Our aim is to follow the procedures set out by Solihull Safeguarding Children’s Partnership, Working Together to Safeguard Children 2018 and Keeping Children Safe in Education 2023 by knowing and understanding that:

  • Safeguarding and promoting the welfare of children is everyone’s responsibility, and the voice of the child is evident.
  • Everyone who comes into contact with children and their families has a role to
  • Everyone should ensure that their approach is child-centered considering, at all times, what is in the best interests of the child.
  • By establishing a safe environment, we enable our children to learn and develop within an ethos

of openness.

  • No single practitioner can have the full picture of a child’s needs and circumstances.
  • If children and families are to receive the right help at the right time, everyone who comes into contact with children and their families has a role to play in identifying concerns, sharing information and taking prompt action.
  • Ensuring that as a company we have awareness of our staff’s knowledge and understanding as well as embedding safeguarding, through clear systems of communication and Continuous Professional Development (CPD) so that safeguarding is a robust element of our practice.

Legislation and statutory guidance

This policy is based on the Department for Education’s Keeping Children Safe In Education 2023 statutory guidance and Working Together to Safeguard Children (2018), and the Governance Handbook. 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 175 of the Education Act 2002, which places a duty on schools and local authorities to safeguard and promote the welfare of pupils

The School Staffing (England) Regulations 2009, which set out what must be recorded on the single central record and the requirement for at least one person conducting an interview to be trained in safer recruitment techniques

The Children Act 1989 (and 2004 amendment), which provides a framework for the care and protection of children

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 teachers 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 schools’ duties under the Counter- Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism

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

This policy also meets requirements relating to safeguarding and welfare in the statutory framework for the Early Years Foundation Stage.

This policy also complies with inter-agency working procedures put in place by the Solihull Safeguarding Local Children’s Partnership and What to do if you’re worried a child is being abused (March 2015).



Safeguarding and promoting the welfare of children is defined as:

  • 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 following 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

The Bugs Group is committed to safeguarding and promoting the welfare of all its children. We believe that:


  • All children/young people have the right to be protected from harm;
  • Children/young people need to be safe and to feel safe;
  • Children/young people need support that matches their individual needs, including those who may have experienced abuse;
  • All children/young people have the right to speak freely and voice their values and beliefs;
  • All children/young people must be encouraged to respect each other’s values and

support each other;

  • All children/young people have the right to be supported to meet their emotional, and social needs as well as their educational needs – a happy, healthy, sociable child/young person will achieve better;
  • The Bugs Group can and does contribute to the prevention of abuse, victimisation, bullying (including homophobic, bi-phobic, trans-phobic and cyber-bullying), exploitation, extreme behaviours, child on child abuse, discriminatory views and risk taking behaviours;
  • All staff and visitors have an important role to play in safeguarding children and protecting them from abuse.


Equality statement

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.

We give special consideration to children who:

  • Have special educational needs (SEN) or disabilities
  • 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 (female genital mutilation), 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

Roles and responsibilities

Safeguarding and child protection is everyone’s responsibility. This policy applies to all staff and is consistent with the procedures of the 3 safeguarding partners.

All staff

All staff will undergo safeguarding training.

All staff will sign a declaration at the beginning of each academic year to say that they have reviewed the guidance.

All staff will be aware of:

  • Our systems which support safeguarding, including this child protection and safeguarding policy, the staff code of conduct policy, the role and identity of the designated safeguarding lead (DSL) and deputies, the behaviour policy, the online safety policy, and the safeguarding response to children who go missing


  • 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 sexual exploitation (CSE), indicators of being at risk from or involved with serious violent crime, FGM and radicalisation
  • The importance of reassuring victims that they are being taken seriously and that they will be supported and kept safe.

You must inform the Designated Safeguarding Lead immediately, verbally and provide a written account as soon as possible.

In the case of a serious concern, or where clarification is needed, then the member of staff must speak directly to the Designated Safeguarding Leads (DSL)

Safer Recruitment processes and checks, and be subject to these processes.

The designated safeguarding leads (DSL)

Our lead DSL is Zoe Smyth. As the Strategic DSL, she takes lead responsibility and management oversight for child protection and wider safeguarding, and is responsible for coordinating all child protection activity, including online safety and understanding the filtering and monitoring systems and processes in place
The DSL will be available during hours of 9:00-17:30 Monday to Friday for staff to discuss any safeguarding concerns.
The DSLs can be contacted out of business hours if necessary, via the email addresses: [email protected]

If the DSL is not available, please contact the deputy DSL.
The DSLs will be given the time, training, resources, and support to:• Provide advice and support to other staff on child welfare and child protection matters.
• 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.

The full responsibilities of the DSLs are set out in their job descriptions.
• The Designated Safeguarding Leads attend appropriate refresher training at least every two years.
• The DSL and all other staff who work with children undertake training on an annual basis with additional updates as necessary.
The Bugs Group reviews its policies/procedures annually, approve this policy at each review and hold the DSL to account for its implementation.

Confidentiality and Record Keeping

All information is recorded and is shared on a need-to-know basis. All recordings under Safeguarding are only viewed by our team of DSL’s.

You should note that:
• 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
• Information must be shared on a ‘need-to-know’ basis, but you do not need consent to share information if a child is suffering, or at risk of serious harm.
• The Data Protection Act (DPA) 2018 and 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
• 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
• If staff are in any doubt about sharing information, they should speak to the designated safeguarding lead

Recognising abuse and taking action

Every member of staff working with children at The Bugs Group are advised to maintain an attitude of ‘professional curiosity and respectful uncertainty’ where safeguarding is concerned. When concerned about the welfare of a child, staff members should always act in the best interests of the child and have a responsibility to act as outlined in this policy.

Please note – in this and subsequent sections, you should take any references to the DSL to mean “the DSL”

Staff must follow the procedures set out below in the event of a safeguarding issue.

Recognising abuse and taking action

All adults will alert the DSL who will make a referral to children’s social care and/or the police immediately if a child is in immediate danger or at risk of harm.
Referrals are made based on the child’s home address. Anyone can make a referral.

Contact details are given below:
To report a child or young person at risk, if they live in Solihull, call 0121 788 4300 (Monday to Thursday 8.45am – 5.20pm, Friday 8.45am – 4.30pm).
If you are calling Solihull out of working hours (Evenings, weekends or bank holidays) please call 0121 605 6060.
To report a child or young person at risk, if they live in Birmingham, call 0121 303 1888 (Monday to Thursday 8.45am – 5.15pm, Friday 8.45am to 4.15pm)
If you are calling Birmingham out of working hours (Evenings, weekends or Bank Holidays) please call 0121 675 4806
To report a child or young person at risk, if they live in Worcester, call 01905 822666
In an emergency always call 999
Tell the DSL as soon as possible if you make a referral directly.
You can also contact the charity NSPCC on 0808 800 5000 if you need advice on the appropriate action.

All referrals must be followed up in writing on The Bugs Group Safeguarding Children Concerns Form.

All referrals must be followed up in writing on The Bugs Group Safeguarding Children Concerns Form.

West Midlands Child Protection Procedures

If a child/young person does not make a disclosure or is not in immediate danger but you are worried or have ongoing concerns about a child/young person, then this must be recorded on Safeguarding Children Concerns Form, inform the DSL to the concerns. This will/may build up the picture of significant harm. Often a picture of Neglect will build up over time. This will be monitored and reported in the same way as an immediate response/emergency.

If a child makes a disclosure to you

discloses a safeguarding issue to you, you should:
• Listen to and believe them. Remember what they are telling you.
• Allow them time to talk freely and do not ask leading questions.
• Check that you have understood correctly, what the child is trying to tell you.
• Stay calm and do not show that you are shocked, upset, angry or embarrassed.
• Tell the child they have done the right thing in telling you. Reassure them.
• Do not tell them they should have told you sooner.
• Gather the child’s wishes/views and record in the child’s words.
• Do not tell the child that what s/he experienced is dirty, naughty or bad.
• Do not promise to keep it a secret.
• Explain what will happen next and that you will have to pass this information on.
At the end of the conversation tell the child again who you are going to tell and why that person or people need to know. At The Bugs Group this will be Mrs Z Smyth – Strategic DSL.

ALL child protection concerns must be reported immediately, in detail, via Safeguarding Children Concerns Form and DSL alerted. This must be written in the child’s own words, stick to the facts, and do not add any opinion or interpretations; this document must be signed and dated, including the time it was passed on.
Be aware that the child may retract what s/he has told you. It is essential to record all you have heard.
N.B: It is not staff’s role to seek disclosures. Their role is to observe that something may be wrong, ask about it, listen, be available and try to make time to talk. You must not deal with this yourself. It is everyone’s responsibility to safeguard children.
Clear indications or disclosure of abuse must be reported to children’s social care without delay by the Designated Safeguarding Lead picking up the concern.
Children making a disclosure may do so with difficulty, having chosen carefully to whom they will speak. Listening to and supporting a child/young person who has been abused can be traumatic for the adults involved. Support for you will be available from your Designated Safeguarding Lead.

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)

Where possible, speak to the DSL first to agree a course of action.
All concerns must be recorded in writing.
If in exceptional circumstances the DSL is not available, this should not delay appropriate action being taken. 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. Share any action taken with the DSL as soon as possible.

If you discover that FGM has taken place, or a pupil is at risk of FGM

The Department for Education’s 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 pupil has already been subjected to FGM, and factors that suggest a pupil may be at risk, are set out in Appendix 4 of this policy.
Any member of staff who discovers (either through disclosure by the victim, informed by someone else or visual evidence) that an act of FGM appears to have been carried out on a child under 18 must immediately report this to the police, personally. This is a statutory duty, and staff 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 and involve children’s social care as appropriate.
The duty for staff mentioned above does not apply in cases where a pupil is at risk of FGM or FGM is suspected but is not known to have been carried out. Staff should not examine pupils.
Any member of staff who suspects a pupil is at risk of FGM or suspects that FGM has been carried out must speak to the DSL and follow our local safeguarding procedures.

If you have concerns about extremism

The Bugs Group are subject to a duty to have “due regard to the need to prevent people being drawn into terrorism” (section 26, Counter Terrorism and Security Act 2015). This is known as The Prevent Duty and is part of our companies wider safeguarding obligations.
If a child is not suffering or likely to suffer from harm, or in immediate danger, 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. Seek advice from local authority children’s social care. Make a referral to local authority children’s social care directly. Inform the DSL as soon as practically possible after the referral.
Where there is a concern, the DSL will consider the level of risk and decide which agency to make a referral to. Channel is a multi-agency approach to provide support to individuals who are at risk of being drawn into terrorist related activity. It is led by the West Midlands Police Counter-Terrorism Unit, and it aims to:
• Establish an effective multi-agency referral and intervention process to identify vulnerable individuals.
• Safeguard individuals who might be vulnerable to being radicalised, so that they are not at risk of being drawn into terrorist-related activity; and
• Provide early intervention to protect and divert people away from the risks they face and reduce vulnerability.
• The Channel programme focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. It provides a mechanism for schools to make referrals if they are concerned that an individual might be vulnerable to radicalisation. An individual’s participation in the programme is entirely voluntary at all stages.
• Schools have a duty to cooperate with the Channel programme in the carrying out of its functions, and with the Police in providing information about an individual who is referred to Channel (Section 38, Counter Terrorism and Security Act 2015).

The Department for Education also has a dedicated telephone helpline, 020 7340 7264, which you can call to raise concerns about extremism with respect to a child. You can also email [email protected]. 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 immediate danger

Think someone may be planning to travel to join an extremist group See or hear something that may be terrorist-related

If you have a mental health concern

All staff have an incredibly important role to play in supporting the mental health and wellbeing of our children and are aware that 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.
Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Staff, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.
Where children have suffered abuse and neglect, or other potentially traumatic Adverse Childhood Experiences (ACE), this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences, can impact on their mental health, behaviour, and education.
If you have a mental health concern about a child that is also a safeguarding concern, take immediate action. If you have a mental health concern that is not also a safeguarding concern, speak to the DSL to agree a course of action.

Concerns about a staff member, supply teacher or volunteer

Our aim is to provide a safe and supportive environment securing wellbeing and best possible outcomes for the children at The Bugs Group. We do recognise that sometimes the behaviour of adults may lead to an allegation of abuse being made.
If you have concerns about a member of staff, or an allegation is made about a member of staff posing a risk of harm to children, speak to the Managing Director.

Allegations of abuse made against other pupils (Child on Child Abuse)

Allegations of abuse made against other pupils (Child on Child Abuse)
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”.
We also recognise the gendered nature of peer-on-peer (children on children) abuse. However, all peer-on-peer abuse is unacceptable and will be taken seriously.
Most cases of pupils hurting other pupils will be dealt with under our behaviour policy, but this child protection and safeguarding policy will apply to any allegations that raise safeguarding concerns. This might include where the alleged behaviour:
• Is serious, and potentially a criminal offence
• Could put pupils in the group at risk
• Is violent
• Involves pupils 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 semi-nudes)
Procedures for dealing with allegations of child-on-child abuse If a child makes an allegation of abuse against another pupil:
• You must record the allegation 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 een made and any others affected) with a named person they can talk to if needed

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.
We will minimise the risk of peer-on-peer abuse by:

Challenging any form of derogatory or sexualised language or behaviour, including requesting or sending sexual images
• Being vigilant to issues that particularly affect different genders – for example, sexualised or aggressive touching or grabbing towards female pupils, and initiation or hazing type violence with respect to boys
• Ensuring children know they can talk to staff confidentially.
• Ensuring staff are trained to understand 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
• Ensure staff reassure victims that they are being taken seriously
• Ensure staff are trained to understand:
o How to recognise the indicators and signs of peer-on-peer abuse, and know how to identify it and respond to reports
o 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
o That certain children may face additional barriers to telling someone because of their vulnerability, disability, gender, ethnicity and/or sexual orientation
o 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
o The important role they have to play in preventing peer-on-peer abuse and responding where they believe a child may be at risk from it
o That they should speak to the DSL if they have any concerns.

Sharing of nudes and semi-nudes (Sexting)

This is a suggested approach based on guidance from the UK Council for Child Internet Safety for all staff and for DSLs.

Your responsibilities when responding to an incident

If you are made aware of an incident involving sexting (also known as ‘youth produced sexual imagery’), you must report it to the DSL immediately.                                                                      You must not:
• View, download or share the imagery yourself, or ask a child 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 child to delete it
• Ask the child who is 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 child 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 child 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 school staff. This meeting will consider the initial evidence and aim to determine:
• Whether there is an immediate risk to the child
• If a referral needs to be made to the police and/or children’s social care
• If it is necessary to view the imagery in order to safeguard the young person (in most cases, imagery should not be viewed)
• What further information is required to decide on the best response
• Whether the imagery 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 from devices or online services
• Any relevant facts about the children involved which would influence risk assessment
Whether to contact parents or carers of the children involved (in most cases parents 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 imagery 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 child in the imagery is under 13
• The DSL has reason to believe a child is at immediate risk of harm owing to the sharing of the imagery (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 headteacher within the child’s school, may decide to respond to the incident without involving the police or children’s social care.

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.
They will hold interviews with the children involved (if appropriate) to establish the facts and assess the risks.If at any point in the process there is a concern that a pupil has been harmed or is at risk of harm, a referral will be made to children’s social care and/or the police immediately.
Informing parents
The DSL will inform parents 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 pupil at risk of harm.
Referring to the police
If it is necessary to refer an incident to the police, this will be done by contacting a police community support officer, local neighbourhood police or dialling 101.
Recording incidents
All incidents of sharing of nudes and semi-nudes, and the decisions made in responding to them will be recorded.
Notifying parents
Where appropriate, we will discuss any concerns about a child with the child’s parents. The DSL will normally do this in the event of a suspicion or disclosure.
Other staff will only talk to parents about any such concerns following consultation with the DSL.
If we believe that notifying the parents 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 of all the children involved.

Pupils with special educational needs and disabilities (SEND)

We recognise that pupils with special educational needs and disabilities (SEND) can face additional safeguarding challenges. 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 disability without further exploration
Pupils being more prone to peer group isolation than other pupils
The potential for pupils with SEND being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs
Communication barriers and difficulties in overcoming these barriers

Pupils with a social worker

Pupils 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 attendance, 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 has a social worker, the DSL will always consider this fact to ensure any decisions are made in the best interests of the childs safety and welfare.

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 looked after legal status, contact arrangements with birth parents or those with parental responsibility, and care arrangements.

Online safety and the use of mobile technology

Staff are allowed to bring their personal phones to work for their own use but will limit such use to non-contact time when children are not present. Staff members’ personal phones will remain in their bags or cupboards during contact time with children and must be turned off or on silent.
Staff will not take pictures or recordings of pupils on their personal phones, mobile devices, or cameras.
We will follow the General Data Protection Regulation and Data Protection Act 2018 when taking and storing photos and recordings for use in the school.
Children are not allowed to use mobile phones whilst on the school site. Children who choose to bring a mobile phone onto site must have it switched off at all times and the phone given to a member of staff until the end of the day.
Any phone in the possession of a child that is switched on and/or in use will be confiscated by a member of staff immediately and kept securely for a parent to collect at a mutually convenient time. The Bugs Group will not accept any responsibility for broken/lost or stolen mobile devices that is in the child’s possession.
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.

Complaints and concerns about school safeguarding policies

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.

Record keeping

We will hold records in line with our records retention schedule.
All safeguarding concerns, discussions, decisions made and the reasons for those decisions, must be recorded in writing. If you are in any doubt about whether to record something, discuss it with the DSL.
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.
All paper-based records are held securely. These will only be available to DSL team.
All safeguarding records are only accessible to DSL team.


All staff

All staff members will undertake safeguarding and child protection training at induction to ensure they understand the company’s safeguarding systems and their responsibilities and can identify signs of possible abuse or neglect. This training will be regularly updated.
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 online safety as required, but at least annually.

The DSL and deputies

The DSL will undertake 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 .
They will also undertake Prevent awareness training.

Monitoring arrangements

This policy will be reviewed annually by DSL’s.

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

Appendix : 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 cyberbullying), 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 assault 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.
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.

Domestic Abuse is an incident or pattern of incidents, which may not always be physical violence and can include:

  • coercive control and ‘gaslighting’
  • economic abuse
  • online abuse
  • threats and intimidation
  • emotional abuse
  • sexual abuse

This can impact in children through seeing, hearing or experiencing the effects of domestic abuse and/or experiencing it through their own intimate relationships.

Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, religion, socio- economic status, sexuality or background.



All staff, but especially the designated safeguarding lead should consider whether children are at risk of abuse or exploitation in situations outside their families. Extra-familial harms take a variety of different forms and children can be vulnerable to multiple harms including (but not limited to) sexual abuse (including harassment and exploitation), domestic abuse in their own intimate relationships (teenage relationship abuse), criminal exploitation, serious youth violence, county lines, and radicalisation.

Appendix 2: Allegations of abuse made against staff

This section is based on ‘Section 1: Allegations that may meet the harms threshold’ in part 4 of Keeping Children Safe in Education.

This section of this policy applies to all cases in which it is alleged that a current member of staff has:

  • Behaved in a way that has harmed a child, or may have harmed a child, and/or
  • Possibly committed a criminal offence against or related to a child, and/or
  • Behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children, and/or
  • Behaved or may have behaved in a way that indicates they may not be suitable to work with

It applies regardless of whether the alleged abuse took place inside or outside of work.

We will deal with any allegation of abuse against a member of staff in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation.

A ‘case manager’ will lead any investigation. This will be the managing director.

Our procedures for dealing with allegations will be applied with common sense and judgement.

Suspension of the accused until the case is resolved

Suspension will not be the default position and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that it might be grounds for dismissal. In such cases, we will only suspend an individual if we have considered all other options available and there is no reasonable alternative.

Definitions for outcomes of allegation investigations

  • Substantiated: there is sufficient evidence to prove the allegation
  • Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive
  • False: there is sufficient evidence to disprove the allegation
  • Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation (this does not imply guilt or innocence)
  • Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made.


Procedure for dealing with allegations

In the event of an allegation that meets the criteria above, the ‘case manager’ – will take the following steps:

  • Conduct basic enquiries in line with local procedures to establish the facts to help determine whether there is any foundation to the allegation before carrying on with the steps below.
  • Discuss the allegation with the designated officer at the local authority. This is to consider the nature, content and context of the allegation and agree a course of action, including whether further enquiries are necessary to enable a decision on how to proceed, and whether it is necessary to involve the police and/or children’s social care services. (The case manager may, on occasion, consider it necessary to involve the police before consulting the designated officer – for example, if the accused individual is deemed to be an immediate risk to children or there is evidence of a possible criminal offence. In such cases, the case manager will notify the designated officer as soon as practicably possible after contacting the police).
  • Inform the accused individual of the concerns or allegations and likely course of action as soon as possible after speaking to the designated officer (and the police or children’s social care services, where necessary). Where the police and/or children’s social care services are involved, the case manager will only share such information with the individual as has been agreed with those agencies.
  • Where appropriate (in the circumstances described above), carefully consider whether suspension of the individual from contact with children is justified or whether alternative arrangements can be put in place. Advice will be sought from the designated officer, police and/or children’s social care services, as
  • If immediate suspension is considered necessary, agree, and record the rationale for this with the designated officer. The record will include information about the alternatives to suspension that have been considered, and why they were rejected. Written confirmation of the suspension will be provided to the individual facing the allegation or concern within 1 working day, and the individual will be given a named contact at the school and their contact details.
  • If it is decided that no further action is to be taken in regard to the subject of the allegation or concern, record this decision and the justification for it and agree with the designated officer what information should be put in writing to the individual and by whom, as well as what action should follow both in respect of the individual and those who made the initial
  • If it is decided that further action is needed, take steps as agreed with the designated officer to initiate the appropriate action in school and/or liaise with the police and/or children’s social care services as appropriate.
  • Provide effective support for the individual facing the allegation or concern, including appointing a named representative to keep them informed of the progress of the case and considering what other support is appropriate.
  • Inform the parents or carers of the child/children involved about the allegation as soon as possible if they do not already know (following agreement with children’s social care services and/or the police, if applicable). The case manager will also inform the parents or carers of the requirement to maintain confidentiality about any allegations made against staff (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of staff will be advised to seek legal advice.
  • Keep the parents or carers of the child/children involved informed of the progress of the case (only in relation to their child – no information will be shared regarding the staff member).
  • Make a referral to the DBS where it is thought that the individual facing the allegation or concern has engaged in conduct that harmed or is likely to harm a child, or if the individual otherwise poses a risk of harm to a child.


If it is appropriate to refer the case to local authority children’s social care or the police, the DSL will make the referral or support you to do so.

If you make a referral directly 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.

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