Document Control

Executive Summary

Table of Contents

1.        Important Contacts        5

2.        Legislation and Guidance        6

3.        Definitions        7

4.        Equality Statement        8

5.        Roles and Responsibilities        8

5.1.        All Staff        8

5.2.        The Designated Safeguarding Lead (DSL)        9

5.3.        The Governing Body        10

5.4.        The Headteacher/Principal        10

5.5.        Virtual School Headteachers        11

6.        Confidentiality        11

7.        Recognising Abuse and Taking Action        12

7.1.        If a child is suffering or likely to suffer harm, or in immediate danger        12

7.2.        If a child makes a disclosure to you        13

7.3.        If you discover FGM has taken place or a pupil is at risk of FGM        13

7.4.        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)        14

Early help        14

Referral        14

7.5.        If you have concerns about extremism        15

7.6.        If you have a mental health concern        15

7.7.        Concerns about a staff member, supply teacher, volunteer or contractor        16

7.8 Allegations of abuse made against other pupils (Child on Child Abuse)        17

7.8.        Sharing of nudes and semi-nudes (‘sexting’)        18

7.10        Reporting systems for our pupils        20

8.        Online Safety        20

9.        Notifying Parents        22

10.        Pupils with Special Educational Needs        22

11.        Pupils with a Social Worker and Those Vulnerable        22

12.        Looked After and Previously Looked After Children        23

13.        Complaints        23

14.        Record Keeping        23

15.        Training        24

15.1.        All Staff        24

15.2.        The DSL, Deputy DSL and Safeguarding Officer        24

15.3.        Governors        24

15.4.        Recruitment – Interview Panels        24

15.5.        Staff who have contact with pupils and families        25

16.        Monitoring Arrangements        25

17.        Links with Other Policies        25

TCAT Policies        25

Appleton Thorn Policies

Appendix 1: Types of Abuse        26

Appendix 2: Safer Recruitment and DBS Checks – Policies and Procedures        27

Appendix 3: Allegations of Abuse against Staff        32

Appendix 4: Specific Safeguarding Issues        39

County lines        41

Non-collection of children        46

Missing pupils        47

Child Abduction and community safety incidents        47

If you see anything suspicious that doesn’t feel right, report it immediately.        47

Cybercrime        47

Children and the court system        47

Children with family members in prison        48

1. Important Contacts

Aims

This Policy should be read in conjunction with the TCAT Statement on Safeguarding and Child Protection.

Appleton Thorn Primary as one of the academies within TCAT aims to ensure that:

• Appropriate action is taken in a timely manner to safeguard and promote children’s welfare
• All staff are aware of their statutory responsibilities with respect to safeguarding
• Staff are properly trained in recognising and reporting safeguarding issues

2. Legislation and Guidance

This policy is based on the Department for Education’s statutory guidance Keeping Children Safe in Education 2025 and Working Together to Safeguard Children (2023) 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, and ‘Safeguarding Children and Safer Recruitment in Education DFE, 2011’ 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
• Part 3 of the schedule to the Education (Independent School Standards) Regulations 2014, which places a duty on academies and independent schools to safeguard and promote the welfare of pupils at the school.
• 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 Teacher Standards 2012’
• ‘What to do if you are worried a child is being abused’ Advice for Practitioners (DFE, 2015)
• The Human Rights Act 1988, The Equality Act 2010 and The Public Sector Equality Duty (PESD)

Primary schools within TCAT also follow:

• 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

3.  Definitions

Safeguarding and promoting the welfare of children means:

• Providing help and support to meet the needs of children as soon as problems emerge.
• Protecting children from maltreatment whether that is within or outside the home including online
• 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.

Sexting (also known as youth produced sexual imagery) is the sharing of sexual imagery (photos or videos) by children

Children includes everyone under the age of 18.

In all cases of Child on Child Abuse (section 7) the following definitions will be used:

• Victim- the child or young person who discloses
• Alleged Perpetrator- the child or young person who is subject to the allegation.

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 area

TCAT schools and academies comply with the Pan-Cheshire Safeguarding and Child Protection arrangements and support the work and scrutiny of the Children’s Safeguarding Partnerships in all Local Authorities in which its academies are based.

Warrington - Warrington Safeguarding Partnerships - Welcome to the Safeguarding Children Partnership

St Helens - St. Helens Safeguarding Children Partnership - Home

Wirral - Welcome to the Wirral Safeguarding Children Partnership - Wirral Safeguarding Children Partnership

4. 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 (see section 9)
• 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, 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 (see section 11)

5. Roles and Responsibilities

Safeguarding and child protection is everyone’s responsibility. This policy applies to all staff, volunteers and governors in the school and is consistent with the procedures of the 3 safeguarding partners. Our policy and procedures also apply to extended school and off-site activities.

1. All Staff

All staff will read and understand part 1, Annex of the Department for Education’s statutory safeguarding guidance, Keeping Children Safe in Education 2025, and review this guidance at least annually.

All staff will be aware of:

• Our systems which support safeguarding, including this child protection and safeguarding policy, the role and identity of the designated safeguarding lead’s (DSL) and Safeguarding Officer, the behaviour policy, and the safeguarding response to children who go missing from education
• The Early Help process and their role in it, including identifying emerging problems, liaising with the DSL and or Pastoral Staff and sharing information with other professionals to support early identification and assessment
• 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 filtering and monitoring systems and processes in place on devices and networks in their academy
• The signs of different types of abuse and neglect, as well as specific safeguarding issues, such as child sexual exploitation (CSE), Child Criminal Exploitation (CCE) indicators of being at risk from or involved with serious violent crime, FGM and radicalisation
• That abuse can happen to children on and offline line with equal significance for the child.
• That whilst all children should be protected, it is important to recognise that some groups of children, are potentially at greater risk of harm than others (both online and offline). The list below, is not exhaustive, but highlights some of those groups.

• Children who need a social worker (Child in Need and Child Protection Plans)
• Children who are absent from education
• Elective Home Education (EHE)
• Children requiring mental health support
• Looked after children and previously looked after children
• Care leavers
• Children with special educational needs, disabilities or health issues
• Children who are lesbian, gay, bi, or gender questioning.

• Abuse online may include:

1. Sending abusive, harassing or misogynistic comments
2. Non-consensual sharing of indecent mages
3. Sharing abusive images and pornography to those who do not want to receive such images.

• The need to emphasise the importance of online safety when communicating with parents/carers
• The need to advise LGBT pupils of safe spaces/people where they are able to find support
• The nature of Serious violence (including that linked to county lines)
• That children are vulnerable to abuse and harm both inside and outside the home
• Children at young people who are LGBTQ or are perceived to be are at risk of being targeted by other children and young people.
• Staff will be aware of what to look for to identify those who may need help or protection
• What sexual violence and sexual harassment are and actions to take if suspected or disclosed
• That children may and do abuse other children and the actions to take when child on child abuse is suspected or disclosed.

Section 15 and Appendix 4 provide more details on staff support and training.

2. The Designated Safeguarding Lead (DSL)

Appleton Thorn Primary School Safeguarding Team is made up of:

During term time, the DSL’s will be available during school hours for staff to discuss any safeguarding concerns. During extra-curricular activities and residentials, the DSL or appropriate member of senior staff will be available. Where incidents become known during the school day but are unresolved at the end of the school day the DSL, appropriate member of staff will remain on site until the next course of action for the child, or young person has been resolved.

When school is closed contact arrangements may be put in place for those students judged to be at most risk. All academies will ensure that Safeguarding partners are signposted on the web site.

The DSL’s and the Safeguarding Officer will be given the time, funding, training, resources and support to:

• Provide advice and support to other staff on child welfare and child protection matters
• Take part in strategy discussions and inter-agency meetings and/or support other staff to
• Contribute to the assessment of children
• 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
• Have a good understanding of harmful sexual behaviour including the local picture and participate in sharing information with local partners and police
• Be confident in accessing local specialised support for children and young people involved in sexual violence and harassment
• Understand that any child or young person must have an ‘appropriate adult’ in the case of a Police search or investigation.
• Be responsible for understanding the filtering and monitoring systems and processes in place on devices and networks in their academy

The DSL will also keep the Headteacher and Safeguarding Governor informed of any issues, liaise with local authority case managers, and designated officers for child protection concerns as appropriate. Their full responsibilities are laid out in their job description.

3. The Governing Body

The governing body will approve this policy at each review, ensure it complies with the law and hold the Headteacher/Principal to account for its implementation.

The governing body will appoint link governor to monitor the effectiveness of this policy in conjunction with the full governing body. This is always a different person from the DSL.

The chair of governors will act as the ‘case manager’ in the event that an allegation of abuse is made

against the Headteacher/Principal where appropriate (see Appendix 3).

The governing body will review the DfE’s filtering and monitoring standards and discuss with IT staff and service providers what needs to be done to support the academy in meeting the standards (KCSIE 2025, paragraph 142)

All governors will read Keeping Children Safe in Education with particular focus on Chapter 1 and 5.

All governors will complete annual TCAT Safeguarding Essentials training and Safer Recruitment training via the National College.

The Safeguarding Governor and Chair of Governors will also complete the Annual Certificate for Governors via the National College.

Section 15 of this policy has information on how governors are supported to fulfil their role.

4. The Headteacher/Principal

The Principal/Headteacher is responsible for the implementation of this policy, including:

• Ensuring that staff (including temporary staff) and volunteers are informed of the systems which support safeguarding, including this policy, as part of their induction
• Communicating this policy to parents when their child joins the school and via the school website
• Ensuring that the DSL and Safeguarding Officer has appropriate time, funding, training and resources, and that there is always adequate cover if the DSL is absent
• Ensuring that all staff undertake appropriate safeguarding and child protection training and update this regularly
• Acting as the ‘case manager’ in the event of an allegation of abuse made against another member of staff or volunteer, where appropriate (see Appendix 3)
• Make decisions regarding the management and actions to ‘low level’ concerns about staff in collaboration with the DSL

TCAT academies which are Early years providers and primary schools, will also,

• Ensure the relevant staffing ratios are met, where applicable
• Make sure each child in the Early Years Foundation Stage is assigned a key person

5. Virtual School Headteachers

Virtual school heads have a non-statutory responsibility for the strategic oversight of the educational attendance, attainment, and progress of pupils with a social worker and those in ‘Kinship Care’ (those who live in Private fostering arrangements or on SGO’s) TCAT Principal’s and Headteacher will work supportively with Virtual Headteacher for their Children in Care.

5.6 Alternative Provision

TCAT academies may place pupils in Alternative Provision.  In such instances the home school maintains responsibility of the pupils safeguarding.  The home school will seek written reassurance that the Safeguarding responsibilities of the provider are fully in line with KCSIE 2025 and will have the name of the DSL/DDSL within the AP.

Specifically, the school should seek written confirmation:

• All staff have had appropriate Safeguarding checks
• New staff have been appropriately checked prior to employment.
• The home school should know where pupils are each day and maintain address of any sub- contracted AP provision and oversee the same Safeguarding checks.
• Schools should review placement at AP at least once per half term
• Attendance should be checked to ensure the pupil is attending regularly

In the event of a Safeguarding concern being raised the placement should be reviewed and terminated, if necessary, until concerns have been satisfactorily addressed

If using TCAT’S own Alternative Provision Re-Route academies will adopt the TCAT Re-Route Safeguarding Addendum

6. Confidentiality

TCAT schools and academies are committed to maintaining the responsibility to protect data as laid down in the Data Protection Act and the TCAT GDPR Policy. We are also committed to ensuring that we share information with the Safeguarding Partners to ensure 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
• 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
• When staff process data to protect the vital interests of an individual (i.e. recording safeguarding concerns on CPOMS), the information recorded will be relevant to the case and chronology. When an individual or the parent/carer of the individual is not informed that the data is being recorded this will be in circumstances where professionals consider that to inform them would increase the risk to the individual and/or the harm threshold.

If a victim asks the school not to tell anyone about the sexual violence or sexual harassment:

There is no definitive answer, because even if a victim does not consent to sharing information, staff may still lawfully share it if there is another legal basis under the UK GDPR that applies.

The DSL will have to balance the victim’s wishes against their duty to protect the victim and other children

The DSL should consider that:

• Parents or carers should normally be informed (unless this would put the victim at greater risk)
• The basic safeguarding principle is: if a child is at risk of harm, is in immediate danger, or has been harmed, a referral should be made to local authority children’s social care
• Rape, assault by penetration and sexual assault are crimes. Where a report of rape, assault by penetration or sexual assault is made, this should be referred to the police. While the age of criminal responsibility is 10, if the alleged perpetrator is under 10, the starting principle of referring to the police remains.

Regarding anonymity, all staff will:

• Be aware of anonymity, witness support and the criminal process in general where an allegation of sexual violence or sexual harassment is progressing through the criminal justice system
• Do all they reasonably can to protect the anonymity of any children involved in any report of sexual violence or sexual harassment, for example, carefully considering which staff should know about the report, and any support for children involved
• Consider the potential impact of social media in facilitating the spreading of rumours and exposing victims’ identity
• 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 DSL (or deputy)

7. Recognising Abuse and Taking Action

Staff, volunteers and governors of Appleton Thorn Primary School must follow the procedures set out below in the event of a safeguarding issue.

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

“the DSL (or deputy DSL)” or Safeguarding Officer

6. If a child is suffering or likely to suffer harm, or in immediate danger

• If it is a medical emergency contact 999.
• Inform the DSL immediately if a child is suffering or likely to suffer significant harm.
• If contact with either DSL or the Safeguarding Officer cannot be made then you should make a referral to Social Care and/or the Police. ANYONE CAN MAKE A REFERRAL
• Tell the DSL (see section 5.2) as soon as possible if you make a referral directly.
• The contact details and process for making a referral can be found below:

Warrington - https://www.warrington.gov.uk/mars

St Helens - Concerned about a child's safety or welfare? - St Helens Borough Council

Wirral – Children and families request for support form - Log in or sign up for a MyWirral account

7.  If a child makes a disclosure to you

If a child discloses a safeguarding issue to you, you should:

• Listen to and believe them. Allow them time to talk freely and do not ask leading questions
• Stay calm and do not show that you are shocked or upset
• Reassure the child they have done the right thing in telling you.
• Explain what will happen next and that you will have to pass this information on. Do not promise to keep it a secret
• Write up your conversation as soon as possible in the child’s own words record on CPOMS if you have access if not forward to the DSL/Safeguarding Officer who will do so. Stick to the facts, and do not put your own judgement on it
• Sign and date the write-up and pass it on to the DSL. Alternatively, if appropriate, make a referral to children’s social care and/or the police directly (see 7.1), and tell the DSL as soon as possible that you have done so

Bear in mind that some children may:

• Not feel ready, or know how to tell someone that they are being abused, exploited or neglected
• Not recognise their experiences as harmful
• Feel embarrassed, humiliated or threatened. This could be due to their vulnerability, disability, sexual orientation and/or language barriers
• None of this should stop you from having a ‘professional curiosity’ and speaking to the DSL if you have concerns about a child.  

8. If you discover 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.

Any teacher who discovers (either through disclosure by the victim or visual evidence) that an act of FGM appears to have been carried out on a pupil under 18 must immediately report this to the police, personally. This is a statutory duty, and teachers will face disciplinary sanctions for failing to meet it.

Unless they have been specifically told not to disclose by the Police, they should also discuss the case with the DSL and involve children’s social care as appropriate.

Any other member of staff who discovers that an act of FGM appears to have been carried out on a pupil under 18 must speak to the DSL and follow our local safeguarding procedures.

The duty for teachers 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.

9. 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)

It is important to share any concerns that you have with those in a position to further monitor and where necessary act on the concern. All TCAT schools and academies prioritise the safeguarding and welfare of pupils in their care. At Appleton Thorn Primary School the welfare of pupils is supported by their class teacher and the Teaching Assistant Team, in addition to additional support, when required from our Pastoral Lead Mrs Gibbon.  All concerns must be reported to the class teacher in the first instance. They will decide if action is needed including support for the child directly from school or referral through to Early Help Where external agencies are involved the DSL and Safeguarding Officer must be informed.

Figure 1 on page 14 illustrates the procedure to follow if you have any concerns about a child’s

welfare.

Early help

Early Help is ‘support for children of all ages that improves a family’s resilience and outcomes or reduces the chance of a problem getting worse.

If early help is appropriate, the DSL or Safeguarding Officer will lead on liaising with other agencies and setting up an inter-agency assessment as appropriate. Staff may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead practitioner.

The DSL or Safeguarding Officer will keep the case under constant review and the school will consider

a referral to local authority children’s social care if the situation does not seem to be improving.

Timelines of interventions will be monitored and reviewed.

Early Help is an important aspect of Safeguarding and many children and families can be supported by the process. Consideration to the offer of Early Help should be given to:

• Pupils with health conditions
• Pupils with mental health conditions
• Pupils at risk of honour-based abuse (such as forced marriage or female genital mutilation)
• Pupils who are persistently absent form school including persistent absences for part of the school day
• Pupils who have had repeated suspensions and is at risk of Permanent Exclusion
• Pupils who have a parent/carer in custody or is affected by parental offending.
• Pupils who are frequently missing from education, care or home

For further details see the following links:

Warrington - https://www.warrington.gov.uk/early-help

St Helens - St. Helens Safeguarding Children Partnership - Early Help

Wirral - Early help | wirral.gov.uk

Referral

If it is appropriate to refer the case to local authority children’s social care or the police, the DSL or

Safeguarding Officer will make the referral.

If you make a referral directly (see section 7.1), 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 Safeguarding Officer 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.

10. If you have concerns about extremism

All TCAT Aacdemies have adopted the TCAT Prevent Statement accessible on each academies webs site.

If a child is suffering or likely to suffer from harm, or in immediate danger then you should refer the matter to the DSL with responsibility for the Prevent Duty, at Appleton Thorn this is Mrs Zoe Jones office@appletonthorn.tcat.uk.com. In the exceptional case of this not being possible then speak to the senior DSL Mr Aaron Roberts office@appletonthorn.tcat.uk.com. The Department for Education also has a dedicated telephone helpline, 020 7340 7264, which school staff and governors can call to raise concerns about extremism with respect to a pupil. You can also email counter.extremism@education.gov.uk. 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

11. If you have a mental health concern

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. Poor mental health can also be the result or cause of bullying. Therefore, all staff should be familiar with the school’s Anti-Bullying Policy.

All TCAT academies have identified staff who are trained in responding to mental health concerns. At Appleton Thorn Primary School we have a dedicated Mental Health Lead, Ms Laura Tsang office@appletonthorn.tcat.uk.com All concerns about a child’s mental health will be shared with the mental health lead who will decide how to respond. This may be through direct support from school or referral to external avenues of support like KOOTH or CAMHS. If the concern around mental health is also a concern around safeguarding then the DSL or Safeguarding Officer must be informed.

Figure 1: Procedure if you have concerns about a child’s welfare

Warrington - https://www.warrington.gov.uk/mars

St Helens - Concerned about a child's safety or welfare? - St Helens Borough Council

Wirral – Children and families request for support form - Log in or sign up for a MyWirral account

12. Concerns about a staff member, supply teacher, volunteer or contractor

If you have concerns about a member of staff (including a supply teacher, volunteer or contractor), or an allegation is made about a member of staff (including a supply teacher, volunteer or contractor) posing a risk of harm to children, speak to the Headteacher/principal as soon as possible. If there is a concern regarding an individual or organisation who was using the academies premises for running an activity for children, the academies safeguarding policies and procedures will be followed, including informing the local authority designated officer (LADO), as per any safeguarding allegation. If the concerns/allegations are about the Headteacher/principal, speak to the chair of governors.

The Headteacher/chair of governors will then follow the procedures set out in Appendix 3, if appropriate.

Where you believe there is a conflict of interest in reporting a concern or allegation about a member of staff (including a supply teacher, volunteer or contractor) to the Headteacher, report it directly to the local authority designated officer (LADO).

TCAT academies with early years providers will also where appropriate inform Ofsted of the allegation and actions taken, within the necessary timescale (see Appendix 3 for more detail).

In all instances of allegations being made about a member of staff TCAT Academies will follow the TCAT LADO and Low Level concern protocol.

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

We recognise that children can abuse their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”, as this can lead to a culture of unacceptable behaviours and an unsafe environment for pupils.

We also recognise the gendered nature of child-on-child abuse. However, all child-on-child abuse is unacceptable and will be taken seriously.

Most cases of pupils hurting other pupils will be dealt with under our school’s 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 school 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)

See appendix 4 for more information about child-on-child abuse.

Procedures for dealing with allegations of child-on-child abuse

If a pupil makes an allegation of abuse against another pupil or if you are concerned that child-on-child abuse is happening then you must inform the DSL

• 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 been made and any others affected) with a named person they can talk to if needed. This will include considering school transport as a potentially vulnerable place for a victim or alleged perpetrator(s)
• The DSL will contact the children and adolescent mental health services (CAMHS), if appropriate
• If the incident is a criminal offence and there are delays in the criminal process, the DSL will work closely with the police (and other agencies as required) while protecting children and/or taking any disciplinary measures against the alleged perpetrator. We will ask the police if we have any questions about the investigation.

Creating a supportive environment in school 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.

 To achieve this, we will:

• Challenge any form of derogatory or sexualised language or inappropriate behaviour between peers, including requesting or sending sexual images
• Be 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
• Ensure our curriculum helps to educate pupils about appropriate behaviour and consent
• Ensure pupils can easily and confidently report abuse using our reporting systems (as described in section 7.10 below)
• Ensure staff reassure victims that they are being taken seriously
• Be alert to reports of sexual violence and/or harassment that may point to environmental or systemic problems that could be addressed by updating policies, processes and the curriculum, or could reflect wider issues in the local area that should be shared with safeguarding partners
• Support children who have witnessed sexual violence, especially rape or assault by penetration. We will do all we can to make sure the victim, alleged perpetrator(s) and any witnesses are not bullied or harassed
• Consider intra familial harms and any necessary support for siblings following a report of sexual violence and/or harassment  
• TCAT academies may signpost pupils/young people to ‘Shore Space’, a confidential chat service for young people concerned about their own or someone else’s sexual thoughts and behaviors.https://shorespace.org.uk/

Ensure staff are trained to:

• Recognise the indicators and signs of child-on-child abuse, and know how to identify it and respond to reports
• That even if there are no reports of child-on-child abuse in school, it does not mean it is not happening – staff should maintain an attitude of “it could happen here”
• 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
• That certain children may face additional barriers to telling someone because of their vulnerability, disability, gender, ethnicity and/or sexual orientation
• That a pupil 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
• The important role they have to play in preventing child-on-child abuse and responding where they believe a child may be at risk from it
• That they should speak to the DSL if they have any concerns
• That social media is likely to play a role in the fall-out from any incident or alleged incident, including for potential contact between the victim, alleged perpetrator(s) and friends from either side
• The DSL will take the lead role in any disciplining of the alleged perpetrator(s). Safeguarding Partners will provide support at the same time as taking any disciplinary action. Disciplinary action can be taken while other investigations are going on, e.g. by the police. The fact that another body is investigating or has investigated an incident does not (in itself) prevent our school from coming to its own conclusion about what happened and imposing a penalty accordingly. We will consider these matters on a case-by-case basis, taking into account whether:
• Taking action would prejudice an investigation and/or subsequent prosecution – we will liaise with the police and/or LA children’s social care to determine this
• There are circumstances that make it unreasonable or irrational for us to reach our own view about what happened while an independent investigation is ongoing  

13.  Sharing of nudes and semi-nudes (‘sexting’)

We follow the suggested approach based on guidance from the UK Council for Internet Safety for all staff and for DSLs and senior leaders.

Your responsibilities when responding to an incident

If you are made aware of an incident involving the consensual or non-consensual sharing of nude or semi-nude images/videos (also known as ‘sexting’ or ‘youth produced sexual imagery’), you must report it to the DSL immediately.

You must not:

• View, copy, print, share, store or save the imagery yourself, or ask a pupil 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 pupil to delete it
• Ask the pupil(s) who are 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 pupil(s) 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 pupil(s) 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 may include the staff member who reported the incident and the safeguarding or leadership team that deals with safeguarding concerns. This meeting will consider the initial evidence and aim to determine:

• Whether there is an immediate risk to pupil(s)
• If a referral needs to be made to the police and/or children’s social care
• If it is necessary to view the image(s) in order to safeguard the young person (in most cases, images or videos should not be viewed)
• What further information is required to decide on the best response
• Whether the image(s) 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 or videos from devices or online services
• Any relevant facts about the pupils involved which would influence risk assessment
• If there is a need to contact another school, college, setting or individual
• Whether to contact parents or carers of the pupils involved (in most cases parents/carers 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 images or videos 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 pupil in the images or videos is under 13
• The DSL has reason to believe a pupil is at immediate risk of harm owing to the sharing of nudes and semi-nudes (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/principal and other members of staff as appropriate, may decide to respond to the incident without involving the police or children’s social care. The decision will be made and recorded in line with the procedures set out in this policy.  

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 to establish the facts and assess the risks.

They will hold interviews with the pupils involved (if appropriate).

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/carers

The DSL will inform parents/carers 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 through contact with the schools allocated Police officer or through 101.

Recording incidents

All incidents of sharing of nudes and semi-nudes, and the decisions made in responding to them, will be recorded on CPOMS. The record-keeping arrangements set out in section 14 of this policy also apply to recording these incidents.

Curriculum coverage

Pupils are taught about the issues surrounding the sharing of nudes and semi-nudes as part of our Personal Development Curriculum incorporating RSHE. Teaching covers the following in relation to the sharing of nudes and semi-nudes:

• What it is
• How it is most likely to be encountered
• The consequences of requesting, forwarding or providing such images, including when it is and is not abusive and when it may be deemed as online sexual harassment
• Issues of legality
• The risk of damage to people’s feelings and reputation
• Pupils also learn the strategies and skills needed to manage:
• Specific requests or pressure to provide (or forward) such images
• The receipt of such images
• This policy on the sharing of nudes and semi-nudes is also shared with pupils so they are aware of the processes the school will follow in the event of an incident.

10. Reporting systems for our pupils

Where there is a safeguarding concern, we will take the child’s wishes and feelings into account when determining what action to take and what services to provide.

We recognise the importance of ensuring pupils feel safe and comfortable to come forward and report any concerns and/or allegations.

To achieve this, we will:

• Put systems in place for pupils to confidently report abuse
• Ensure our reporting systems are well promoted, easily understood and easily accessible for pupils
• Make it clear to pupils that their concerns will be taken seriously, and that they can safely express their views and give feedback
• Pupils at Appleton Thorn Primary School are made aware of the names and how to contact the DSL through signage and regular assemblies. Pupils can make their thoughts and feelings known on Safeguarding arrangements through the school council, class worry boxes / monsters and through single sex focus groups held routinely.

8. Online Safety

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. 

To address this, our school aims to:

• Have robust processes in place to ensure the online safety of pupils, staff, volunteers and governors
• Protect and educate the whole school community in its safe and responsible use of technology, including mobile and smart technology (which we refer to as ‘mobile phones’)
• Set clear guidelines for the use of mobile phones for the whole school community
• Establish clear mechanisms to identify, intervene in and escalate any incidents or concerns, where appropriate

This is further elaborated in the Online Safety Policy which is available on the school’s website and overseen by the Online Safety Group and reviewed annual by the Safeguarding Committee

The 4 key categories of risk

Our approach to online safety is based on addressing the following categories of risk:

• Content – being exposed to illegal, inappropriate or harmful content, such as pornography, fake news, racism, misogyny, self-harm, suicide, antisemitism, radicalisation, extremism, misinformation, disinformation including fake news, Conspiracy theories.
• Contact – being subjected to harmful online interaction with other users, such as peer-to-peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes
• Conduct – personal online behaviour that increases the likelihood of, or causes, harm, such as making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography), sharing other explicit images and online bullying; and
• Commerce – risks such as online gambling, inappropriate advertising, phishing and/or financial scams

To meet our aims and address the risks above we will:

Educate pupils about online safety as part of our curriculum. For example:

• The safe use of social media, the internet and technology
• Keeping personal information private
• How to recognise unacceptable behaviour online
• How to report any incidents of cyber-bullying, ensuring pupils are encouraged to do so, including where they are a witness rather than a victim
• Train staff, as part of their induction, on safe internet use and online safeguarding issues including cyber-bullying and the risks of online radicalisation. All staff members will receive refresher training at least once each academic year
• Educate parents/carers about online safety via our website, communications sent directly to them and during parents’ evenings. We will also share clear procedures with them, so they know how to raise concerns about online safety
• Make sure staff are aware of any restrictions placed on them with regards to the use of their mobile phone and cameras, for example that:

• Staff are allowed to bring their personal phones to school for their own use, but will limit such use to non-contact time when pupils are not present
• Staff will not take pictures or recordings of pupils on their personal phones or cameras

• Make all pupils, parents/carers, staff, volunteers and governors aware that they are expected to sign an agreement regarding the acceptable use of the internet in school, use of the school’s ICT systems and use of their mobile and smart technology
• Explain the sanctions we will use if a pupil is in breach of our policies on the acceptable use of the internet and mobile phones
• As part of their safeguarding and online safety training, all staff will understand their expectations, roles and responsibilities around filtering and monitoring systems.
• TCAT academies will be guided by the ‘plan technology for your school service’ to ensure a robust response to online safety Plan for technology
• TCAT academies will develop safe use of AI in schools guided by DFE’s ‘Generative AI in education’

Generative AI:product safety expectations

• TCAT academies use the online safety SENSO filtering program to ensure that any misuse of school based technology and platforms are identified and can be responded to staff, pupils and parents are made aware of this system and how it is monitored and responded to throughout the day.

9. 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.

10. Pupils with Special Educational Needs

We recognise that pupils with special educational needs (SEN) and disabilities 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 SEN and disabilities being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs
• Communication and language barriers

At Appleton Thorn Primary School we support pupils with SEND to overcome these barriers though our commitment to inclusion and specifically by:

• Liaison with the school Assistant Headteacher Inclusion/Assistant SENCO/Designated Provision Lead where Safeguarding concerns involve a pupil with additional needs.
• Ensuring all SEND pupils have a member of the EST who knows the pupil well
• Maintaining strong communication between home and school
• Ensuring that all curriculum coverage aimed at helping pupils to keep themselves safe is accessible to pupils with SEND.
• Ensuring a member of the EST is part of the Safeguarding Team
• Ensuring that all pupils with SEND can access all aspects of school life and be a full part of the school community

11. Pupils with a Social Worker and Those Vulnerable

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. All TCAT academies maintain a register of Vulnerable Pupils including those with allocated Social Workers. At Appleton Thorn Primary School this is the Vulnerable Pupils Register. The VPR holds pupils with Social Workers and those within the Early Help Process and pupils who are receiving support from agencies or intensely at school. Bridgewater High School’s safeguarding Team made up of the DSL’s, Mental Health Lead and SENCO who meet fortnightly to monitor the wellbeing of these pupils.

12. 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’s looked after legal status, contact arrangements with birth parents or those with parental responsibility, and care arrangements
• The DSL’s and Safeguarding Officer has details of children’s social workers and relevant virtual school heads

We have appointed a designated teacher, Mrs Clare Farrell office@appletonthornprimary.org.uk who is responsible for promoting the educational achievement of looked-after children and previously looked-after children in line with statutory guidance.

The designated teacher is appropriately trained and has the relevant qualifications and experience to perform the role. As part of their role they will work closely with the Safeguarding Officer to ensure that all Safeguarding matter are dealt with promptly. Further details of arrangements for Looked after and previously looked after children are available in the Looked After and Previously Looked after children Policy.

13. Complaints

All complaints will be dealt with under the TCAT Complaints Policy and procedure

14. Record Keeping

We will hold records in line with the TCAT records retention schedule.

• All safeguarding documentation will be logged and stored on CPOMS (Child Protection Management System)
• 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 after they have left the school.

If a child for whom the school has, or has had, safeguarding concerns moves to another school, the DSL will ensure that their Safeguarding information is forwarded promptly and securely, and separately from the main pupil file. In addition, if the concerns are significant or complex, and/or social services are involved, the DSL will speak to the DSL of the receiving school and provide information to enable them to have time to make any necessary preparations to ensure the safety of the child. All TCAT schools and academies use CPOMS an electronic secure information management system for the Child Protection and Safeguarding matters.

In addition:

• Appendix 2 sets out our policy on record-keeping specifically with respect to recruitment and pre-employment checks
• Appendix 3 sets out our policy on record-keeping with respect to allegations of abuse made against staff

15. Training

1. All Staff

All staff at Appleton Thorn Primary School and all staff in TCAT schools and academies will undertake Child Protection and Safeguarding training at an appropriate level annually via the National College. The training covers:

• Safeguarding Children including recognizing different types of abuse, FGM, Forced Marriage, Peer on Peer Abuse and Children Missing Education.
• Radicalisation and Extremism including Prevent Strategy guidance
• Mental Health and Wellbeing including types of mental health needs
• How to Keep Children Safe including raising concerns about a child
• Online Safety including cyber bullying and sexting

In addition, the DSL’s within each of the schools and academies will direct regular briefings to all staff in local and national context. The TCAT Safeguarding Hub will further disseminate guidance and provide training to individual schools and DSL’s and broader Safeguarding staff.

At Appleton Thorn Primary Supply teachers and those volunteering will read the Child Protection Awareness document prior to commencing their role within school and all visitors to the school will be issued with information regarding Safeguarding principals and how to identify and respond to any safeguarding concerns.

2. The DSL, Deputy DSL and Safeguarding Officer

The DSL’s and Safeguarding Officers 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 (for example, through e-bulletins, meeting other DSLs, or taking time to read and digest safeguarding developments). They will also undertake Prevent awareness training.

3. Governors

All governors will read Keeping Children Safe in Education chapter 1

All governors will complete annual TCAT Safeguarding Essentials training and governors who may interview will complete Safer Recruitment bi-annually.

The Safeguarding Governor and Chair of Governors will also complete the Annual Certificate for Governors via the National College.

As the chair of governors may be required to act as the ‘case manager’ if an allegation of abuse is made against the Headteacher, they receive training in managing allegations for this purpose.

4. Recruitment – Interview Panels

At least one person conducting any interview for a post at the school will have undertaken safer recruitment training. At Appleton Thorn Primary School all members of the Senior Leadership Team and the Chair of Governors undertake Safer Recruitment Training annually via the National College. This will cover, as a minimum, the contents of the Department for Education’s statutory guidance, Keeping Children Safe in Education, and will be in line with local safeguarding procedures.

5. Staff who have contact with pupils and families

All Schools and academies within TCAT will have access to Supervision for DSL’s and Safeguarding Leads through TCAT’s Lead Practitioner for Safeguarding supported by the TCAT Safeguarding Hub. Appleton Thorn Primary School also recognises that staff who have regular and often intense contact with children and families will also require supervision. We will provide this through the function of the Safeguarding Team and through the Mental Health First Aider for Adults Mrs Zoe Jones.

16. Monitoring Arrangements

This policy will be reviewed annually by Mrs Zoe Jones with the Local Governing Challenge Board

17. Links with Other Policies

This policy links to the following policies and procedures:

TCAT Policies

1. GDPR
2. CCTV
3. Whistle Blowing
4. Complaints
5. Equality
6. Health and Safety
7. Attendance Policy
8. Online Safety Policy

Appleton Thorn Primary Policies:

9. Behaviour Policy and Manual of Procedures
10. Drugs and Substance abuse Policy
11. RSE Policy
12. SEND Policy
13. Privacy and Acceptable Use Policies
14. Anti-Bullying Policy
15. Mental Health and Wellbeing Policy
16. Looked After and Previously Looked After Children.

These appendices are based on the Department for Education’s statutory guidance, Keeping Children Safe in Education 2025

Appendix 1: Types of Abuse

Abuse, including neglect and exploitation are rarely standalone events that can be covered by 1 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 cyber-bullying), 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.

Appendix 2: Safer Recruitment and DBS Checks – Policies and Procedures

Recruitment and selection process

To make sure we recruit suitable people, we will ensure that those involved in the recruitment and employment of staff to work with children have received appropriate safer recruitment training.

We have put the following steps in place during our recruitment and selection process to ensure we are committed to safeguarding and promoting the welfare of children.

Advertising

When advertising roles, we will make clear:

• Our school’s commitment to safeguarding and promoting the welfare of children
• That safeguarding checks will be undertaken
• The safeguarding requirements and responsibilities of the role, such as the extent to which the role will involve contact with children
• Whether or not the role is exempt from the Rehabilitation of Offenders Act 1974 and the amendments to the Exceptions Order 1975, 2013 and 2020. If the role is exempt, certain spent convictions and cautions are ‘protected’, so they do not need to be disclosed, and if they are disclosed, we cannot take them into account

Application forms

Our application forms will:

• Include a statement saying that it is an offence to apply for the role if an applicant is barred from engaging in regulated activity relevant to children (where the role involves this type of regulated activity)
• Include a copy of, or link to, our child protection and safeguarding policy and our policy on the employment of ex-offenders

Shortlisting

Our shortlisting process will involve at least 2 people and will:

• Consider any inconsistencies and look for gaps in employment and reasons given for them
• Explore all potential concerns
• Once we have shortlisted candidates, we will ask shortlisted candidates to:
• Complete a self-declaration of their criminal record or any information that would make them unsuitable to work with children, so that they can share relevant information and discuss it at interview stage. The information we will ask for includes:

• If they have a criminal history
• Whether they are included on the barred list
• Whether they are prohibited from teaching
• Information about any criminal offences committed in any country in line with the law as applicable in England and Wales
• Any relevant overseas information

• Sign a declaration confirming the information they have provided is true

We will also consider carrying out an online search on shortlisted candidates to help identify any incidents or issues that are publicly available online and candidates will be informed that this check may happen.

Seeking references and checking employment history

We will obtain references before interview. Any concerns raised will be explored further with referees and taken up with the candidate at interview.  

When seeking references we will:

• Not accept open references
• Liaise directly with referees and verify any information contained within references with the referees
• Ensure any references are from the candidate’s current employer and completed by a senior person. Where the referee is school based, we will ask for the reference to be confirmed by the Headteacher/principal as accurate in respect to disciplinary investigations
• Obtain verification of the candidate’s most recent relevant period of employment if they are not currently employed
• Secure a reference from the relevant employer from the last time the candidate worked with children if they are not currently working with children
• Compare the information on the application form with that in the reference and take up any inconsistencies with the candidate
• Resolve any concerns before any appointment is confirmed  

Interview and selection

When interviewing candidates, we will:

• Probe any gaps in employment, or where the candidate has changed employment or location frequently, and ask candidates to explain this
• Explore any potential areas of concern to determine the candidate’s suitability to work with children
• Record all information considered and decisions made

Pre-appointment vetting checks

We will record all information on the checks carried out in the school’s single central record (SCR). Copies of these checks, where appropriate, will be held in individuals’ personnel files. We follow requirements and best practice in retaining copies of these checks, as set out below.

New staff

All offers of appointment will be conditional until satisfactory completion of the necessary pre-employment checks. When appointing new staff, we will:

• Verify their identity
• Obtain (via the applicant) an enhanced DBS certificate, including barred list information for those who will be engaging in regulated activity (see definition below). We will obtain the certificate before, or as soon as practicable after, appointment, including when using the DBS update service. We will not keep a copy of the certificate for longer than 6 months, but when the copy is destroyed we may still keep a record of the fact that vetting took place, the result of the check and recruitment decision taken
• Obtain a separate barred list check if they will start work in regulated activity before the DBS certificate is available
• Verify their mental and physical fitness to carry out their work responsibilities
• Verify their right to work in the UK. We will keep a copy of this verification for the duration of the member of staff’s employment and for 2 years afterwards
• Verify their professional qualifications, as appropriate
• Ensure they are not subject to a prohibition order if they are employed to be a teacher. For non-teaching staff who will be pupil facing we will check their name against the prohibition from teaching list.
• Carry out further additional checks, as appropriate, on candidates who have lived or worked outside of the UK. These could include, where available:

• For all staff, including teaching positions: criminal records checks for overseas applicants
• For teaching positions: obtaining a letter from the professional regulating authority in the country where the applicant has worked, confirming that they have not imposed any sanctions or restrictions on that person, and/or are aware of any reason why that person may be unsuitable to teach

• Check that candidates taking up a management position* are not subject to a prohibition from management (section 128) direction made by the secretary of state
• Management positions are most likely to include, but are not limited to, Headteachers, principals and deputy/assistant Headteachers.

Schools with pupils aged under 8 will ensure that appropriate checks are carried out to ensure that individuals are not disqualified under the 2018 Childcare Disqualification Regulations and Childcare Act 2006. Where we take a decision that an individual falls outside of the scope of these regulations and we do not carry out such checks, we will retain a record of our assessment on the individual’s personnel file. This will include our evaluation of any risks and control measures put in place, and any advice sought.

Regulated activity means a person who will be:

• Responsible, on a regular basis in a school or college, for teaching, training, instructing, caring for or supervising children; or
• Carrying out paid, or unsupervised unpaid, work regularly in a school or college where that work provides an opportunity for contact with children; or
• Engaging in intimate or personal care or overnight activity, even if this happens only once and regardless of whether they are supervised or not

Existing staff

In certain circumstances we will carry out all the relevant checks on existing staff as if the individual was a new member of staff. These circumstances are when:

• There are concerns about an existing member of staff’s suitability to work with children; or
• An individual moves from a post that is not regulated activity to one that is; or
• There has been a break in service of 12 weeks or more
• We will refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult where:
• We believe the individual has engaged in relevant conduct; or
• We believe the individual has received a caution or conviction for a relevant (automatic barring either with or without the right to make representations) offence, under the Safeguarding Vulnerable Groups Act 2006 (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009; or
• We believe the ‘harm test’ is satisfied in respect of the individual (i.e. they may harm a child or vulnerable adult or put them at risk of harm); and
• The individual has been removed from working in regulated activity (paid or unpaid) or would have been removed if they had not left

Agency and third-party staff

We will obtain written notification from any agency or third-party organisation that it has carried out the necessary safer recruitment checks that we would otherwise perform. We will also check that the person presenting themselves for work is the same person on whom the checks have been made.

Contractors

We will ensure that any contractor, or any employee of the contractor, who is to work at the school has had the appropriate level of DBS check (this includes contractors who are provided through a PFI or similar contract). This will be:

• An enhanced DBS check with barred list information for contractors engaging in regulated activity
• An enhanced DBS check, not including barred list information, for all other contractors who are not in regulated activity but whose work provides them with an opportunity for regular contact with children
• We will obtain the DBS check for self-employed contractors.
• We will not keep copies of such checks for longer than 6 months.
• Contractors who have not had any checks will not be allowed to work unsupervised or engage in regulated activity under any circumstances.

TCAT Academies with pupils aged under 8 will:

For self-employed contractors such as music teachers or sports coaches, we will ensure that appropriate checks are carried out to ensure that individuals are not disqualified under the 2018 Childcare Disqualification Regulations and Childcare Act 2006. Where we decide that an individual falls outside of the scope of these regulations and we do not carry out such checks, we will retain a record of our assessment. This will include our evaluation of any risks and control measures put in place, and any advice sought.

Trainee/student teachers

Where applicants for initial teacher training are salaried by us, we will ensure that all necessary checks are carried out.

Where trainee teachers are fee-funded, we will obtain written confirmation from the training provider that necessary checks have been carried out and that the trainee has been judged by the provider to be suitable to work with children.

TCAT Academies with pupils under 8 will in both cases check to ensure that individuals are not disqualified under the 2018 Childcare Disqualification Regulations and Childcare Act 2006.

Volunteers

We will:

• Never leave an unchecked volunteer unsupervised or allow them to work in regulated activity
• Obtain an enhanced DBS check with barred list information for all volunteers who are new to working in regulated activity
• Carry out a risk assessment when deciding whether to seek an enhanced DBS check without barred list information for any volunteers not engaging in regulated activity. We will retain a record of this risk assessment

TCAT academies with pupils aged under 8 will:

• Ensure that appropriate checks are carried out to ensure that individuals are not disqualified under the 2018 Childcare Disqualification Regulations and Childcare Act 2006. Where we decide that an individual falls outside of the scope of these regulations and we do not carry out such checks, we will retain a record of our assessment. This will include our evaluation of any risks and control measures put in place, and any advice sought

Governors and members

All governors and trustees will have an enhanced DBS check without barred list information.

They will have an enhanced DBS check with barred list information if working in regulated activity

The Chair of the Trust board will have their DBS check countersigned by the secretary of state.  

All proprietors, trustees, local governors and members will also have the following checks:

• A section 128 check (to check prohibition on participation in management under section 128 of the Education and Skills Act 2008). [Section 128 checks are only required for local governors if they have retained or been delegated any management responsibilities.]
• Identity
• Right to work in the UK

Adults who supervise pupils on work experience

When organising work experience, we will ensure that policies and procedures are in place to protect children from harm.

We will also consider whether it is necessary for barred list checks to be carried out on the individuals who supervise a pupil under 16 on work experience. This will depend on the specific circumstances of the work experience, including the nature of the supervision, the frequency of the activity being supervised, and whether the work is regulated activity.

Pupils staying with host families

Where the school makes arrangements for pupils to be provided with care and accommodation by a host family to which they are not related (for example, during a foreign exchange visit), we will request enhanced DBS checks with barred list information on those people.

Where the school is organising such hosting arrangements overseas and host families cannot be checked in the same way, we will work with our partner schools abroad to ensure that similar assurances are undertaken prior to the visit.

Appendix 3: Allegations of Abuse against Staff

Section 1: Allegations that may meet the harms threshold

This section applies to all cases in which it is alleged that a current member of staff, including a supply teacher, volunteer or contractor, 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 they 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 children – this includes behaviour taking place both inside and outside of school

If we are in any doubt as to whether a concern meets the harm threshold, we will consult out local authority designated officer (LADO).

We will deal with any allegation of abuse quickly, 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 Headteacher, or the chair of governors, where the Headteacher is the subject of the allegation. The case manager will be identified at the earliest opportunity.

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

Suspension of the accused until the case is resolved

Suspension of the accused 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 there 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.

Based on an assessment of risk, we will consider alternatives such as:

• Redeployment within the school so that the individual does not have direct contact with the child or children concerned
• Providing an assistant to be present when the individual has contact with children
• Redeploying the individual to alternative work in the school so that they do not have unsupervised access to children
• Moving the child or children to classes where they will not come into contact with the individual, making it clear that this is not a punishment and parents/carers have been consulted
• Temporarily redeploying the individual to another role in a different location, for example to an alternative school or other work for the Trust

If in doubt, the case manager will seek views from the school’s personnel adviser and the designated officer at the local authority, as well as the police and children’s social care where they have been involved.

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, or to cause harm to the subject of the allegation
• 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 at the school is justified or whether alternative arrangements such as those outlined above can be put in place. Advice will be sought from the designated officer, police and/or children’s social care services, as appropriate
• Where the case manager is concerned about the welfare of other children in the community or the individual’s family, they will discuss these concerns with the DSL and make a risk assessment of the situation. If necessary, the DSL may make a referral to children’s social care
• 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 allegation
• 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. Support will be provided by a dedicated person from within the academy often the member of staff responsible for personnel and further support will be provided by TCAT Human Resources Lead.
• 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 teachers (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of a teacher 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

TCAT Academies with pupils under 8 will:

Inform Ofsted of any allegations of serious harm or abuse by any person living, working, or looking after children at the premises (whether the allegations relate to harm or abuse committed on the premises or elsewhere), and any action taken in respect of the allegations. This notification will be made as soon as reasonably possible and always within 14 days of the allegations being made.

If the school is made aware that the secretary of state has made an interim prohibition order in respect of an individual, we will immediately suspend that individual from teaching, pending the findings of the investigation by the Teaching Regulation Agency.

Where the police are involved, wherever possible the school will ask the police at the start of the investigation to obtain consent from the individuals involved to share their statements and evidence for use in the school’s disciplinary process, should this be required at a later point.

Additional considerations for supply teachers and all contracted staff

If there are concerns or an allegation is made against someone not directly employed by the school, such as a supply teacher or contracted staff member provided by an agency, we will take the actions below in addition to our standard procedures.

• We will not decide to stop using an individual due to safeguarding concerns without finding out the facts and liaising with our LADO to determine a suitable outcome
• The Headteacher/Principal will discuss with the agency whether it is appropriate to suspend the individual, or redeploy them to another part of the school, while the school carries out the investigation
• We will involve the agency fully, but the school will take the lead in collecting the necessary information and providing it to the LADO as required
• We will address issues such as information sharing, to ensure any previous concerns or allegations known to the agency are taken into account (we will do this, for example, as part of the allegations management meeting or by liaising directly with the agency where necessary)

When using an agency, we will inform them of our process for managing allegations, and keep them updated about our policies as necessary, and will invite the agency's HR manager or equivalent to meetings as appropriate.

Timescales

We will deal with all allegations as quickly and effectively as possible and will endeavour to comply with the following timescales, where reasonably practicable:

• Any cases where it is clear immediately that the allegation is unsubstantiated or malicious should be resolved within 1 week
• If the nature of an allegation does not require formal disciplinary action, appropriate action should be taken within 3 working days
• If a disciplinary hearing is required and can be held without further investigation, this should be held within 15 working days

However, these are objectives only and where they are not met, we will endeavour to take the required action as soon as possible thereafter.

Specific actions

Action following a criminal investigation or prosecution

The case manager will discuss with the local authority’s designated officer whether any further action, including disciplinary action, is appropriate and, if so, how to proceed, taking into account information provided by the police and/or children’s social care services.

Conclusion of a case where the allegation is substantiated

If the allegation is substantiated and the individual is dismissed or the school ceases to use their services, or the individual resigns or otherwise ceases to provide their services, the school will make a referral to the DBS for consideration of whether inclusion on the barred lists is required.

If the individual concerned is a member of teaching staff, the school will consider whether to refer the matter to the Teaching Regulation Agency to consider prohibiting the individual from teaching.

Individuals returning to work after suspension

If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.

The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation, if they are still attending the school.

Unsubstantiated, unfounded, false or malicious reports

If a report is:

• Determined to be unsubstantiated, unfounded, false or malicious, the DSL will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to children’s social care may be appropriate
• Shown to be deliberately invented, or malicious, the school will consider whether any disciplinary action is appropriate against the individual(s) who made it

Unsubstantiated, unfounded, false or malicious allegations

If an allegation is:

• Determined to be unsubstantiated, unfounded, false or malicious, the LADO and case manager will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to children’s social care may be appropriate
• Shown to be deliberately invented, or malicious, the school will consider whether any disciplinary action is appropriate against the individual(s) who made it

Confidentiality and information sharing        

The school will make every effort to maintain confidentiality and guard against unwanted publicity while an allegation is being investigated or considered.

The case manager will take advice from the LADO, police and children’s social care services, as appropriate, to agree:

• Who needs to know about the allegation and what information can be shared
• How to manage speculation, leaks and gossip, including how to make parents or carers of a child/children involved aware of their obligations with respect to confidentiality
• What, if any, information can be reasonably given to the wider community to reduce speculation
• How to manage press interest if, and when, it arises

Record-keeping

The case manager will maintain clear records about any case where the allegation or concern meets the criteria above and store them on the individual’s confidential personnel file for the duration of the case.

The records of any allegation that, following an investigation, is found to be malicious or false will be deleted from the individual’s personnel file (unless the individual consents for the records to be retained on the file).

For all other allegations (which are not found to be malicious or false), the following information will be kept on the file of the individual concerned:

• A clear and comprehensive summary of the allegation
• Details of how the allegation was followed up and resolved
• Notes of any action taken, decisions reached and the outcome
• A declaration on whether the information will be referred to in any future reference

In these cases, the school will provide a copy to the individual, in agreement with children’s social care or the police as appropriate.

Where records contain information about allegations of sexual abuse, we will preserve these for the Independent Inquiry into Child Sexual Abuse (IICSA), for the term of the inquiry. We will retain all other records at least until the individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer.

References

When providing employer references, we will:

• Not refer to any allegation that has been found to be false, unfounded, unsubstantiated or malicious, or any repeated allegations which have all been found to be false, unfounded, unsubstantiated or malicious
• Include substantiated allegations, provided that the information is factual and does not include opinions

Learning lessons

After any cases where the allegations are substantiated, the case manager will review the circumstances of the case with the local authority’s designated officer to determine whether there are any improvements that we can make to the school’s procedures or practice to help prevent similar events in the future.

This will include consideration of (as applicable):

• Issues arising from the decision to suspend the member of staff
• The duration of the suspension
• Whether or not the suspension was justified
• The use of suspension when the individual is subsequently reinstated. We will consider how future investigations of a similar nature could be carried out without suspending the individual

For all other cases, the case manager will consider the facts and determine whether any improvements can be made.

Non-recent allegations

Abuse can be reported, no matter how long ago it happened.

We will report any non-recent allegations made by a child to the LADO in line with our local authority’s procedures for dealing with non-recent allegations.

Where an adult makes an allegation to the school that they were abused as a child, we will advise the individual to report the allegation to the police.

Section 2: Concerns that do not meet the harm threshold

This section applies to all concerns (including allegations) about members of staff, including supply teachers, volunteers and contractors, which do not meet the harm threshold set out in section 1 above.

Concerns may arise through, for example:

• Suspicion
• Complaint
• Safeguarding concern or allegation from another member of staff
• Disclosure made by a child, parent or other adult within or outside the school
• Pre-employment vetting checks

We recognise the importance of responding to and dealing with any concerns in a timely manner to safeguard the welfare of children.

Definition of low-level concerns

The term ‘low-level’ concern is any concern – no matter how small – that an adult working in or on behalf of the school may have acted in a way that:

• Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and
• Does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the designated officer at the local authority
• Examples of such behaviour could include, but are not limited to:
• Being overly friendly with children
• Having favourites
• Taking photographs of children on their mobile phone
• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door
• Humiliating pupils

Sharing low-level concerns

We recognise the importance of creating a culture of openness, trust and transparency to encourage all staff to confidentially share low-level concerns so that they can be addressed appropriately.

We will create this culture by:

• Ensuring staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others
• Empowering staff to share any low-level concerns as per section 7.7 of this policy
• Empowering staff to self-refer
• Addressing unprofessional behaviour and supporting the individual to correct it at an early stage
• Providing a responsive, sensitive and proportionate handling of such concerns when they are raised
• Helping to identify any weakness in the school’s safeguarding system

Responding to low-level concerns

If the concern is raised via a third party, the Headteacher will collect evidence where necessary by speaking:

• Directly to the person who raised the concern, unless it has been raised anonymously
• To the individual involved and any witnesses  

The Headteacher/principal will use the information collected to categorise the type of behaviour and determine any further action, in line with the Trust’s code of conduct]. The headteacher will be the ultimate decision-maker in respect of all low-level concerns, though they may wish to collaborate with the DSL.  

For managing low level concerns TCAT Academies should follow the LADO and Low Level Concern Policy

LADO and Low Level Concerns Protocol 2025.pdf

Record keeping

All low-level concerns will be recorded in writing. In addition to details of the concern raised, records will include the context in which the concern arose, any action taken and the rationale for decisions and action taken.

Records will be:

• Kept confidential, held securely and comply with the DPA 2018 and UK GDPR
• Reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. Where a pattern of such behaviour is identified, we will decide on a course of action, either through our disciplinary procedures or, where a pattern of behaviour moves from a concern to meeting the harms threshold as described in section 1 of this appendix, we will refer it to the designated officer at the local authority
• Retained at least until the individual leaves employment at the school 

Where a low-level concern relates to a supply teacher or contractor, we will notify the individual’s employer, so any potential patterns of inappropriate behaviour can be identified.

References 

We will not include low-level concerns in references unless:

• The concern (or group of concerns) has met the threshold for referral to the designated officer at the local authority and is found to be substantiated; and/or
• The concern (or group of concerns) relates to issues which would ordinarily be included in a reference, such as misconduct or poor performance

Appendix 4: Specific Safeguarding Issues

This appendix is mostly based on the advice in Keeping Children Safe in Education, in particular annex B – it identifies key aspects of Safeguarding that staff need to be aware of.

Children missing from education

A child being absent from education – deliberately missing education for prolonged periods and/or on repeat can act as a warning sign to a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation, or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage. Supporting children who are absent from education helps prevent the risk of them becoming a child missing education in the future

There are many circumstances where a child may become missing from education, but some children are particularly at risk. These include children who:

• Are at risk of harm or neglect
• Are at risk of forced marriage or FGM
• Come from Gypsy, Roma, or Traveller families
• Come from the families of service personnel
• Go missing or run away from home or care
• Are supervised by the youth justice system
• Cease to attend a school
• Come from new migrant families

We will follow our procedures for unauthorised absence and for dealing with children who are absent from education, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual exploitation, and to help prevent the risks of becoming missing from education in the future. This includes informing the local authority if a child leaves the school without a new school being named, and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points.

Warrington - School attendance | warrington.gov.uk

St Helens – Child missing from education - St Helens Borough Council

Wirral – Wirral Attendance Team | wirral.gov.uk

Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being missing, such as travelling to conflict zones, FGM and forced marriage.

If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries. We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger

Child criminal exploitation

Child criminal exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity, in exchange for something the victim needs or wants, and/or for the financial or other advantage of the perpetrator or facilitator, and/or through violence or the threat of violence.

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. For example, young people may be forced to work in cannabis factories, coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.

Indicators of CCE can include a child:

• Appearing with unexplained gifts or new possessions
• Associating with other young people involved in exploitation
• Suffering from changes in emotional wellbeing
• Misusing drugs and alcohol
• Going missing for periods of time or regularly coming home late
• Regularly missing school or education
• Not taking part in education

If a member of staff suspects CCE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

Child sexual exploitation

Child sexual exploitation (CSE) is a form of child sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, in exchange for something the victim needs or wants and/or for the financial advantage or increased status of the perpetrator or facilitator. It may, or may not, be accompanied by violence or threats of violence.

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. Children or young people who are being sexually exploited may not understand that they are being abused. They often trust their abuser and may be tricked into believing they are in a loving, consensual relationship.

CSE can include both physical contact (penetrative and non-penetrative acts) and non-contact sexual activity. It can also happen online. For example, young people may be persuaded or forced to share sexually explicit images of themselves, have sexual conversations by text, or take part in sexual activities using a webcam. CSE may also occur without the victim’s immediate knowledge, for example through others copying videos or images.

In addition to the CCE indicators above, indicators of CSE can include a child:

• Having an older boyfriend or girlfriend
• Suffering from sexually transmitted infections or becoming pregnant

If a member of staff suspects CSE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

Child-on-child abuse

Child-on-child abuse is when children abuse other children. This type of abuse can take place inside and outside of school. It can also take place both face-to-face and online, and can occur simultaneously between the 2.

Our school has a zero-tolerance approach to sexual violence and sexual harassment. We recognise that even if there are there no reports, that doesn’t mean that this kind of abuse isn’t happening.

Child-on-child abuse is most likely to include, but may not be limited to:

• Bullying (including cyber-bullying, prejudice-based and discriminatory bullying)
• Abuse in intimate personal relationships between children (this is sometimes known as ‘teenage relationship abuse’)
• Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)
• Sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence)
• Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse
• Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party
• Consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery)
• Upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm
• 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 and may also include an online element)

Where children abuse their peers online, this can take the form of, for example, abusive, harassing, and misogynistic messages; the non-consensual sharing of indecent images, especially around chat groups; and the sharing of abusive images and pornography, to those who don't want to receive such content.

If staff have any concerns about child-on-child abuse, or a child makes a report to them, they will follow the procedures set out in section 7 of this policy, as appropriate. In particular, section 7.8 and 7.9 set out more detail about our school’s approach to this type of abuse.

When considering instances of harmful sexual behaviour between children, we will consider their ages and stages of development. We recognise that children displaying harmful sexual behaviour have often experienced their own abuse and trauma, and will offer them appropriate support.

County lines

County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or other form of “deal line”. Exploitation is an integral part of the county lines offending model with children exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools, further and higher educational institutions, pupil referral units, special educational needs schools, children’s homes and care homes.

Children are often recruited to move drugs and money between locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection. Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network. One of the ways of identifying potential involvement in county lines are missing episodes (both from home and school), when the victim may have been trafficked for the purpose of transporting drug. If a pupil is suspected to be at risk of or involved in county lines a member of staff will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and police, if appropriate using referral through to CESOG.

Domestic abuse

Children can witness and be adversely affected by domestic abuse and/or violence at home where it occurs between family members. Children can be victims of abuse if they hear, see or experience domestic violence. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse (abuse in intimate personal relationships between children) and child/adolescent to parent violence and abuse. It can be physical, sexual, financial, psychological or emotional. It can also include ill treatment that isn’t physical, as well as witnessing the ill treatment of others – for example, the impact of all forms of domestic abuse on children.

Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home. Children who witness domestic abuse are also victims

Older children may also experience and/or be the perpetrators of domestic abuse and/or violence in their own personal relationships. This can include sexual harassment.

Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children and affect their health, wellbeing, development and ability to learn.

If police are called to an incident of domestic abuse and any children in the household have experienced the incident, the police will inform the key adult in school (usually the designated safeguarding lead) before the child or children arrive at school the following day. This is the procedure where police forces in the areas where the child lives are part of Operation Encompass – School may also be made aware if the incident via a VPA (Vulnerable Person’s Assessment) However, schools become informed appropriate supportive measures for the pupil should be implemented and the incident logged on CPOMS.  

Homelessness

Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare.

The DSL [and deputy/deputies] will be aware of contact details and referral routes in to the local housing authority so they can raise/progress concerns at the earliest opportunity (where appropriate and in accordance with local procedures).

Where a child has been harmed or is at risk of harm, the DSL will also make a referral to children’s social care.

So-called ‘honour-based’ abuse (including FGM and forced marriage)

So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes committed to protect or defend the honour of the family and/or community, including FGM, forced marriage, and practices such as breast ironing.

Abuse committed in this context often involves a wider network of family or community pressure and can include multiple perpetrators.

All forms of HBA are abuse and will be handled and escalated as such. All staff will be alert to the possibility of a child being at risk of HBA or already having suffered it. If staff have a concern, they will speak to the DSL, who will activate local safeguarding procedures.

FGM

The DSL will make sure that staff have access to appropriate training to equip them to be alert to children affected by FGM or at risk of FGM.

Section 7.3 of this policy sets out the procedures to be followed if a staff member discovers that an act of FGM appears to have been carried out or suspects that a pupil is at risk of FGM.

Indicators that FGM has already occurred include:

• A pupil confiding in a professional that FGM has taken place
• A mother/family member disclosing that FGM has been carried out
• A family/pupil already being known to social services in relation to other safeguarding issues
• A girl:

• Having difficulty walking, sitting or standing, or looking uncomfortable
• Finding it hard to sit still for long periods of time (where this was not a problem previously)
• Spending longer than normal in the bathroom or toilet due to difficulties urinating
• Having frequent urinary, menstrual or stomach problems
• Avoiding physical exercise or missing PE
• Being repeatedly absent from school, or absent for a prolonged period
• Demonstrating increased emotional and psychological needs – for example, withdrawal or depression, or significant change in behaviour
• Being reluctant to undergo any medical examinations
• Asking for help, but not being explicit about the problem
• Talking about pain or discomfort between her legs

Potential signs that a pupil may be at risk of FGM include:

• The girl’s family having a history of practising FGM (this is the biggest risk factor to consider)
• FGM being known to be practised in the girl’s community or country of origin
• A parent or family member expressing concern that FGM may be carried out
• A family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues

A girl:

• Having a mother, older sibling or cousin who has undergone FGM
• Having limited level of integration within UK society
• Confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”
• Talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents/carers stating that they or a relative will take the girl out of the country for a prolonged period
• Requesting help from a teacher or another adult because she is aware or suspects that she is at immediate risk of FGM
• Talking about FGM in conversation – for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)
• Being unexpectedly absent from school
• Having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication

The above indicators and risk factors are not intended to be exhaustive

Forced marriage

Forcing a person into marriage is a crime. It is a crime to carry out any conduct whose purpose is to cause a child to marry before their 18th birthday, even if violence, threats or another form of coercion are not used. This applies to non-binding, unofficial ‘marriages’ as well as legal marriages. A forced marriage is one entered into without the full and free consent of 1 or both parties and where violence, threats, or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological.

Staff will receive training around forced marriage and the presenting symptoms. We are aware of the ‘1 chance’ rule, i.e. we may only have 1 chance to speak to the potential victim and only 1 chance to save them.

If a member of staff suspects that a pupil is being forced into marriage, they will speak to the pupil about their concerns in a secure and private place. They will then report this to the DSL.

The DSL will:

• Speak to the pupil about the concerns in a secure and private place
• Activate the local safeguarding procedures and refer the case to the local authority’s designated officer
• Seek advice from the Forced Marriage Unit on 020 7008 0151 or fmu@fco.gov.uk
• Refer the pupil to an education welfare officer, pastoral tutor, learning mentor, or school counsellor, as appropriate

Preventing radicalisation

Radicalisation refers to the process by which a person legitimising support  for or use of terrorists violence’

Extremism is vocal or active opposition to fundamental British values, such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs. This also includes calling for the death of members of the armed forces

Terrorism is an action that:

• Endangers or causes serious violence to a person/people;
• Causes serious damage to property; or
• Seriously interferes or disrupts an electronic system

The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.

Schools have a duty to prevent children from being drawn into terrorism. The DSL will undertake Prevent awareness training and make sure that staff have access to appropriate training to equip them to identify children at risk.

We will assess the risk of children in our school being drawn into terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.

We will ensure that suitable internet filtering is in place and equip our pupils to stay safe online at school and at home.

There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. Radicalisation can occur quickly or over a long period.

Staff will be alert to changes in pupils’ behaviour.

The government website Educate Against Hate and charity NSPCC say that signs that a pupil is being radicalised can include:

• Refusal to engage with, or becoming abusive to, peers who are different from themselves
• Becoming susceptible to conspiracy theories and feelings of persecution
• Changes in friendship groups and appearance
• Rejecting activities they used to enjoy
• Converting to a new religion
• Isolating themselves from family and friends
• Talking as if from a scripted speech
• An unwillingness or inability to discuss their views
• A sudden disrespectful attitude towards others
• Increased levels of anger
• Increased secretiveness, especially around internet use
• Expressions of sympathy for extremist ideologies and groups, or justification of their actions
• Accessing extremist material online, including on Facebook or Twitter
• Possessing extremist literature
• Being in contact with extremist recruiters and joining, or seeking to join, extremist organisations

Children who are at risk of radicalisation may have low self-esteem, or be victims of bullying or discrimination. It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong.

If staff are concerned about a pupil, they will follow our procedures set out in section 7.5 of this policy, including discussing their concerns with the DSL.

Staff should always take action if they are worried.

All TCAT academies deliver education on Equality and Diversity including Fundamental British Values within their Personal Development and PSHE curriculums and extra-curricular aspects of school.

Sexual violence and sexual harassment between children in schools

Sexual violence and sexual harassment can occur:

• Between 2 children of any age and sex
• Through a group of children sexually assaulting or sexually harassing a single child or group of children
• Online and face to face (both physically and verbally)

Sexual violence and sexual harassment exist on a continuum and may overlap.

Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same school.

If a victim reports an incident, it is essential that staff make sure they are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting any form of abuse or neglect. Nor should a victim ever be made to feel ashamed for making a report.

When supporting victims, staff will:

• Reassure victims that the law on child-on-child abuse is there to protect them, not criminalise them
• Regularly review decisions and actions, and update policies with lessons learnt
• Look out for potential patterns of concerning, problematic or inappropriate behaviour, and decide on a course of action where we identify any patterns
• Consider if there are wider cultural issues within the school that enabled inappropriate behaviour to occur and whether revising policies and/or providing extra staff training could minimise the risk of it happening again
• Remain alert to the possible challenges of detecting signs that a child has experienced sexual violence, and show sensitivity to their needs

Some groups are potentially more at risk. Evidence shows that girls, children with SEN and/or disabilities, and lesbian, gay, bisexual and Gender Questioning Children are at greater risk.

Staff should be aware of the importance of:

• Challenging inappropriate behaviours
• Making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up
• Challenging physical behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them

If staff have any concerns about sexual violence or sexual harassment, or a child makes a report to them, they will follow the procedures set out in section 7 of this policy, as appropriate. In particular, section 7.8 and 7.9 set out more detail about our school’s approach to this type of abuse.

Serious violence

Indicators which may signal that a child is at risk from, or involved with, serious violent crime may include:

• Increased absence from school
• Change in friendships or relationships with older individuals or groups
• Significant decline in performance
• Signs of self-harm or a significant change in wellbeing
• Signs of assault or unexplained injuries
• Unexplained gifts or new possessions (this could indicate that the child has been approached by, or is involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation (see above)

Risk factors which increase the likelihood of involvement in serious violence include:

• Being male
• Having been frequently absent or permanently excluded from school
• Having experienced child maltreatment
• Having been involved in offending, such as theft or robbery

Staff will be aware of these indicators and risk factors. If a member of staff has a concern about a pupil being involved in, or at risk of, serious violence, they will report this to the DSL.

Checking the identity and suitability of visitors

All visitors will be required to verify their identity to the satisfaction of staff and sign in showing the reason for the visit and who they are visiting. All visitors will be issued with a visitors badge.

Visitors to the school who are visiting for a professional purpose, such as educational psychologists and school improvement officers, will be asked to show photo ID and:

• Will be asked to show their DBS certificate, which will be checked alongside their photo ID; or
• The organisation sending the professional, such as the LA or educational psychology service, will provide prior written confirmation that an appropriate level of DBS check has been carried out (if this is provided, we will not ask to see the DBS certificate)

All other visitors, including visiting speakers, will be accompanied by a member of staff at all times. We will not invite into the school any speaker who is known to disseminate extremist views, and will carry out appropriate checks to ensure that any individual or organisation using school facilities is not seeking to disseminate extremist views or radicalise pupils or staff.

Non-collection of children

If a child is not collected at the end of the session/day, we will:

• Exhaust all points of contact to ensure that the child id collected
• Ensure those with responsibility are aware of their responsibility and the school duty in regard Safeguarding.

Missing pupils

Our procedures are designed to ensure that a missing child is found and returned to effective supervision as soon as possible. If a child goes missing for example are not in school when expected to be or have not returned home when expected, we will

• Consider the potential vulnerability of the child including consideration of age and whether they have other vulnerable factors
• Exhaust all possible points of contact including where appropriate safe direct contact to the pupils themselves.
• Ensure those with parental responsibility are informed unless we have sound reason to believe that this may out the child at greater risk. In this instance Social Care and Police will be informed.
• The overriding aim will be to ensure that the child is safe and to ensure the child is returned to the place that they should be,
• Details of the incident will be recorded on CPOMS and discussed with the DSL and Safeguarding Officer to assess risk for the pupil.

Child Abduction and community safety incidents

• Child abduction is when children are taken from their parents or carers without permission. It can be committed by parents or other family members, by people known but not related to the child (like neighbours, friends, acquaintances) and by strangers
• Community safety incidents are things like unknown adults loitering near school or trying to talk to children. When a school is made aware of this the DSL will liaise with the local Police to decide on appropriate actions.
• Always follow our pick-up procedures to make sure that children go home safely with their designated adult(s)

If you see anything suspicious that doesn’t feel right, report it immediately.

Modern Slavery

• This includes human trafficking and slavery, servitude and forced or compulsory labour
• The exploitation can take many forms for example sexual exploitation, forced labour, forced criminality and the removal of organs
• There Is national referral mechanisms for modern slavery- speak to your DSL if you need to know more about this.

Cybercrime

• This is defined as criminal activity committed using computers and/or the internet
• This includes activities such as hacking, ‘denial of service’ attacks (where a website is made
• available), and creating and using malware such as viruses
• Children who are particularly skilled in computing and technology may be drawn into cybercrime-either deliberately or inadvertently.

Children and the court system

Children are sometimes required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed. Similarly, making child arrangements via the family courts following separation can be stressful and entrench conflict in families. This can be particularly stressful for children. In both instances additional pastoral support will be offered to pupils affected and DSL will liaise with social care, police and other services to support pupils and their families.

Children with family members in prison

Approximately 200,000 children in England and Wales have a parent sent to prison each year. These children are at risk of poor outcomes including poverty, stigma, isolation and poor mental health. Any pupils who have a parent or carer in prison will be offered additional pastoral support as required and the DSL will liaise with police, probation and social care as required