1 INTRODUCTION
Located in over 570 acres of picturesque North Bedfordshire countryside, Keysoe International is a highly esteemed destination known around the world for its professional and welcoming environment.
As well as being a highly esteemed equestrian and events centre of excellence complete with an Indoor arena, international size outdoor arena, cross country course, a Café, and bar, we also offer:
o Alternative Education Provision, Work-Based Learning, and Animal Assisted Therapy (through Keysoe Cuddle Therapy Ponies CIC)
o Venue hire, parties, and catering
o Clinics, courses, and summer camps

2 PURPOSE
Sadly, abuse is prevalent in Society, and often, it is the most vulnerable people who are commonly victims of abuse. It is a basic human right for a person to live in a safe environment away from harm or abuse, and they should, in no circumstances, be exploited. Therefore, safeguarding procedures are a pivotal component in ensuring these individuals are protected.
As a provider of services to children and vulnerable adults, Keysoe International Limited and Keysoe Cuddle Therapy Ponies CIC (collectively referred to as Keysoe International Ltd.), we acknowledge our duty of care and are committed to safeguarding these groups.

3 SCOPE
The policy applies to all staff, including employees, agency staff, student learners, volunteers and self-employed colleagues (referred to as staff throughout), and, in part, those who use our services or engage with us (referred to as participants throughout).
This policy does not, however, replace the responsibilities of those third parties who also have a duty of care to participants, for example, referring schools, referring local authorities, and the operators of third-party sites we visit during off-site visits.
Participants, parents, guardians, carers and any stakeholder can obtain a copy of this policy on request.

4 DEFINITIONS
KCSiE: Keeping Children Safe in Education (https://www.gov.uk/government/publications/keeping-children-safe-in-education–2)
LADO: Local Authority Designated Officer
DSLs: Designated Safeguarding Leads
Safeguarding means protecting a citizen’s health, wellbeing and human rights, enabling them to live free from harm, abuse and neglect. (NHS) The term ‘safeguarding’ embraces both the act of child/vulnerable adult protection and a preventative approach to keeping these groups safe.
Children: For the purposes of safeguarding, a child is anyone under the age of 18. (KCSiE 2023) Note: even if a child has reached 16 years of age and is living independently, in further education, a member of the armed forces, in hospital or in custody in the secure estate, they are still legally children and should be given the same protection and entitlements as any other child (Department for Education, 2023).
Adults: Are individuals who are 18 or over.
Vulnerable Adults: Any adult (person over the age of 18) who may be in need of extra support. This is because they are elderly or have a learning disability, physical disability, sensory impairment or mental health problems. They also may be unable to take care of themselves or protect themselves from harm.
DBS Check: A Disclosure and Barring Service check (previously known as CRB or criminal record checks) that helps employers make safer recruitment decisions. DBS also maintains the Adults’ and Children’s Barred Lists, and makes considered decisions as to whether an individual should be included on one or both of these lists and barred from engaging in regulated activity.

5 UNDERPINNING LEGISLATION AND GUIDANCE
Laws
1. Children Act 1989: Establishes the legal framework for the protection and welfare of children.
2. Children Act 2004: Introduced further child welfare provisions and the concept of integrated services.
3. Safeguarding Vulnerable Groups Act 2006: Establishes the framework for vetting individuals working with children and vulnerable adults.
4. Children and Families Act 2014: Focuses on children’s welfare, including adoption and family justice.
5. Care Act 2014: Sets out the duties for the care and support of adults and the safeguarding of adults from abuse or neglect.
6. Protection of Freedoms Act 2012: Amends the Safeguarding Vulnerable Groups Act 2006, including changes to vetting and barring arrangements.
7. Mental Capacity Act 2005: Provides a framework for making decisions on behalf of adults who lack the capacity to make decisions for themselves.
8. The Children and Social Work Act 2017: Aims to improve support for looked-after children, care leavers, and the safeguarding of children.
Guidance
1. Working Together to Safeguard Children: Statutory guidance on inter-agency working to safeguard and promote the welfare of children.
2. Care and Support Statutory Guidance (under the Care Act 2014): Provides guidance on how care and support should be provided to adults.
3. Keeping Children Safe in Education (KCSIE): Statutory guidance for schools and colleges on safeguarding children.
4. Safeguarding Vulnerable Groups Act 2006 (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009: Details the criteria for which individuals should be considered for barring from work with children and vulnerable adults.

6 ROLES AND RESPONSIBILITIES
6.1 Senior Management Team
The Senior Management team have a strategic responsibility for our safeguarding arrangements and will comply with their duties under legislation.
Their roles and responsibilities include but are not limited to:
o Ensuring that safeguarding and child protection are at the forefront and underpin all relevant aspects of our operations.
o Having due regard have regard for up-to-date safeguarding legislation, guidance, best practice, and the local multi-agency safeguarding requirements.
o Ensuring that our safeguarding policies and procedures are regularly reviewed and are effective.
o Ensuring that appropriate resources are allocated for staff safeguarding training.
o Ensuring that appropriate action is taken in a timely manner where safeguarding concerns are raised.
o Ensuring that this policy and any related policies, procedures and guidance are understood and followed by all staff.
6.2 Designated Safeguarding Leads (DSLs)
The DSLs have overall responsibility for the day-to-day oversight of safeguarding and child protection systems. Their role includes but is not limited to:
o Acting as the central contact point for all staff to discuss any safeguarding concerns.
o Maintaining a confidential recording system for safeguarding and child protection concerns.
o Coordinating safeguarding action.
o Liaising with other agencies and professionals.
o Helping promote positive outcomes by sharing information about the welfare, safeguarding, and child protection issues that children and vulnerable adults have.
o Ensuring all staff access appropriate safeguarding training and relevant updates in line with the recommendations within KCSiE and other relevant legislative or regulatory guidance.
6.3 Members of Staff
Our staff play a particularly important role in safeguarding as they are in a position to both promote welfare and identify concerns early.
All members of staff have a responsibility to:
o Provide a safe environment in which every participant can thrive.
o Be aware of the indicators of abuse and neglect so that they can identify concerns.
o Know what to do if a child or vulnerable adult tells them that they are being abused, neglected, or exploited.
o Be prepared to identify children who may benefit from early help.
o Understand and follow our safeguarding policy and procedures.
o Undertake regular and appropriate training, which is regularly updated.
o Know how to maintain an appropriate level of confidentiality.
o Reassure those who report concerns that they are being taken seriously and that they will be supported and kept safe.

7 POLICY
7.1 Staff Training
7.1.1 DSLs
The DSL will undergo appropriate and specific training to provide them with the knowledge and skills required to carry out their role. Deputy DSLs will be trained to the same standard as the DSL.
The DSLs’ training will be updated formally at least every two years, but their knowledge and skills will be updated through a variety of methods (e.g. via bulletins, meetings or further reading) at regular intervals and at least annually.
7.1.2 All Staff Members
Every member of staff is provided with the relevant training so that they know:
o the name of the Designated Safeguarding Lead/Deputies and their role;
o how to identify the signs of abuse and neglect;
o that participants may not feel ready or know how to tell someone that they are being abused and/or they may not recognise their experiences as harmful;
o how to pass on and record concerns;
o their role in the early help process;
o the process for making referrals to children’s and adult’s social care;
o the safeguarding response to children who go missing in education.
All staff members interacting with children and vulnerable adults undergo safeguarding and child protection training at induction. Staff training is regularly updated, and in addition to this training, all staff members receive regular safeguarding and child protection updates from the DSLs as required, but at least annually.
In addition, all staff involved in alternative provision must read and understand Part 1 and Annex A of Keeping Children Safe in Education.
Selected staff (those who work directly with children and vulnerable adults) will complete Level 2 certified safeguarding training courses.
7.2 Safe Staffing
7.2.1 Advertising
All adverts should include the following:
o A job description and specification.
o A statement as to Keysoe International Ltd’s commitment to safeguarding and promoting the welfare of children and vulnerable adults.
Adverts for roles subject to a DBS/International check should include the following:
o A statement that safeguarding checks will be undertaken.
o A statement as to the safeguarding responsibilities of the post as per the job description and personal specification.
o A statement as to whether the post is exempt from the Rehabilitation of Offenders Act (ROA) 1974. The amendments to the ROA 1974 (Exceptions Order 1975, (amended 2013 and 2020)) provide that when applying for certain jobs and activities, certain spent convictions and cautions are ‘protected’, so they do not need to be disclosed to employers, and if they are disclosed, employers cannot take them into account.
o A statement as to whether a role involves engaging in regulated activity and that it is an offence to apply for the role if the applicant is barred from engaging in that regulated activity.
7.2.2 Applications
All applicants must provide the following:
o Their personal details, current and former names, current address, and National Insurance number.
o Details of their present (or last) employment and reason for leaving.
o Full employment history (since leaving school, including education, employment, and voluntary work), including reasons for any gaps in employment.
o Qualifications, the awarding body, and the date of award (if applicable).
o Details of referees/references (see below for further information).
o A statement of the personal qualities and experience that the applicant believes are relevant to their suitability for the post advertised and how they meet the person specification.
7.2.3 Shortlisting
The Senior Management team will review all applications and supplementary evidence and shortlist candidates for interview.
Shortlisting decisions are based on evidence that the applicant has met the requirements of the person specification.
When shortlisting the Senior Management team, will:
o Consider any inconsistencies and look for gaps in employment and reasons given for them.
o Explore all potential concerns.
o Complete cursory due diligence checks where a concern is raised.
Shortlisted candidates applying for a teaching or therapy role which is classed as regulated will be asked to complete a self-declaration of their criminal record or information that would make them unsuitable to work with children and/or vulnerable adults.
7.2.4 Online Checks
Where appropriate, we will carry out an online search as part of our due diligence on the shortlisted candidates. This may help identify any incidents or issues that have happened and are publicly available online, which we might want to explore with the applicant at interview. We will inform shortlisted candidates that online searches may be done as part of due diligence checks.
7.2.5 Interviewing
The interview panel will usually comprise members of the Senior Management team and at least one DSL.
During interviews, the panel must bring a copy of the role description and person specification for reference, and any relevant information from the interview must be captured on the interview proforma.
Any potential candidate must be advised during the interview that failure to meet any of the following criteria will deem them inappropriate for the role or will result in any subsequent offer being withdrawn:
o Meeting the job description and person specification.
o Providing the required legitimate identity documents and proof of qualifications (where required).
o Obtaining two satisfactory references.
o Obtaining a satisfactory DBS and/or Internation Police check (where required).
Candidates must have equal opportunities when applying for a position, and the interviewees must outline legal and legitimate reasons why a candidate has been successful or unsuccessful. Reasons why an individual is offered a position over another must be decided using objective information gathered and must be documented.
7.2.6 Proof of Qualifications
Therapists and other professionals required to hold a formal qualification will be required to provide Keysoe International Ltd with proof of qualifications, which we will seek to verify.
7.2.7 References
Keysoe International Ltd. requires all applicants to provide the names and contact details of two referees.
Referees will be contacted and must state that:
o The applicant is known to them, and
o The applicant is thought to be suitable for employment in the specified role, and
o The applicant is of good character; and
o They know of no reason the applicant should not work with children or vulnerable individuals.
At least one referee should be a professional person and the other an individual able to provide a character reference. Neither referee must be related to the applicant
For regulated positions, Keysoe International Ltd. will:
o Not accept open references, e.g., to whom it may concern.
o Not rely on applicants to obtain their own references.
o Ensure any references are from the candidate’s current employer and have been completed by a senior person with appropriate authority (if the referee is school or college-based, the reference should be confirmed as accurate in respect of any disciplinary investigations).
o Obtain verification of the individual’s most recent relevant period of employment where the applicant is not currently employed.
o Secure a reference from the relevant employer from the last time the applicant worked with children or vulnerable adults (if not currently working with children or vulnerable adults). If the applicant has never worked with children or vulnerable adults, then ensure a reference from their current employer.
o Always verify any information with the person who provided the reference.
o Ensure electronic references originate from a legitimate source.
o Contact referees to clarify content where information is vague or insufficient information is provided.
o Compare the information on the application form with that in the reference and take up any discrepancies with the candidate.
o Establish the reason for the candidate leaving their current or most recent post.
o Ensure any concerns are satisfactorily resolved before the appointment is confirmed.
7.2.8 Medical Suitability
Certain roles require a level of physical fitness and/or mental resilience, and therefore, Keysoe International Ltd. reserves the right to enquire as to an applicant’s medical suitability.
Where reasonable adjustments are requested, the company will do its utmost to accommodate the applicant.
7.2.9 Identity Checks and Right to Work
Staff working for Keysoe International Ltd. are required to provide the following and have the information verified before any offer of employment is made:
o Original Photographic Identity (passport or overseas alternative).
o Proof of National Insurance Number.
o UK Bank Account or Building Society Account details.
o Original Right to Work in UK documentation (if applicable) or access to the UK Immigration portal to confirm their status.
Photographic identity documents must be checked to ensure that the candidate is a true likeness to the photograph displayed.
Staff subject to a DBS check will be required to provide appropriate identification documents defined by the DBS ID Guidance: https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-1-july-2021
7.2.10 DBS Checks
An enhanced DBS check is mandatory before any offer of employment for a regulated position is made.
Keysoe International Ltd. makes every subject of a criminal record check submitted to DBS aware of the existence of the code of practice and makes a copy available on request.
Where a DBS check is required, Keysoe International Ltd. will finance the check. However, applicants must share the information with Keysoe International Ltd.
Any criminal history disclosed on the DBS Certificate will be reviewed, and any formal offer made will depend on the nature of the offence, the number of offences, and the time which has passed since the offences occurred.
Keysoe International Ltd. undertakes to discuss any matter revealed on a DBS Certificate with the applicant before withdrawing a conditional offer of employment.
Where any checks indicate that the applicant is unsuitable for a position, they will be informed in writing of the reason for the withdrawal and their right to appeal.
7.2.11 Checks for Existing Staff
We will carry out new checks on existing staff in the following circumstances:
i) Where an individual moves from an activity that was not regulated into a post which is considered to be regulated.
ii) Where there has been a break in service of 12 weeks or more.
iii) Where there are concerns about their suitability to work with children/vulnerable adults.
7.2.12 Overseas Police Checks
Following best practice, staff in regulated positions who have lived or worked overseas for a substantial amount of time may be subject to an overseas police check in addition to a DBS check.
The following Gov.UK website details how may obtain an overseas police check and provides information on individual countries and states by alphabetical order: https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants
7.2.13 Ongoing Checks
Ongoing DBS checking is also mandatory, whether through the Update Service or one-off annual DBS checking. Refusing to comply with a request for a DBS check may result in disciplinary action.
Keysoe International Ltd. relies on its staff to uphold the good name of the organisation and is responsible for ensuring that colleagues subject to DBS checks report to the Senior Management team any arrests, criminal proceedings, or upcoming court cases which affect their suitability for the role.
Following disclosure, we will re-assess the suitability of the staff member as it would for an applicant for a new position.
Individuals failing to provide such information will be disciplined and may be subject to summary dismissal or immediate severance of any agency, service, or contractor agreement.
7.2.14 Duty to report to the Disclosure and Barring Service
If an allegation is made and investigated and has foundation, we will ensure we have consulted the referral duty criteria in the DBS referral guidance. (Appx 19)
We have a legal duty to make a referral to the DBS where we remove an individual from regulated activity and believe the individual has
i) Engaged in relevant conduct in relation to children and/or adults; and/or
ii) Satisfied the harm test in relation to children and/or vulnerable adults; and/or
iii) Been cautioned or convicted of a relevant (automatic barring either with or without the right to make representations) offence. (Appx 20)
The DBS will consider whether to bar the individual.
7.2.15 Agency Workers
We will undertake written notification from any agency or third-party organisation that they have carried out the same checks as an organisation would otherwise perform on any individual who will be working at a school or college.
If an agency or organisation has obtained an enhanced DBS certificate before the person is due to begin work at Keysoe International Ltd., which has disclosed any matter or information, or any information was provided to the employment business, we will obtain a copy of the certificate from the agency.
We will check that the person presenting themselves for work is the same person to whom the checks have been made.
7.2.16 Contractors
Where we use contractors to provide services, we will set out our safeguarding requirements in the contract between us and them.
We will ensure any contractor or employee of the contractor working for us has been subject to the appropriate level of DBS check.
In cases where the individual does not have the opportunity for regular contact with children or vulnerable adults, we will decide whether a basic DBS check will be appropriate.
7.2.17 Trainees and Volunteers
Where applicants for trainees or volunteers are accepted, we will ensure all necessary checks are carried out and obtain an enhanced DBS check with a barred list check as we would with an employee.
7.2.18 Recording Recruitment and Selection Information
Keysoe International Ltd. maintains a single central record detailing checks carried out, which is readily available should an inspecting body wish to inspect it.
Individuals failing to provide such information will be disciplined and may be subject to summary dismissal or immediate severance of any agency, service, or contractor agreement.
7.2.14 Duty to report to the Disclosure and Barring Service
If an allegation is made and investigated and has foundation, we will ensure we have consulted the referral duty criteria in the DBS referral guidance. (Appx 19)
We have a legal duty to make a referral to the DBS where we remove an individual from regulated activity and believe the individual has
i) Engaged in relevant conduct in relation to children and/or adults; and/or
ii) Satisfied the harm test in relation to children and/or vulnerable adults; and/or
iii) Been cautioned or convicted of a relevant (automatic barring either with or without the right to make representations) offence. (Appx 20)
The DBS will consider whether to bar the individual.
7.2.15 Agency Workers
We will undertake written notification from any agency or third-party organisation that they have carried out the same checks as an organisation would otherwise perform on any individual who will be working at a school or college.
If an agency or organisation has obtained an enhanced DBS certificate before the person is due to begin work at Keysoe International Ltd., which has disclosed any matter or information, or any information was provided to the employment business, we will obtain a copy of the certificate from the agency.
We will check that the person presenting themselves for work is the same person to whom the checks have been made.
7.2.16 Contractors
Where we use contractors to provide services, we will set out our safeguarding requirements in the contract between us and them.
We will ensure any contractor or employee of the contractor working for us has been subject to the appropriate level of DBS check.
In cases where the individual does not have the opportunity for regular contact with children or vulnerable adults, we will decide whether a basic DBS check will be appropriate.
7.2.17 Trainees and Volunteers
Where applicants for trainees or volunteers are accepted, we will ensure all necessary checks are carried out and obtain an enhanced DBS check with a barred list check as we would with an employee.
7.2.18 Recording Recruitment and Selection Information
Keysoe International Ltd. maintains a single central record detailing checks carried out, which is readily available should an inspecting body wish to inspect it.
o Carefully considering the practicalities around safety, for example, making it clear who may and may not collect participants from sessions or determining if particular participants are suitable for certain group sessions (based on past experience, criminal history, past abuse, etc.).
o Ensuring that participants are supported in the most appropriate ways, for example, by ensuring that staff are able to pick up on signs of abuse which may not be obvious or changing their communication methods to best allow participants to disclose any concerns.
7.2.19 Data Protection
Keysoe International Ltd. will only ask an individual to provide details of convictions and cautions that we are legally entitled to know about.
Keysoe International Ltd. will abide by legislation detailing on what grounds a DBS certificate at an enhanced level can legally be requested and how this information is processed, including the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 as amended and, where appropriate, the Police Act Regulations as amended.
Criminal records information will only be used to assess the suitability of an applicant for a specific position of trust for which they have applied.
All certificates and information about criminal records will be kept securely.
Information will only be released to staff members who are entitled to see it as part of their role.
Criminal records information will be destroyed once it is no longer needed.
7.2.20 Confidentiality
Keysoe International Ltd. will deal with all matters related to DBS and/or other checks sensitively and with due respect for the privacy of all individuals involved.
All staff must treat as confidential any information communicated to them in connection with the management of such checks.
Breaches of the requirement to maintain confidentiality related to such matters will be taken seriously and may result in disciplinary action.
Staff are asked to immediately report any breaches of confidentiality to the Senior Management team.
7.2.21 Failure to Comply
Failure to reveal information that is directly relevant to a position will lead to withdrawal of an offer of employment or termination of employment/other working or volunteering agreement.
Where an applicant has applied for a regulated role and is found to be barred from engaging in regulated activity working with children, the appropriate authorities will be informed.
7.3 Being Proactive in Safeguarding
To ensure that our approach to safeguarding is both proactive and reactive, we are committed to:
o Promoting an open culture underpinned by a zero-tolerance policy towards abuse and neglect.
o Keeping up-to-date with local and national news, guidance and best practice and adapting our policy to align with updates.
o Training staff, educating participants and their families around safeguarding and raising awareness of what to do if they have a concern.
o Ensuring that we take a participant-centred approach to safeguarding, by listening, recognising autonomy and respecting their wishes (wherever possible).
o Completing needs assessments and risk assessments as necessary to highlight where individuals may need additional support and/or protection.
7.4 Terrorism and the Prevent Duty
Keysoe International Ltd. will have due regard to and will follow guidance on the Prevent duty.
Staff with concerns relating to radicalisation or extremism should immediately inform the DSLs.
Staff and participants are reminded that radicalisation and extremism must not be confused with religious beliefs that differ from their own and that we will not tolerate any hate speech or discrimination.
7.5 Positions of Trust
A Position of Trust is a position held by any person required to have direct contact with an adult or child, and, due to the nature of their role, they are in a position to exercise authority, power and control over them.
For example, people working for or on behalf of:
a. Social Care;
b. Health Services;
c. The Police and criminal justice system;
d. Housing;
e. Education.
The law changed in 2022 to extend the definition to include sports coaches.
This means that under the Sexual Offences Act 2003, in England and Wales, it is a criminal offence for a person in a position of trust to have a sexual or intimate relationship with a child under 18 years old, even if the relationship is deemed consensual.
7.6 Early Help
Any child may benefit from early help, but staff should be particularly alert to the potential need for early help for a child who:
o Is disabled or has certain health conditions and has specific additional needs.
o Has special educational needs (whether or not they have a statutory Education, Health and Care Plan).
o Has a mental health need.
o Is a young carer.
o Is showing signs of being drawn into anti-social or criminal behaviour, including gang involvement and association with organised crime groups or county lines.
o Is frequently missing/goes missing from care or from home.
o Is at risk of modern slavery, trafficking, sexual or criminal exploitation.
o Is at risk of being radicalised or exploited.
o Has a family member in prison or is affected by parental offending.
o Is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse.
o Is misusing alcohol and other drugs themselves.
o Has returned home to their family from care.
o Is at risk of honour-based abuse such as Female Genital Mutilation or Forced Marriage.
o Is a privately fostered child.
o Is persistently absent from education (for whole or part days).
Where early help may be beneficial, the staff member should inform the DSLs, who will make a referral where appropriate.
For more information on Early Help, see: https://www.bedford.gov.uk/social-care-health-and-community/children-young-people/help-for-families/early-help/
7.7 Teaching Safeguarding
Our staff will inform all participants how they may seek help and/or report any concerns related to safeguarding or welfare issues. This guidance will be fully inclusive and developed to be age and stage of development appropriate (especially when considering the needs of children with SEND and other vulnerabilities).
7.8 Site Security
Whilst our site is covered by CCTV and has designated private areas, all staff members have a responsibility to ensure our buildings and grounds are secure and to report concerns that may come to light.
We check the identity of all participants and visitors entering the Therapy and Well-Being Centre. Any individual in this area who is not known or identifiable will be challenged for clarification and reassurance.
We will not accept the behaviour of any participant, parent, carer or anyone else that threatens security or leads others, child or adult, to feel unsafe. Such behaviour will be treated as a serious concern and may result in a decision to refuse the person access to the site.
7.9 Supervision
Participants will be afforded the appropriate level of supervision whilst at the Keysoe Therapy and Well-Being Centre.
As we provide activities, therapy and alternative education to a diverse group of adults and children with varying abilities, the level of supervision required will vary and will wholly depend on the needs of the participants. Therefore, staff-to-participant ratios will be determined via a risk/needs assessment.
Where a one-to-one ratio is deemed appropriate, this will be enforced.
It must be noted that our staff do not provide personal care or administer medications. Therefore, participants who need support with these will need to be accompanied by a responsible adult who can meet their needs.
7.10 Equality and Diversity
Keysoe International Ltd. will ensure all participants and stakeholders, regardless of age, ability or disability, gender, race, religion, ethnic origin, sexual orientation, marital or gender status, have the right to be protected from abuse and that their rights, dignity and worth are always respected.
7.11 Record Keeping
7.11.1 Safeguarding Records
All concerns, discussions and decisions made and the reasons for those decisions must be recorded in writing (signed and dated).
Records should include information in relation to the date, the time, the place where the alleged abuse happened, your name and the names of others present, the name of the complainant (if known) and, where different, the name of the individual who has allegedly been abused (if known), the nature of the alleged abuse, a description of any injuries observed, the account which has been given of the allegation, and the name of the person at the agency and/or third-party to whom the concern was passed onto (if relevant).
Records must also reflect if consent was or was not obtained and, if relevant, why the concern was reported if consent was withheld.
All safeguarding-related information is kept securely (either in a locked filing cabinet in a secure office or on a secure server) for no longer than necessary in accordance with The Data Protection Act and GDPR.
7.11.2 Other Records
We will continue to support any participant leaving our service about whom there have been concerns by ensuring that all appropriate information, including Safeguarding and welfare concerns, is forwarded under confidential cover to the referrer (school, college, local authority, SENCO, etc.) and/or new provider of education as a matter of priority.
We will ensure that we have at least two emergency contacts for every participant in case of emergencies and/or welfare concerns.
We will keep up-to-date and accurate training records.
7.12 Confidentiality
All documentation relating to incidents or allegations of people being harmed or placed at risk of harm will be kept and treated confidentially and in accordance with the Data Protection Act 1998 (DPA) and UK GDPR 2021.
The Data Protection Act and UK GDPR do not prevent the sharing of information for the purposes of keeping children safe and promoting their welfare. Similarly, there are legitimate reasons why personal and sensitive data may be shared with third parties where there are safeguarding concerns relating to vulnerable adults, whether the adult consents or not.
If in any doubt about sharing information, staff should speak to the DSLs. Fears about sharing information must not be allowed to stand in the way of the need to safeguard and promote the welfare of children and vulnerable adults.
7.13 Inter-Agency Working
We recognise the importance of multi-agency working and are committed to working alongside partner agencies to provide a coordinated response to promote children and adult welfare and protect these groups from harm. To do this, we will:
o Develop and promote effective working relationships with other agencies, including agencies providing early help services to children, the Police and Social Care.
o Ensure that relevant staff members participate in multi-agency meetings, conferences, forums, etc.
o Participate in local safeguarding reviews, file audits, etc., as and when required to do so by our local Safeguarding Partnerships.
o Ensure that we effectively communicate with referrers (the local authority, schools, colleges, etc.) and others involved in providing care and/or support for our participants to ensure that we have a joined-up approach to safeguarding.

8 SAFEGUARDING CHILDREN POLICY
Safeguarding and promoting the welfare of children is defined for the purposes of this guidance as:
o Protecting children from maltreatment.
o Preventing impairment of children’s health or development.
o Ensuring that children grow up in circumstances consistent with the provision of safe and effective care.
o Taking action to enable all children to have the best outcomes.
(KCSiE)
For more information on child abuse and the signs to look out for visit:
o https://www.beds.police.uk/advice/advice-and-information/caa/child-abuse/what-is-child-abuse/
o https://safeguardingbedfordshire.org.uk/p/what-is-abuse-neglect/what-is-abuse-and-neglect
o https://learning.nspcc.org.uk/child-abuse-and-neglect/
8.1 Types of Abuse: Children
Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology can be used to facilitate offline abuse. Children may be abused by an adult or adults or other children.
Physical Abuse
Physical abuse is a form of abuse which may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, or otherwise causing physical harm to a child on purpose. Physical harm may also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness in a child.
Emotional Abuse
Emotional abuse is the persistent emotional maltreatment of a child to cause severe and persistent adverse effects on the child’s emotional development. It may involve:
o Conveying to children that they are worthless or unloved, inadequate, or valued only as far as they meet the needs of another person.
o Not giving the child opportunities to express their views, deliberately silencing them, or ridiculing what they say or how they communicate.
o Imposing age or developmentally inappropriate expectations on children. These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction.
o Seeing or hearing the ill-treatment of another.
o Serious bullying (including cyberbullying).
o Causing children frequently to feel frightened or in danger.
o Exploiting and corrupting children.
Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Neglect
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.
Once a child is born, neglect may involve a parent failing to fulfil any of the following:
o Provide adequate food, clothing, and shelter (including exclusion from home or abandonment).
o Protect a child from physical and emotional harm or danger.
o Ensure adequate supervision (including the use of inadequate caregivers).
o Ensure access to appropriate medical care or treatment.
It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Potential Risk of Harm to an Unborn Child
The parents’ background or current behaviour may indicate that significant harm to an unborn child is likely.
Examples of circumstances where this may be the case include:
o Where a parent has a conviction for harming another child.
o Where another child has been removed from the care of one of the parents.
o Where a parent’s lifestyle is such that there is the likelihood of significant harm to the child, for example, exposure to domestic abuse, severe emotional, behavioural, or mental health difficulties, or dependency on drugs, alcohol, or other substances.
Sexual Abuse
When a child or young person is sexually abused, they’re forced (do not consent), tricked or manipulated into sexual activities. They might not understand that what’s happening is abuse or that it’s wrong for the abuser to do this to them.
Sexual abuse can happen anywhere, can happen in person or online, and includes both contact and non-contact abuse.
Harmful sexual behaviour: Children’s sexual behaviour exists on a wide continuum, ranging from normal and developmentally expected to inappropriate, problematic, abusive, and violent. Problematic, abusive, and violent sexual behaviour is developmentally inappropriate and may cause developmental damage. A useful umbrella term is “harmful sexual behaviour” (HSB). The term has been widely adopted in child protection and is used in this advice. HSB can occur online and/or face-to-face and can also occur simultaneously between the two. HSB should be considered in a child protection context.
When considering HSB, both ages and the stages of development of the children are critical factors. Sexual behaviour between children can be considered harmful if one of the children is much older, particularly if there is more than two years difference or if one of the children is pre-pubescent and the other is not. However, a younger child can abuse an older child, particularly if they have power over them, for example, if the older child is disabled or smaller in stature.
What is consent? Consent is about having the freedom and capacity to choose.
Consent to sexual activity may be given to one sort of sexual activity but not another, e.g., to vaginal but not anal sex or penetration with conditions such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if they agree by choice to that penetration and has the freedom and capacity to make that choice.
In the UK:
o A child under the age of thirteen can never consent to any sexual activity.
o The age of consent is sixteen.
o Sexual intercourse without consent is rape.
Child-on-child abuse (peer abuse) is most likely to include, but may not be limited to:
o Bullying (including cyberbullying, prejudice-based and discriminatory bullying).
o Abuse in intimate personal relationships between children (sometimes known as ‘teenage relationship abuse’).
o Physical abuse (which may include an online element which facilitates, threatens and/or encourages physical abuse).
o Sexual violence such as rape and sexual assault; (this may include an online element which facilitates, threatens and/or encourages sexual violence).
o Non-consensual and consensual image sharing of children.
o Sexual harassment, such as sexual comments, remarks, jokes, and online sexual harassment, which may be standalone or part of a broader pattern of abuse.
o Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or engage in sexual activity.
o Consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth-produced sexual imagery).
o ‘Upskirting’ – typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks.
o Initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group).
Child Sexual Exploitation
Child sexual exploitation is also a form of child sexual abuse. It occurs when an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of eighteen into sexual activity (a) in exchange for something the victim needs or wants and/or (b) for the financial advantage or increased status of the perpetrator or facilitator.
The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.
Child Criminal Exploitation
Child criminal exploitation occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18 into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or another advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence. This includes child slavery and child trafficking.
County lines is a form of criminal exploitation where urban gangs persuade, coerce or force children and young people to store drugs and money and/or transport them to suburban areas, market towns and coastal towns (Home Office, 2018). It can happen in any part of the UK and is against the law and a form of child abuse.
Human Trafficking
Child trafficking is a very serious crime which can have a devastating and lasting impact on its victims. Children can be trafficked into, within and out of the UK.
Children are trafficked for many reasons, including sexual exploitation, domestic servitude, labour, benefit fraud and involvement in criminal activity.
Extremism and Radicalisation
Radicalisation is targeting the vulnerable by seeking to promote division between communities based on race, faith, or denomination, justify discrimination towards women and girls, persuade others that minorities are inferior, or argue against the primacy of democracy and the rule of law in our Society. This may lead to extremism and criminal acts.
Children may also be radicalised through grooming or coercion.
Domestic Abuse
Young people aged 16 and 17 may be victims of domestic abuse, and children under the age of 16 may be victims if they are exposed to the abuse, including psychological, physical, sexual, financial, and/or emotional abuse.
FGM
Includes: Alteration or Removal of parts of the Female Genitalia for Non-surgical or Religious beliefs.
It is often referred to as Female Circumcision, cutting or Sunna.
FGM is often performed during Early Childhood. However it also may take place during infancy, adolescence, before marriage and during pregnancy.
8.2 Children with Disabilities, Additional Needs or Special Educational Needs
We recognise that, statistically, children with additional needs, special educational needs, emotional and behavioural difficulties, and disabilities are most vulnerable to abuse. Therefore, staff who deal with children with complex and multiple disabilities and/or emotional and behavioural problems should be particularly sensitive to indicators of abuse.
We will support staff to decide appropriate strategies that will reduce anxiety for the individual child and raise self–esteem as part of an overall behaviour support plan agreed with parents/carers.
In addition, and as appropriate, staff will assist in teaching children personal safety skills commensurate with their age, ability, and needs. For example, how to recognise if they are feeling unsafe, how to ask for help, the difference between safe and unsafe physical contact, and how to recognise and manage risk, including in a digital context.
The content of lessons will be shared with the parents/carers so that these skills can be supported and continued in other environments.
If participants have communication difficulties, we are aware that they are vulnerable to abuse because they are unable to express themselves to others. Instead, such children will often exhibit changes in behaviours or signs and indicators of abuse recognised by staff with a good knowledge of the child.
Where necessary, we will provide additional training to staff in the use of alternative communication systems, thus ensuring that disabled children know how to raise concerns and have access to a range of adults with whom they can communicate.
8.3 Young Carers
We recognise that children who are living in a home environment which requires them to act as a young carer for a family member or a friend who is ill, disabled or misuses drugs or alcohol can increase their vulnerability and that they may need additional support and protection.
Therefore, we will request to be informed prior to enrolment should we have young carers whom we are supporting and will offer additional support internally, work with external agencies if necessary, and refer to Early Help or Social Care as required if concerns arise.
8.4 Children Frequently Missing Education
We recognise that children going missing, particularly repeatedly, can act as a warning sign of a range of safeguarding possibilities, including abuse, neglect, child sexual exploitation and child criminal exploitation, modern slavery, mental health problems, risk of substance abuse, risk of travelling to conflict zones, and risk of FGM or forced marriage.
We monitor the attendance of individual participants closely and analyse patterns of absence to aid early identification of possible safeguarding concerns.
When a child is missing, we will follow the Bedfordshire Children missing education/possible missing children procedure and make a referral via their form: https://bedford-self.achieveservice.com/service/Notification_to_the_Local_Authority_of_a_Child_Missing_Education
8.5 Mental health
All staff should recognise 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.
Staff are aware that children’s experiences, for example, where children have suffered abuse and neglect or other potentially traumatic Adverse Childhood Experiences (ACEs), can impact their mental health, behaviour, and education.
Staff 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.
If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken by speaking to the DSLs.
8.6 Self Harm
Self-harm is defined as ‘intentional self-poisoning or injury, irrespective of the apparent purpose.’
Any child or young person who self-harms or expresses thoughts about this or about suicide must be taken seriously, and appropriate help and intervention should be offered at the earliest point. Any staff member who is made aware that a child or young person has self-harmed should talk with the child or young person as soon as possible. If the child or young person is contemplating suicide, this should be without delay.
Self-harm in children is a safeguarding concern for families and Children’s Services, and early help is crucial.
When considering a referral to the most appropriate service, the following has links to the local guidance for self-harm and risk of suicide: https://bedfordscb.proceduresonline.com/p_self_harm.html.

9 SAFEGUARDING CHILDREN PROCEDURE
Keysoe International Ltd. adheres to child protection procedures that have been agreed locally through the Bedford Borough Safeguarding Children Board. Where we identify children and families in need of support, we will carry out our responsibilities in accordance with the Bedford local procedures.
In line with the procedures, the Integrated Front Door will be contacted as soon as there is a significant concern.
The name of the Designated Safeguarding Leads will be clearly advertised on the premises and on the website, with a statement explaining our role in referring and monitoring cases of suspected abuse.
We will ensure all parents and carers are aware of the responsibilities of staff members to safeguard and promote the welfare of children by publishing this policy on our website and by referring to it in our introductory materials.
Any member of staff who does not feel that concerns about a child have been responded to appropriately and in accordance with the procedures outlined in this policy should raise their concerns with the Senior Management team, escalate their concerns to the Bedford Borough Safeguarding Children Board’s Escalation procedures or refer the matter to an appropriate third party (see the ‘Whistleblowing’ section below).
9.1 What to do if you have concerns about a child or young person
You may have concerns about a child because of something you have seen or heard, or a child may choose to disclose something to you.
The following process is further detailed below; however, in short, all staff must:
1. Accept the disclosure and/or record any concerns noted without a disclosure (for example, observing bruises or overhearing/seeing something concerning) on the Cause for Concern form (KIF-0021).
2. In an emergency, call the Police on 999 and continue with the process as appropriate.
3. If a child or young person has a physical injury or requires medical assistance, this should be sought immediately by phoning 999 and requesting an ambulance.
4. Ask for consent if appropriate (see below).
5. Speak to the Safeguarding Lead and report your concerns.
6. The Safeguarding Lead will:
a. Make a referral to the Local Safeguarding Team/MASH as appropriate; and/or
b. Involve any other relevant organisations as appropriate, for example, the LADO or the venue’s safeguarding team (if at a school, college, etc.); and
7. The Local Safeguarding Team and/or Police will manage the matter but may ask for more information from the staff member, who should cooperate with any formal investigation.
9.1.1 Dealing with a disclosure
If a child or young person discloses information to you, you should:
 If you are with the individual – make the area safe and call the Police if necessary.
 Not promise confidentiality. We may have a duty to share this information and refer it to the Local Safeguarding Team and/or the Police.
 Listen to what is being said without displaying shock or disbelief.
 Reassure the child or young person that they have done the right thing by telling someone.
 Not interrogate them or take photographs of them.
 Not ask leading questions (e.g., “Did they touch your private parts?”).
 Not ask them to repeat the information for another member of staff.
 Explain what you have to do next and who you have to talk to.
 Take notes if possible, or write up your conversation as soon as possible afterwards so that nothing is forgotten. Record the words used (do not paraphrase) and any non-verbal behaviour witnessed which causes concern.
 Record the date, time, and place.
 Ask the young person (16/17 years of age) if they consent to a report being made (the section below outlines the need for consent in certain circumstances).
Whatever the nature of your concerns, you do not need consent, and you MUST complete a Cause for Concern form (KIF-0021) and inform the Designated Safeguarding Leads as soon as possible so that a referral can be submitted where appropriate.
9.1.2 Do I need consent to report abuse or a concern?
o You DO NOT need the permission of a child under the age of sixteen or over the age of sixteen who lacks the mental capacity to consent to report genuine suspicions or allegations of abuse or neglect to our Designated Safeguarding Leads and/or the Local Authority MASH/Police.
o You DO NOT need anyone’s permission to report a crime or any situation where there is a concern that a child and/or children is/are in immediate danger to the Police.
o You DO need to try to obtain the consent of a person aged sixteen or seventeen to share the information outside of the organisation if you believe that they have the mental capacity to consent. However, if consent is not given, you may still share the information with the Local Authority MASH/Police if it is in the public interest, if there is a legal basis for sharing the information, or if a child or children are at risk of significant harm.
9.1.3 What is mental capacity?
A person lacks mental capacity where they have a reduced ability to make informed decisions “in the moment”. This may be transient (e.g., due to fear, shock, injury, or illness) or long-term (e.g., due to learning differences, disability, or mental health issues). Staff should always try to use plain language and aid the young person wherever possible to understand the concern and make an informed decision as to whether they would like it to be reported.
Whilst capacity to consent is a complex issue. It should not get in the way of genuine concerns going unreported.
9.1.4 Should I tell the parents/guardians?
Best practice shows that parents/guardians should be notified of the intended referral if the staff member has contact with them, although only if doing so would not put the child or young person at further risk of harm.
However, the following are circumstances where disclosure to the parent, guardian or responsible adult is not appropriate:
o Where sexual abuse or sexual exploitation is suspected.
o Where organised or multiple cases of abuse are suspected.
o Where Fabricated or Induced Illness (previously known as Munchausen Syndrome by Proxy) is suspected.
o Where Female Genital Mutilation is the concern.
o In cases of suspected Forced Marriage.
o Where it would place a child or young person, yourself, or others at immediate risk.
9.1.5 Where to report concerns
Whether to make a safeguarding referral to the Local Authority Safeguarding Team is a decision made by the Designated Safeguarding Leads when a safeguarding concern is raised.
The local authority the report is made to should be the local authority where the victim lives or, if this is unknown, where the abuse took place.
The contact details for the Safeguarding Team can be found in ‘Appendix A – Local Authority Key Contacts’.
However, staff must be aware that the Police should be contacted on 999 immediately and that they DO NOT need consent to make this call:
o If a crime is being committed.
o If life is at risk.
o If a child or young person is in immediate danger or is at risk of significant harm.
9.2 Further Advice
Further information about what to do if you are worried that a child is being abused is available here in advice for practitioners: https://www.gov.uk/government/publications/what-to-do-if-youre-worried-a-child-is-being-abused–2.

10 SAFEGUARDING ADULTS POLICY
10.1 Principles: Making Safeguarding Personal
Legislation recognises that adults make choices that may mean that one part of their well-being suffers at the expense of another. Similarly, adults can also make a decision to risk their personal safety.
‘Making Safeguarding Personal’ means engaging an adult at risk in a conversation about how best to respond to their situation in a way that enhances their involvement, choice and control, as well as improving their quality of life, well-being and safety. Their views, wishes, feelings and beliefs will be taken into account when decisions are made about how to support them to be safe and find the solution that is right for them. Treating people with respect, enhancing their dignity and supporting their ability to make decisions also helps promote people’s sense of self-worth and support recovery from abuse.
If an adult at risk has difficulty making their views and wishes known, they can be supported or represented by an advocate. This might be a safe family member or friend of their choice or a professional advocate (usually from a third-sector organisation).
Being able to live free from abuse and neglect is a key element of well-being. Any actions taken to safeguard an adult must take their whole well-being into account and be proportionate to the risk of harm.
10.2 Types of Abuse: Adults
Physical abuse
Physical abuse including hitting, slapping, pushing, misuse of medication, restraint, or inappropriate physical sanctions.
Sexual abuse
Sexual abuse including rape and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
Psychological abuse
Psychological abuse including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or unreasonable and unjustified withdrawal of services or supportive networks.
Exploitation
Exploitation either opportunistically or premeditated, unfairly manipulating someone for profit or personal gain.
Financial or material abuse
Financial or material abuse including theft, fraud, exploitation, coercion in relation to an adult’s financial affairs or arrangements, or the misuse or misappropriation of property, possessions, or benefits.
Neglect
Neglect and acts of omission include ignoring medical or physical care needs, failing to provide access to appropriate health, care and support or educational services, and withholding the necessities of life, such as medication, adequate nutrition, and heating.
Discriminatory abuse
Discriminatory abuse including discrimination on the grounds of any of the protected characteristics.
Organisational or Institutional Abuse
Organisational or Institutional Abuse including neglect and poor care practice within an institution or specific care setting like a hospital or care home, for example. This may range from isolated incidents to continuing ill-treatment.
Domestic abuse
Domestic abuse including physical, emotional, and financial abuse, forced marriage, honour-based violence and controlling or coercive behaviour
Self-Neglect
Self-Neglect lack of self-care to the extent that it threatens personal health and safety, neglecting to care for one’s personal hygiene, health or surroundings, inability to avoid self-harm, failure to seek help or access services to meet health and social care needs.
Radicalisation
Self-Neglect
FGM
10.3 Increased Vulnerability to Abuse
Vulnerability is a changeable and contextual state but may include adults at risk with a physical disability or diagnosed condition such as dementia or learning difficulties or those who have a mental health condition such as severe anxiety or depression. Adults in these groups may:
o Have a smaller network of friends and peer groups to support and protect them.
o Require intimate/physical and or invasive medical care required, which can allow abuse to be hidden.
o Have communication difficulties.
o Be less able to resist inappropriate or abusive behaviour, either verbally or physically.
o Be dependent on the abuser for a service or basic need.
o Have medical conditions that are used to explain injuries.
Personal circumstances, such as domestic violence, poverty, substance abuse, homelessness and social exclusion, may also have an impact on vulnerability.

11 SAFEGUARDING ADULTS PROCEDURE
11.1 What to do if you have concerns about a vulnerable adult
The following process is further detailed below; however, in short, all staff must:
1. Accept the disclosure and/or record any concerns noted without disclosure (for example, observing bruises or overhearing/seeing something concerning) on the Cause for Concern form (KIF-0021).
2. In an emergency, call the Police on 999 and continue with the process as appropriate.
3. If an adult has a physical injury or requires medical assistance, this should be sought immediately by phoning 999 and requesting an ambulance.
4. Try to get the adult’s consent.
5. Speak to the Safeguarding Leads and report your concerns.
6. The Safeguarding Lead(s) will:
a. Make a referral to the Local Safeguarding Team as appropriate; and/or
b. Involve any other relevant organisations as appropriate, for example, the LADO or the venue’s safeguarding team (if in a care home, hospice, etc.); and
c. Provide first-line support as appropriate.
7. The Local Safeguarding Team and/or Police will manage the matter but may ask for more information from the staff member, who should cooperate with any formal investigation.
11.1.1 Accepting a disclosure
If an adult has reported to you that they have been abused, are being abused, or are at risk of abuse, you should:
 If you are with the individual, make the area safe.
 Encourage the individual to talk to you.
 Ask open questions to gather as much information as you can, such as what, when, how and how they feel.
 Act in a calm manner, speak slowly and clearly and obtain an interpreter or another communication aid if necessary.
 Try to assess capacity: is the adult able to understand information about the decision, remember that information, use that information to make a decision, and communicate their decision by talking, using sign language or any other means?
 Explain your concern and explain that you will/or would like to share information with the Police and/or a Local Authority and ask for their consent.
 Never promise that you will keep a secret, as consent may be overridden if there is a legal and legitimate reason to do so.
11.1.2 Do I need consent to report abuse or a concern?
Unlike children, adults have a general right to independence, choice and self-determination, including control over information about themselves. In the context of adult safeguarding, these rights can be overridden in certain circumstances.
o The law DOES NOT prevent the sharing of sensitive, personal information within organisations. If the information is confidential, but there is a safeguarding concern, sharing it may be justified.
o The law DOES prevent the sharing of sensitive, personal information between organisations where the adult has capacity, and there is no legal and legitimate reason for the information to be shared.
o The law DOES NOT prevent the sharing of sensitive, personal information between organisations where the public interest served outweighs the public interest served by protecting confidentiality – for example, where a serious crime may be prevented and/or in an emergency or life-threatening situations involving adults or children.
Therefore, every staff member MUST try to gain consent from an adult before sharing information outside of the organisation. However, if the adult is believed to lack capacity, it may be shared externally.
All staff must also remember that just because a decision is unwise in their eyes, this does not override the law, and however difficult it is, an adult with capacity has the right to make informed decisions no matter how this negatively impacts their own life. For example, self-neglect may not be a safeguarding issue if the adult has capacity to make the decision not to provide themselves with adequate care.
11.1.3 Where to report your concerns
Whether to make a safeguarding referral to the Local Authority Safeguarding Team is a decision made by the Designated Safeguarding Leads when a safeguarding concern is raised.
The local authority the report is made to should be the local authority where the victim lives or, if this is unknown, where the abuse took place.
The contact details for the Safeguarding Team can be found in the ‘Appendix A – Local Authority Key Contacts’.
However, staff must be aware that the Police should be contacted on 999 immediately and that they DO NOT need consent to make this call:
o If a crime is being committed.
o If life is at risk.
o If a child or young person is in immediate danger or is at risk of significant harm.

12 MANAGING ALLEGATIONS AGAINST STAFF
Any concerns or allegations about staff will be recorded and dealt with appropriately in line with national (Part four of KCSiE 2023) and the local Bedfordshire C/C allegations procedures.
Ensuring concerns are dealt with effectively will protect those working in or on behalf of Keysoe International Ltd. from potential false allegations or misunderstandings.
12.1 Low-level concerns
The term ‘low-level’ concern does not mean that it is insignificant. A low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ – that an adult working in or on behalf of the organisation may have acted in a way that:
o Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work; and
o Does not meet the harm threshold or is otherwise not serious enough to consider a referral to the LADO.
Examples of such behaviour could include, but are not limited to:
o Being over-friendly with children;
o Having favourites;
o Taking photographs of children on their mobile phones, contrary to local policy;
o Engaging with a child on a one-to-one basis in a secluded area or behind a closed door; or
o Humiliating participants.
Low-level concerns should be managed as per the local procedure (i.e., taking steps to ensure any conduct or behaviour issues are addressed with the member of staff through normal employment practices). However, Keeping Children Safe in Education, Part 4, Section 2 provides that if there is any doubt as to whether the information which has been shared about a member of staff as a low-level concern, in fact, meets the harm threshold and thus should be treated as an allegation, the LADO should be consulted.
12.2 Concerns that meet the harm threshold
Where an allegation relates to the following, it will immediately be reported to the LADO (within 24 hours) to agree on further action to be taken in respect of the participant and staff member:
o behaving in a way that has harmed a child or vulnerable adult or may have harmed a child or vulnerable adult
o possibly committing a criminal offence against or related to a child or vulnerable adult
o behaving towards a child, children, a vulnerable adult or vulnerable adults in a way that indicates he or she may pose a risk of harm to children or vulnerable adults
o behaving in a way that indicates they may not be suitable to work with children or vulnerable adults.
Where such allegations are made, consideration must be given to the following three strands:
1. The Police being informed of a possible criminal offence; and/or
2. A referral being made to the Local Authority Safeguarding Team; and/or
3. Consideration of suspension or temporary adjustments to the role.
Making an adjustment to a role does not in any way imply guilt. It is purely an action designed to allow an investigation to be carried out as quickly as possible while minimising risk.
All staff members who are subject to such action will be offered appropriate support until any investigation is concluded.

13 SUPPORT FOR THOSE WHO REPORT ABUSE
All those making a complaint or allegation or expressing concern, whether they are staff members, participants, or members of the general public, should be reassured that they will be taken seriously and that we will take action as necessary.

14 COMPLAINTS
All stakeholders should feel able to raise or report any concerns about participant safety or potential failures in our safeguarding regime.
We have a complaints procedure available to whoever may wish to report concerns or complaints. This can be found on the website.
We will take all concerns reported seriously, and all complaints will be considered and responded to in line with the relevant and appropriate process.

15 WHISTLEBLOWING
Staff may access the NSPCC whistleblowing helpline if they do not feel able to raise concerns regarding child protection failures internally. Their contact details are:
o Tel: 0800 028 0285 (8:00 am to 8:00 pm, Monday to Friday)
o Email: help@nspcc.org.uk
Alternatively, Protect (the UK’s Whistleblowing Charity) offers a confidential and free advice line for whistleblowers. Their contact details are:
o Tel: 020 3117 2520
o Advice line form: https://protect-advice.org.uk/contact-protect-advice-line/

16 QUALITY ASSURANCE
We will ensure that systems are in place to monitor the implementation of and compliance with this policy and procedures.
The Designated Safeguarding Lead and Deputy will ensure regular reporting on safeguarding activity and systems to the Senior Management team.
The Senior Management team will ensure that action is taken to remedy any deficiencies and weaknesses identified in our safeguarding and/or child protection arrangements without delay.

17 MONITORING AND REVIEWING
Keysoe International Ltd. will review this policy at least annually (as a minimum) and will update it as needed so that it is kept up to date with safeguarding issues as they emerge and evolve, including lessons learnt.
The policy will also be revised following any national or local updates, significant local or national safeguarding events and/or learning, and/or any changes to our own procedures.

18 APPENDIX A: LOCAL AUTHORITY KEY CONTACTS
18.1 Bedfordshire Borough, Central Bedfordshire and Luton Borough Council

18.2 Cambridgeshire and Peterborough Safeguarding Partnership Board

 

18.3 Northamptonshire Safeguarding Partnership

19 APPENDIX B: USEFUL SUPPORT CONTACT DETAILS
Support Organisations
o NSPCC: www.nspcc.org.uk
o Barnardo’s: www.barnardos.org.uk
o Action for Children: www.actionforchildren.org.uk
o Children’s Society: www.childrenssociety.org.uk
o Centre of Expertise on Child Sexual Abuse: www.csacentre.org.uk
NSPCC guidance
o How schools, colleges and academies may protect children from neglect, sexual abuse, sexting, sexual exploitation and grooming and entrapment.
o Recommended adult to child ratios – The NSPCC offers guidance on appropriate levels of supervision for children and young people. This includes advice on adult to child ratios, toilet ratios, first aid ratios, travelling ratios.
o The NSPCC and the Times Educational Supplement have produced a free Safeguarding in Education Self-Assessment Tool (ESAT) which enables school safeguarding leads to audit their school’s current safeguarding arrangements and supports them to make changes and identify areas for developments. Self-Assessment Tool
o The use of photos on websites and in other publications poses direct and indirect risks to children and young people. Organisations wishing to use images of the children they work with or are otherwise in contact with must therefore have a policy in place to safeguard the children involved. Visit the NSPCC for further guidance.
Support for Staff
o Education Support Partnership: www.educationsupportpartnership.org.uk
o Professional Online Safety Helpline: www.saferinternet.org.uk/helpline
o Harmful Sexual Behaviour Support Service: https://swgfl.org.uk/harmful-sexual-behaviour-supportservice
Support for Children
o ChildLine: www.childline.org.uk
o Papyrus: www.papyrus-uk.org
o The Mix: www.themix.org.uk
o Shout: www.giveusashout.org
o Fearless: www.fearless.org
o Victim Support: www.victimsupport.org.uk
Support for Adults
o Family Lives: www.familylives.org.uk
o Crime Stoppers: www.crimestoppers-uk.org
o Victim Support: www.victimsupport.org.uk
o The Samaritans: www.samaritans.org
o NAPAC (National Association for People Abused in Childhood): www.napac.org.uk
o MOSAC: www.mosac.org.uk
o Action Fraud: www.actionfraud.police.uk
o Shout: www.giveusashout.org
o Advice now: www.advicenow.org.uk
Support for Learning Disabilities
o Respond: www.respond.org.uk
o Mencap: www.mencap.org.uk
o Council for Disabled Children: https://councilfordisabledchildren.org.uk
Contextual Safeguarding Network
o https://contextualsafeguarding.org.uk/
Substance Misuse
o We are with you (formerly Addaction): www.wearewithyou.org.uk/services/kent-for-young-people/
o Talk to Frank: www.talktofrank.com
Domestic Abuse
o Domestic abuse services: www.domesticabuseservices.org.uk
o Refuge: www.refuge.org.uk
o Women’s Aid: www.womensaid.org.uk
o Men’s Advice Line: www.mensadviceline.org.uk
o National Domestic Abuse Helpline: www.nationaldahelpline.org.uk
o Respect Phoneline: https://respectphoneline.org.uk
Criminal and Sexual Exploitation
o National Crime Agency: www.nationalcrimeagency.gov.uk/who-we-are
o It’s not okay: www.itsnotokay.co.uk
o NWG Network: www.nwgnetwork.org
o County Lines Toolkit for Professionals:
www.childrenssociety.org.uk/information/professionals/resources/county-lines-toolkit
Honour Based Abuse
o Karma Nirvana: https://karmanirvana.org.uk
o Forced Marriage Unit: www.gov.uk/guidance/forced-marriage
o FGM Factsheet: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/496415/6_1639_HO_SP_FGM_mandatory_reporting_Fact_sheet_Web.pdf
o Mandatory reporting of female genital mutilation: procedural information:
www.gov.uk/government/publications/mandatory-reporting-of-female-genital- mutilation- proceduralinformation
o The right to choose – government guidance on forced marriage:
www.gov.uk/government/publications/the-right-to-choose-government-guidance-on- forcedmarriage
Child-on-child abuse, including bullying, sexual violence, and harassment
o Rape Crisis: https://rapecrisis.org.uk
o Brook: www.brook.org.uk
o Disrespect Nobody: www.disrespectnobody.co.uk
o Upskirting – know your rights: www.gov.uk/government/news/upskirting-know-your-rights
o Lucy Faithfull Foundation: www.lucyfaithfull.org.uk
o Stop it Now! www.stopitnow.org.uk
o Parents Protect: www.parentsprotect.co.uk
o Anti-Bullying Alliance: www.anti-bullyingalliance.org.uk
o Diana Award: www.antibullyingpro.com/
o Bullying UK: www.bullying.co.uk
o Kidscape: www.kidscape.org.uk
Online Safety
o NCA-CEOP: www.ceop.police.uk and www.thinkuknow.co.uk
o Internet Watch Foundation (IWF): www.iwf.org.uk
o Childnet: www.childnet.com
o UK Safer Internet Centre: www.saferinternet.org.uk
o Report Harmful Content: https://reportharmfulcontent.com
o Marie Collins Foundation: www.mariecollinsfoundation.org.uk
o Internet Matters: www.internetmatters.org
o NSPCC: www.nspcc.org.uk/onlinesafety
o Get Safe Online: www.getsafeonline.org
o Parents Protect: www.parentsprotect.co.uk
o Cyber Choices: https://nationalcrimeagency.gov.uk/what-we-do/crime-threats/cybercrime/cyberchoices
o National Cyber Security Centre (NCSC): www.ncsc.gov.uk
Mental Health
o Mind: www.mind.org.uk
o Moodspark: https://moodspark.org.uk
o Young Minds: www.youngminds.org.uk
o We are with you: www.wearewithyou.org.uk/services/kent-for-young-people/
o Anna Freud: www.annafreud.org/schools-and-colleges/
Radicalisation and Hate
o Educate against Hate: www.educateagainsthate.com
o Counter Terrorism Internet Referral Unit: www.gov.uk/report-terrorism
o True Vision: www.report-it.org.uk
Children with Family Members in Prison
o National Information Centre on Children of Offenders (NICCO): https://www.nicco.org.uk/

20 APPENDIX C: INFORMATION SHARING FLOWCHART

 

 

1 Consent must be unambiguous, freely given and withdrawn at any time.
Lawful reasons for sharing information without consent:
o Information can be shared legally without consent if a practitioner is unable to, cannot be reasonably expected to gain consent from the individual, or if gaining consent could place a child at risk.
o Relevant personal information can be shared lawfully if it is to keep a child or individual at risk safe from neglect or physical, emotional or mental harm or if it is protecting their physical, mental, or emotional wellbeing.

 

21 APPENDIX D: STAFF SAFEGUARDING CODE OF CONDUCT
It is the policy that all staff must:
o Work safely and responsibly and take responsibility for their own actions, omissions, and behaviour.
o Ensure that they understand their role, duties, and limitations under this policy.
o Keep up to date with safeguarding training.
o Respect confidentiality and understand when they can and cannot share information.
o Avoid any conduct towards children and vulnerable adults which would lead any reasonable person to question their motivation and intentions. This includes being over-familiar, giving or asking for personal favours, gifting items or money.
o Not make physical contact with any children or vulnerable adults unless:
o It is necessary to prevent an accident.
o It is necessary, for example, to provide first aid, and in such circumstances, a trusted adult should act as a chaperone.
o The individual and/or their guardian has given their consent, for example, to guide a participant using their hands or legs when riding, during hat fitting, and assisting with body movements if a visual demonstration has been provided but further support is requested.
o Not use profane or inappropriate language or make comments or jokes which may cause offence.
o Not record images of participants or any stakeholders on personal devices. All images will be taken on our devices and lawfully processed where valid consent is gained.
o Respect the dignity and privacy of others.
o Be professional and act respectfully when dealing with safeguarding concerns.
Dress appropriately in a way that is unlikely to be viewed as offensive, revealing, or sexually provocative and does not distract, cause embarrassment, or give rise to.

22 REVISION HISTORY
Note: Changes should not be considered in isolation as other requirements of this or other documents may be affected.