vulnerable people (including children, young people and adults) to sell drugs. Often these people are made to travel across counties, and they use dedicated mobile phone ‘lines’ to supply drugs. We have a duty to be vigilant and look for the signs of criminal exploitation in order to protect our learners. Useful videos to support your understanding of County Lines can be found at: https://www.youtube.com/watch?v=3ILaguFXHr4&t=103s https://www.safeguardinginschools.co.uk/county-lines/
- Abuse is often difficult to recognize unless the child or vulnerable adults makes a disclosure.
- Injuries may not be conclusive.
- There must always be concern if the parent or carer shows no anxiety about the child’s or vulnerable adults’ condition or coldly blames the child or vulnerable adults. Most parents or carers express guilt about accidents involving their children or vulnerable adults, even if this is misplaced.
- Suspicion is raised when: 1) there is a delay in seeking treatment, 2) inadequate explanations are given, or the child or vulnerable adult has injuries of different ages or there is a history of injury 3) there is evidence of a failure to thrive.
N.B. Different categories of abuse may be inter-related e.g. emotional abuse in some form is apparent in all other forms of abuse.
Recognising the signs of child abuse is one of the first steps in protecting children. The following is by no means a comprehensive list, but it demonstrates some signs, which may give, rise for concern.
- Unexplained bruising, injuries, burns or illnesses
- Changes in behaviour/character e.g. becoming very withdrawn
- Sexually explicit language, behaviour or mode of dress
- Being left outside the home for long periods of time without food or drink
- Showing uncharacteristic aggressive behaviour
- Showing unexpected fear of an adult
- Refusing to attend school, or other school related issues
- Low self-esteem
- Depression and/or self-harm which may lead to suicide
- Developmental delay – mentally, physically or emotionally
- Reluctance to go home
- Reluctance to disclose personal details i.e. contact details
- Too much money or lots of new possessions
It is important to remember that changes in behaviour or signs that you have noted may not necessarily mean that a child or vulnerable adults is being abused. There may be other issues involved e.g. bullying or domestic problems. It is not your responsibility to decide if it is abuse – it is your responsibility to act on your concerns.
Responding to a Disclosure
- Take seriously whatever the child or vulnerable adult tells you.
- Just listen and be supportive.
- Do not ask detailed or leading questions or press the child or vulnerable adult for more information than they want to give you, instead ask ‘do you want to tell me more?’
- Report to the Director or nominated deputy as soon as is possible. Be very careful if it appears you have led the child or vulnerable adult in any way this can have legal implications.
- Do reassure the child or vulnerable adult that it is not their fault.
- Do not make judgments or say anything about the alleged abuser.
- Do not promise to keep secrets. Be honest about your own position and if possible name the person you will talk to about this matter.
- Do not ask the child or vulnerable adult to repeat the disclosure to anyone else.
- Do not display shock or disapproval when the child or vulnerable adult is making the disclosure.
- Remember the child or vulnerable adult may not regard the experience as wrong or painful. They may not feel angry or guilty.
- Keep the child informed of any action you are going to take.
- Inform the Director (or the nominated deputy in case of the Director’s absence) as soon as possible.
- Make a written record of everything as soon as possible. This record must state everything the child or vulnerable adult has said, these records must be precise and state only what the child or vulnerable adult has said, do not add anything which you think the child or vulnerable adult may have meant or implied similarly if the child or vulnerable adult uses ’pet’ words do not translate them. Sign and date the record – this should then given to the designated person who must keep it in a secure, locked place.
- Do not destroy any evidence. Initial disclosure, even if retracted may still be referred to.
- Take care of yourself – make sure that you have the opportunity to discuss your feelings (in confidence) with a fellow professional.
It is vital to follow these guidelines as closely as possible. Any failure to do so may prejudice legal proceedings.
Suspicion of Abuse or of Inappropriate Behaviour
- If any member of staff suspects abuse of a child or vulnerable adult or suspects inappropriate behaviour towards a child or vulnerable adult by anyone (including a member of 198 CAL staff), then they must make their concerns known to the Director who will investigate and record all the facts concerning the incident, and decide upon appropriate action. (See Appendix 1. Incident reporting form)
- In the case of abuse alleged to have taken place while a child or vulnerable adult is in the care of 198 CAL, the following details will be recorded: the person’s name, address, sex, date of birth, parent(s)’ or guardian(s)’ names and contact point, name of staff making the referral, details of the incident or allegation, action taken including dates and time.
- Staffs involved are advised to keep an independent record of this information.
- The Director will inform the relevant Local Authorities and Social Care Services.
- It may be necessary to suspend without prejudice any 198 CAL members of staff against whom an allegation is made.
- In the case of a child or vulnerable adult disclosing information about their welfare or safety (including abuse for example), staff should report the disclosure to The Director.
- If necessary, 198 CAL staff should explain to child or vulnerable adult that when they are at risk they are unable to maintain confidentiality. For example, if a young person confides information about sexual abuse, staffs are required to report this information.
Whistle Blowing Procedures
- We recognise that child or vulnerable adult cannot be expected to raise concerns in an environment where staff fail to do so.
- All staff should be aware of their duty to raise concerns, where they exist, about the management of child protection, which may include the attitude or actions of colleagues.
Any concerns for the welfare of the child or vulnerable adult arising from suspected abuse or harassment by a member of staff or volunteer should be reported to the Director immediately
Arrangements and Procedures
The Director is responsible for co-ordinating these arrangements and procedures.
Appointment of Staff
- 198 CAL has a Vetting and barring procedure and will not employ any person in the provision of the Activities who has committed any offence listed in the document ‘Convictions and Circumstances relating to employment’ which outlines convictions or circumstances which would automatically exclude an offer of appointment.
- Two references must be obtained for all candidates before confirming an appointment; if possible one of these should be from a referee who has experience of the candidate working with children. In this instance, it is essential that the referee is asked explicitly if the candidate is suitable for the role and for working with young people. References should be obtained in writing – it is acceptable for these to be in the form of notes taken during a telephone or face-to-face conversation with a referee. Staff responsible for the appointment should speak personally to at least one of the referees. Copies must be retained.
- All staff and volunteers are subject to a DBS check (see below).
- All appointments are subject to a personal interview that explores attitudes, motivation, temperament and personal qualities as well as skills and experience.
- Candidates must provide proof of identity before an appointment is confirmed. A copy should be made and kept on file. In line with the Bichard Enquiry (4.94, p 147) documents produced to confirm identity should, wherever possible, include a photograph.
- Checks must be carried out to confirm all relevant significant qualifications claimed by candidates.
- All employment offers must be made conditional to satisfactory references, checks and DBS Disclosure. If it is necessary for someone to start work at short notice a risk assessment must be undertaken and they must be supervised by an appropriate DBS checked member of staff whilst working with children and young people / vulnerable adults, until these are completed.
- All staff will be made aware of the policy and these arrangements and procedures, and their obligations regarding child protection, as part of their induction. Staff with substantial access to children will receive further ongoing training as appropriate.
- The Director should maintain confidential records of all incidents relating to child protection, and of any decisions made regarding staff DBS Disclosures.
198 CAL operates safe recruitment practices and takes up at least two references for all employees and associates. All staff working directly with, or having access to, children and young people are subject to enhanced DBS checks. In addition:
- Candidates who produce a DBS check obtained through previous employment must obtain a new DBS check.
- DBS checks must be renewed after three years. It is accepted that the renewal process may take up to six months to complete and therefore previous DBS check will be accepted for up to three and a half years, after which the DBS check will be considered invalid.
- 198 CAL has a separate policy on the recruitment of ex-offenders, and the disclosure of an offence does not necessarily bar an applicant from appointment. However, failure to declare a conviction, caution or bind-over is a serious matter, and may disqualify staff from appointment, or result in summary dismissal if the discrepancy comes to light.
- It is a condition that all employees and volunteers at 198 CAL have an ongoing obligation to promptly report any convictions, police cautions or warnings to The Director.
- 198 CAL maintains a database which records the status of DBS checks obtained for staff and volunteers.
- We are clear about staff and volunteer responsibilities to safeguard and promote young people’s welfare.
- We check that there are no known reasons or information available that would prevent staff, associates or volunteers from working with children and young people.
- We have procedures for dealing with allegations of abuse against members of staff and volunteers
- We ensure staff and volunteers receive training that helps them do their job well.
- We will ensure, where we are working with other organisations and statutory bodies, agreements are in place in relation to safeguarding.
Induction and Training for Board Members, Staff and Volunteers
198 Contemporary Arts & Learning will ensure that:
- All board members, staff and volunteers are provided with a copy of this policy as part of their induction process.
- All members of the governing board understand and fulfil their responsibilities.
- We have a nominated designated member of staff – The Director 198 CAL who is responsible for co-ordinating these arrangements and procedures.
- We have a member of staff who will act in the designated member of staff’s absence.
- All members of staff and volunteers are provided with Safeguarding Training within six months of being (where appropriate) employed by 198 CAL and thereafter every three years.
- All new staff and volunteers are adequately supervised and their progress reviewed on a regular basis.
- All board members, staff and volunteers know:
- The signs and symptoms of concern.
- How to respond to a young person who discloses abuse.
- What to if they are concerned about an individual.
- All parents/carers are made aware of the responsibilities of 198 CAL staff members with regard to safeguarding procedures.
198 expects all staff to comply with safeguarding policy and procedures. The Designated Safeguarding Lead is trained to Level 3/4 standards, and the training must be refreshed every 3 years. In addition, the Designated Safeguarding Lead will undertake annual Continual Professional Development (CPD) which is recorded on the central staff training record. All Deputy Designated Safeguarding Leads receive training at the equivalent to Level 3, but ideally the same as the Designated Lead. This is refreshed every 3 years. All new staff are required to have a safeguarding induction as soon as they start in their role (ideally on their first day, but definitely within the first week of starting their role).
This is followed by mandatory safeguarding training within the first 3 months of employment. For staff who deal with learners, this should meet the Level 2 safeguarding training standards. Such training can be written and delivered by a recognised safeguarding expert or a Designated Safeguarding Lead. 198 has a ‘Safeguarding Induction’ PowerPoint presentation for use as part of the safeguarding induction which has been provided by Lambeth Adult Learning.
All new staff also need to attend a ‘Workshop to Raise Awareness of Prevent’ (WRAP) training which is available online. Annual Continual Professional Development (CPD) for all staff is to be delivered by the Designated Safeguarding Lead in each provider. This is certificated and recorded on the central staff training record. All staff should complete formal refresher training every three years delivered by the Designated Lead. This is in addition to annual CPD activity. If there are any updates to policies or procedures in between these times, these will be explained to relevant staff through email, updates or team meetings.
The Designated Safeguarding Lead and the Designated Deputy are also available to offer generic and specific information, advice and guidance to staff around day-to-day safeguarding matters either by phone or by email.
Good Working Practice
198 Contemporary Arts & Learning has a friendly relaxed atmosphere and professional boundaries are not always clear. Therefore we must be aware that genuine responses can be open to misinterpretation. Staff should conduct themselves in such a way as to avoid compromising situations and to protect themselves against false allegations of abuse.
- Identity badges should be worn at all times while dealing with participants on and offsite.
- There may be occasions when you need to touch a young person (e.g. when you are guiding them in performing a technical operation such as with special needs, guiding them using a mouse) these should be transparent and kept to a minimum.
- Whilst it is important to reassure a children, young person and vulnerable adults who may be nervous in coming into the digital media studio or gallery environment, workers must avoid being over familiar. Never permit ‘horseplay’ which may cause embarrassment or fear.
- Treat all children, young people and vulnerable adults equally, and with respect and dignity.
- Where possible avoid being on your own in an isolated or closed environment with a child, young person and vulnerable adult. Ask a fellow worker to be present during situations that may be sensitive or leave a door ajar with another worker in ear shot and/or visible. This is for your protection as well as being a reassurance to the young person.
- A group should have a minimum of two workers (excluding any workers that may attend with the group or individual). For any offsite activity the offsite activity checklist must be completed.
- Young people should NOT be taken off the premises without written permission from either their school/organisation or parent/carer.
- Those placed directly in charge of young people should be competent in their work-role.
198 Referral Process
Abuse discovered/suspected or a disclosure is made to you.
Immediately inform your Designated Safeguarding Lead in person or by telephone: Kareen Williams email@example.com- 0207 978 8309.
If the person is at risk in immediate danger/in need of medical assistance provide appropriate medical attention or call the emergency services if necessary
The Designated Safeguarding Lead should
- Gather information
- Take advice
- Make judgements to decide if further action is necessary.
If further action is necessary the following actions should be taken;
- If a crime is suspected or has been committed the Designated Lead reports the matter to Police.
- The Designated Lead telephones the adult social care team on 0207 926 5555 (Out of Hours Emergency Duty Team 0207 926 1000) or Lambeth Child Protection Designated Lead on
providing the name of the person, their address and if known their date of birth. If a referral is made, this must be confirmed in writing by the Designated Lead to the appropriate agency within 24 hours.
If NO further action is necessary;
- The matter is dealt with internally and the Designated Lead records and monitors. The Designated Lead will brief the person reporting the issue where it is appropriate or does not breach confidentiality.
Health & Safety
We understand the requirement to ensure that children and vulnerable adults are able to use the Internet and related technologies appropriately and safely. It is part of our wider duty of care, as mentioned above, to ensure that children, young people and vulnerable adults are safe and are protected from potential harm, both within and outside 198 CAL.
- Have an up to date awareness of online safety matters and of the 198 CAL online safety policy and practices
- Report any suspected misuse or problem to the senior staff or director for investigation/action.
- Ensure that all digital communications with students/parents/carers should be on a professional level and only carried out using official systems
- Support children, young people and vulnerable adults understanding and following the Online Safety Policy and acceptable use policies
- Monitor the use of digital technologies, mobile devices, cameras, etc. in planned sessions and other activities.
- Guide children, young people and vulnerable adults to sites checked as suitable for their use and that processes are in place for dealing with any unsuitable material that is found in internet searches
- Be aware of the potential for serious child protection/safeguarding issues to arise from:
- Sharing of personal data
- Access to illegal/inappropriate materials
- Inappropriate on-line contact with adults/strangers
- Potential or actual incidents of grooming
- Inform children, young people and vulnerable adults about the importance of reporting abuse, misuse or access to inappropriate materials and know how to do so.
E Learning and online Delivery
E-safety will be embedded into all teaching and learning so that learners know how to stay safe online. All learners will receive a safeguarding induction at the beginning of the course providing information on safeguarding processes for the project.
- The email or personal website addresses of children or vulnerable adults should not be disclosed by staff under any circumstances and are not to be used to make contact with those individuals except for approved professional purposes.
- Material submitted by children or vulnerable adults to the organisational website should be treated in the same way as photographs (see point above), i.e. any information which could be used to identify or trace individuals should be withheld unless written permission is obtained.
- Contributors of user generated content (UGC) are made aware of any content that is personal and likely to put people at risk.
Epidemic or Pandemic
In situations, for example caused by Coronavirus (COVID-19) 198 CAL will follow the government guidelines and understand that the guidelines will be subject to change. Unless classified as an essential service, 198 CAL will remain closed until instructed otherwise, to ensure that staff volunteers and young people remain safe.
If staff or volunteers were working remotely during an outbreak, as experienced with COVID-19, they will:
- Continue to process and store personal information in line with our Data Protection policies.
- Not use personal devices to communicate with young people, store personal information on personal devices or download and use apps onto work or personal devices (phones/laptops/tablet computers) without express authorisation from senior staff.
In the case of blended delivery 198 CAL will ensure that government advice in relation to Covid safety is followed and that the appropriate signage, hygiene and cleaning and social distancing protocols are adhered to.
Government published the Prevent Strategy in 2010 and this raised awareness of the need to safeguard young people and extremism and radicalization.
The Government in the Prevent Strategy as defines extremism:
Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.
At 198 CAL we understand that our Prevent policy is keeping the children, young people and vulnerable adults safe and keeping them within the law.
Staff will respond to suspicions by making a referral to Lambeth Prevent Duty.
Our Health & Safety policy, set out in a separate document, reflects the consideration we give to the protection of children and vulnerable adults both physically within 198 CAL, including internet use and prevent as well as when on offsite activities
198’s evacuation procedure is outlined in detail in our Health and Safety and Fire Safety policy documents available on request.
198 CAL is committed to ensuring that our staff are safe and protected at all times. The 198 Staff Code of Conduct provides guidelines for staff to follow which have been designed to ensure that staff are protected in their work
Reporting – Contacts & Numbers
|198 Designated Lead||Lucy Davies
Director 198 CAL
|0207 978 firstname.lastname@example.org|
|198 Deputy||Kareen Williams||0207 978 email@example.com|
|Police||Brixton Police Station||020 7326 1212|
|Lambeth Children’s Social Care
|020 7926 5555
Out of hours emergency: 020 7926 1000
|NSPCC Child Protection Helpline||0808 800 5000|
198 Contemporary Arts & Learning management board will review this policy annually ensuring that this policy reflects developments in the Safeguarding of children and young people.
Date Adopted by 198 CAL Management Board