Safeguarding for Under 18s Policy

Definitions and Scope

1. In accordance with the Children Act 1989 and 2004, a child is any person under the age of 18 years. This Policy applies to events and activities that may take place in person, on the Northeastern University London (“the University”) campus or elsewhere, or online anywhere that under 18s have any contact with University staff or students, or contractors. Activities delivered in a school are covered by the school’s own safeguarding procedures, and University staff will use their best endeavours to comply with these as required and as notified to them in advance in writing.
2. In accordance with the Children Act 1989 and 2004, in England a child is any person under the age of 18.
3. The safety and wellbeing of all University students, staff and children who participate in events or activities at the University, and visitors, contractors and other occupiers of the campus or neighbouring property, is essential. All University staff and students working for the University at these activities are responsible for safeguarding.
4. Children may be present at the University in a number of situations or be in contact with University staff or students including, but not limited to, the following:
   1. Participating in a summer school or other activity organised by the University;
   2. Attending open days, offer holder days or campus tours either as potential applicants or as part of a family group;
   3. Participating in or otherwise present because of an event or activity organised by a third-party organisation;
   4. Attending interviews for admission or as part of the recruitment process;
   5. Children that University staff, students or contractors encounter within buildings occupied by the University and by other organisations;
   6. Older children who are on placement as part of their own work experience;
   7. Children in the vicinity of the campus, which is located within a busy tourist district in central London;
   8. In some, but not all, of these situations the children may be accompanied by an adult, such as a parent, guardian or teacher who will be responsible for their safety.
5. The University, its staff, students and contractors are not responsible for ensuring the welfare or safety of children who are present on the University campus without the knowledge of the appropriately authorised University staff members.
6. This Policy must be read in conjunction with the following University policies, which apply as if they were written to include child safeguarding:
   1. Bullying, Harassment and Sexual Misconduct Policy
   2. Code of Behaviour for Summer School
   3. Health and Safety Policy
   4. Parent/Legal Guardian Agreement to Participate Form
   5. Prevent Policy
7. ‘Parent/guardian’ refers to the parent/guardian of the child. The parent/guardian must be an adult over the age of 18 who has responsibility for a participant’s wellbeing and safety. In some cases, this may not be a legal guardian but a responsible family member who can be contacted about the participant in an emergency. For the purposes of this document, ‘guardian’ also refers to ‘legal guardian’ as referenced throughout the Parent/Legal Guardian Agreement to Participate Form.

General

Policy Statement

8. Northeastern University London is committed to protecting the safety and wellbeing of all children taking part in events and activities at the University. All University staff and students working on activities are responsible for safeguarding.
9. This Policy demonstrates the University’s values, responsibility and statutory duties within UK legislation, policy and practice.
10. The University believes all children have the right to be treated equally and with respect, regardless of their background or personal circumstances.

University Responsibilities

11. The University recognises and acknowledges its responsibility to protect the welfare of, and to actively manage potential harm to, children taking part in events and activities at the University.
12. The University recognises its responsibility to take appropriate action when a child discloses that they are experiencing abuse or neglect, or if staff have a concern about the welfare of a child, and to ensure staff and Student Ambassadors understand what might indicate this and what action to take. Where an allegation is made about a staff member, the Human Resources Director will consider whether it is appropriate to invoke the Disciplinary Procedure for Staff. When an allegation is made about a student, the Student Regulation Resolution Office, on behalf of the Registrar, may consider whether it is appropriate to invoke the Disciplinary Procedure for Students.
13. The University has appointed a Designated Safeguarding Lead, who is responsible for the implementation of this Policy and to whom any safeguarding concerns will be reported and who will then discuss and agree the appropriate action to be taken. The Designated Safeguarding Lead has a Deputy (or other nominee) who acts in their place when they are on annual leave or are otherwise unavailable, or if a complaint or concern is raised about them. In the case that both the Designated Safeguarding Lead and the Deputy Designated Safeguarding Lead are off campus or otherwise unavailable, the Designated Safeguarding Lead will have nominated a third trained Safeguarding Officer to whom authority will have been delegated in advance.
14. If there is a complaint about the application of this Policy, it should be raised informally with the person concerned in the first instance, for example, if attending a Widening Participation event, the concern should be raised with the event organiser. If matters remain unresolved then the concern should be escalated to the Designated Safeguarding Lead or their deputy.
15. The University’s Designated Safeguarding Lead is:
    1. Head of Student Support and Development
16. The University’s Deputy Designated Safeguarding Lead is:
    1. Director of Business and Partnership Development & Apprenticeships
17. The University will maintain policies and procedures geared towards abuse prevention, including:
    1. Where staff or others are likely to have substantial unsupervised contact with children, the University requires them, to the extent lawfully permissible, to disclose any police and criminal record checks through Disclosure and Barring Service (DBS) checks for staff, contractors, students or others working on events and activities involving children. As a minimum the HR department may require DBS checks for roles that require this (typically those that involve regular unsupervised interactions with children). The University may be required to make a referral to the DBS when a staff member is dismissed or leaves following safeguarding allegations and where the DBS harm criteria are met;
    2. Disciplinary Procedure for Staff;
    3. Disciplinary Procedure for Students;
    4. Clear rules for staff and students to follow in the instance of a child entering the University;
    5. Staff induction and training;
    6. Confidential reporting procedure.
18. The University will arrange and ensure completion of necessary safeguarding training for all staff working on events and activities involving children.
19. The University ensures that full and accurate records are kept of all safeguarding concerns, in line with the University’s Data Protection Policy  and applicable procedures.
20. In line with the relevant University policies and procedures, anyone responsible for managing the personal data of children is expected to:
    1. Complete a Data Protection Impact Assessment (DPIA) before collecting and processing any personal data;
    2. Establish and document the lawful basis or bases for the processing of any personal or special category data;
    3. Comply with Data Protection Act 2018 requirements regarding the obtaining of consent from children;
    4. Pay special attention to the language used when collecting data from children, specifically when communicating the uses of their personal data and their rights in respect of this, e.g. via a Privacy Notice;
    5. Ensure that appropriate access and security controls are in place to protect the confidentiality of personal data;
    6. Only retain records containing personal data for as long as is necessary and according to the University’s records retention schedules;
    7. Dispose of records containing personal data in accordance with the University’s Information Security Policy.
21. The Data Protection Officer may be contacted where further advice and guidance are required on the processing of either safeguarding data or the personal data of children.

Individual Staff and Student Ambassador Responsibilities

22. University staff and Student Ambassadors understand that safeguarding is their responsibility, and that they are in a position of trust in relation to children, therefore they should:
    1. Treat all children, regardless of any protected characteristics under the Equality Act 2010, with respect and dignity and provide all with the same equity of opportunity;
    2. Read and familiarise themselves with this Policy;
    3. Attend all required safeguarding training and ensure this is kept up to date;
    4. Ensure they are aware of the reporting procedure and follow the procedures set out at all times. This includes reporting any safeguarding concerns to the University immediately, making a full and accurate record of the incident/concern as soon as possible;
    5. Maintain a professional relationship with children and their families. Under the Sexual Offences (Amendment) Act 2000, it is a criminal offence for any person in a position of trust to engage in sexual activity with a child.
23. They should not:
    1. Discuss their personal lives with children;
    2. Meet or arrange to meet children or their families privately away from University events or activities;
    3. Exchange personal contact details with children or their families, or connect with them on social media. Contact should be restricted to work communication channels to ensure a professional relationship is maintained;
    4. Be alone with a child; another adult or children should be present at all times. If a one-to-one meeting is necessary, it should take place in a room with an open door or with visual access;
    5. Display discriminatory or offensive language or behaviours;
    6. Engage in physical contact with children (unless absolutely necessary, for example giving first aid);
    7. Take gifts or money from children or their families;
    8. Give gifts or money to children or their families;
    9. Promise that a conversation will be kept confidential, since it is impossible to guarantee such confidentiality.

Ensuring Safe Practice at Events and Activities

Event Lead Responsibilities

24. All events and activities involving children should have an Event Lead who takes responsibility for initial decision-making during the event. A secondary member of staff (back-up) should be aware of all the arrangements in case the Event Lead is unavailable. This Event Lead should be a Manager or a member of the team with appropriate experience that they have delegated this to. The Event Lead is responsible for:
    1. Producing an appropriate and adequate written risk assessment;
    2. Ensuring that all staff and Student Ambassadors who are working on an event or activity are fully briefed and understand their role/responsibilities, including what to do in the event of an emergency;
    3. Gaining appropriate consent from parents/guardians in advance. The University will use best endeavours to ensure that parents/guardians and/or carers are aware of activities and have consented in advance of their child participating in any events. Parents, guardians and carers who bring children on to the University campus are at all times responsible for their safety and welfare and are obliged to ensure that the children in their care do not disturb others or damage any university property;
    4. Ensuring that the participants involved are adequately supervised for the duration of the event or activity. The University follows NSPCC guidance on the minimum ratio of appropriate adults to children:
       1. Age 9 – 12 years: one adult to eight children;
       2. Age 13 – 18 years: one adult to ten children;
       3. If taking children to an activity off campus the ratio should be: one adult to five children, regardless of age.
    5. Setting expectations of the standards of behaviour required from participants in advance, which may include asking participants and/or their parents/guardians to acknowledge they have read and agree to the participant code of behaviour, with relevant additions made for each event/activity as necessary;
    6. Building in time at the end of events to debrief with staff and provide them the opportunity to raise any concerns.

Working with External Organisations

25. The University partners with external organisations to deliver some events or activities, at the University or at other locations. For partnership working, the University requests a copy of the organisation’s child protection policy and provides them with the University’s relevant policies. The policy is reviewed by a manager who has oversight of the activity or partnership to ensure they are compatible. If any issues are identified, these are discussed, and a joint approach agreed in writing in advance.

Online Events

26. Any events or activities being run online must be delivered on appropriate platforms. All online platforms must:
    1. Be appropriate for the participants’ age group;
    2. Enable staff to restrict the audience to just the intended participants and staff members, including the ability to remove somebody from the session if necessary;
    3. Ensure that participant and staff personal information (e.g., contact information) is not visible to anybody else presenting or viewing the stream;
    4. Enable staff to control whether participants can have their videos/microphones on;
    5. Enable staff to prevent participants from sending private messages or chatting one-to-one with other participants.
27. Event Leads must ensure they have enough staff to support all online events. Participants must be supervised by at least two staff in every live online activity and at least one of those should hold an Enhanced DBS check.
28. Where possible, staff should not have one-to-one video calls with children. If this is unavoidable, the meeting should be recorded and saved in a secure location. Participants should be notified of this Policy at least 24 hours in advance.

What Constitutes Abuse?

29. In drawing up guidance locally, it needs to be recognised that the term ‘abuse’ can be subject to wide interpretation.
30. Abuse may consist of a single act, or repeated acts, and University staff should recognise that abuse is rarely a standalone event that can be covered by one definition or label. There are four main categories of abuse: neglect, physical abuse, emotional abuse and sexual abuse.
31. It is not always possible to recognise that someone is being or has been subjected to abuse; signs may not be obvious. University staff or Student Ambassadors are not responsible for investigating or deciding whether or not abuse is occurring, but it is always the University’s responsibility to report concerns. Possible signs of abuse include:
    1. Direct disclosures of verbal, emotional, physical or sexual abuse or neglect, or bullying, by anyone. Abuse can be current or historical. Children can be abused by other children as well as by adults;
    2. Third party disclosures (abuse happening to someone else);
    3. A child saying they want to tell a staff member or Student Ambassador something on the condition that it will be kept a secret;
    4. Hints about abuse in classwork, homework or conversations;
    5. Self-harm marks, bruises, burns or other injuries;
    6. Signs of disordered eating, anxiety or serious depression;
    7. A sudden change in behaviour, for example a person becoming very withdrawn when previously confident and happy;
    8. Serious aggression or inappropriate behaviour towards other children or University staff;
    9. Worrying language such as excessive swearing or sexualised comments;
    10. Seeming anxious about going home, or afraid of their parents being contacted;
    11. Talking about being pregnant, or having an older girlfriend or boyfriend.

Procedure if a Child Discloses Abuse by Someone Else

32. If a child makes a disclosure that they have suffered harm through abuse or neglect, the initial response should always be limited to listening carefully to what they say to fully understand their situation. Reassurance should be offered, and an explanation given as to what action will be taken.
33. It is vitally important that no promise is given that the information will be kept confidential.
34. The steps which should be followed are:
    1. Stay calm;
    2. Listen carefully to what the child is saying;
    3. Explain that it is likely that a limited number of other people will need to be informed – do not promise to keep information confidential;
    4. Allow the child to speak at their own pace. Ask questions that will give clarification but do not press them for answers or ask leading questions;
    5. Reassure the child that they have done the right thing by talking to someone;
    6. Make sure the child understands what will happen next, that the person in the University who is responsible for their protection will be notified and that the Local Authority Children’s Services may need to be contacted;
    7. Record the disclosure using the child’s/participant’s words where possible and noting time and date;
    8. Notify the Event Lead as soon as possible so they can report this to the Designated Safeguarding Lead;
    9. Do not discuss the disclosure with other staff; discussion should be strictly on a ‘need to know’ basis. Find out when the child is next due to see the individual who is the subject of the complaint: A judgement will need to be made as to the appropriate timing of any follow-up actions to ensure that the child remains safe.
35. Concerns about the welfare of a child, including the possibility of abuse or neglect, may also be raised by behaviour or other indicators noticed by a member of staff, but not directly disclosed by the child. In these instances, it is equally important to act, and these concerns should be raised and discussed with the Event Lead who should then report it to the Designated Safeguarding Lead.

Procedures for Dealing With Safeguarding Allegations or Concerns Regarding a Member of Staff or Student Ambassador

36. When dealing with safeguarding allegations or concerns involving a member of staff or a Student Ambassador, managers and Board Members must remember that the welfare of children at the University is paramount, but that the University also has a responsibility to ensure that University staff and Student Ambassadors are treated fairly and with respect.
37. A safeguarding allegation is one where information comes to light from any source and that suggests that an adult working for or on behalf of the University has or may have:
    1. Behaved in a way that has harmed a child or may have harmed a child;
    2. Committed a criminal offence against or related to a child;
    3. Behaved in such a way that calls into question their suitability to work with children.
38. Concerns should be reported to the Event Lead immediately so they can be raised with the Designated Safeguarding Lead;
39. If the concern relates to the Event Lead, it should be reported to the Designated Safeguarding Lead directly.

Confidentiality

40. Whatever the nature of the disclosure, suspicion, or complaint, it must be kept confidential, and information should only be shared, on a need-to-know basis, with the Event Lead and the Designated Safeguarding Lead. However, as above, no promise of confidentiality should be made as depending on the nature of the concern it may be necessary to involve the authorities.

Dealing with concerns relating to the ‘Prevent Duty’

41. According to the Counter-terrorism and Security Act 2015, under the ‘Prevent Duty’ universities are legally obliged to have due regard for the need to prevent people from being drawn into terrorism, also known as ‘radicalisation’. The University has no direct legal duty to take action under the ‘Prevent Duty’ with respect to the suspected radicalisation of children involved in University events or activities, as that falls to another agency (e.g. their school or college) although the University’s own obligations (if any) cannot be delegated to the organisers. However, University staff must report any concerns raised to the relevant authority, as set out below, so that they can take action. The NSPCC website contains a “Safeguarding checklist”, which event organisers may wish to use to inform what safeguarding measures they could put in place.
42. There is no single way of identifying a person who may be vulnerable to extremist ideology, and radicalisation can be difficult to spot. Signs that may indicate radicalisation include:
    1. Isolation from family and friends;
    2. Talking as if from a scripted speech;
    3. Unwillingness or inability to discuss their views;
    4. Expressing views that justify acts of violence or terrorism;
    5. A sudden disrespectful attitude towards others;
    6. Increased levels of anger or intolerance;
    7. Increased secretiveness, especially around internet use;
    8. Travelling for long periods but being vague about destinations;
    9. Buying or storing large amounts of chemicals for no obvious reason.
43. If University staff or Student Ambassadors have any concerns related to a child regarding radicalisation, they should:
    1. Make a full and accurate record of their concerns, noting the date and time;
    2. Notify the Event Lead as soon as possible, so they can report this to the Designated Safeguarding Lead and/or Prevent Lead.

Monitoring and Reviewing

This Policy is monitored and reviewed by the Designated Safeguarding Lead.

Version History

Annex 1: Child Protection Procedure for Events and Activities at the University

Events or Activities That Have Individual Participants (e.g., children attend without their parent/guardian or school)

1. For participants up to, and including, Year 11 or for those in Year 12 and 13 that last for more than one day, the University must receive:
   1. A signed Parent/Legal Guardian Agreement to Participate Form, including details of two emergency contacts and permission for their child to participate in the event or activities;
   2. An offer letter signed by the parent/guardian, agreeing to the terms and conditions of the event or activity.
2. The University must ensure that parents/guardians and participants have received the following information:
   1. Details on registration, including location and start and finish times;
   2. Activity timetable including catering information and details of any off-campus activities;
   3. Contact details for the activity, including an email address and emergency phone number that will be available during the event.
3. For all events and activities, accessibility, faith or dietary requirements must be obtained from the parent/guardian of the participant in advance.
4. The University is not responsible for children when they are travelling to and from the University. It is responsible for them from the moment they register at the University on the day of the activity until the end of the activity, whether on the University campus or at external sites such as museums. If a participant does not arrive, the following action may be taken:
   1. A designated staff member will call the participant to find out whether or not they will be attending. If they inform staff that they are no longer attending, this will be confirmed with the parent/guardian and the reason for absence will be recorded. If there is no response the staff member will contact their parent/guardian;
   2. If a child informs staff by phone that they are running late, but then do not arrive, the staff member should follow up and alert the parent/guardian if necessary;
   3. If a child does not arrive and the staff member cannot contact anyone by phone, they should send a follow up email to the child’s parent/guardian to notify them they have not arrived;
   4. A staff member will stay on the registration desk for any late arrivals.
5. If a participant in Year 11 or below needs to leave before the end of a scheduled activity, their parent/guardian should email or call the event staff in advance to explain that they give permission for their child to leave early. If this is not possible, the child should speak to the Event Lead on the day. The staff member will call their parent/guardian and will obtain verbal consent for them to leave the University at a set time.
6. At the end of a scheduled activity, children in Year 10 and above can leave when given permission to do so by University staff. For children in Year 9 or below, their parent/guardian must have given consent for them to leave unaccompanied. If participants need help in finding their way off campus and to the nearest bus stop, for example, staff should direct them.

Supervision During Events or Activities

7. The Event Lead is responsible for briefing and debriefing all staff working at the event or activity.
8. Expectations should be set with participants in the first session of an event or activity, and reiterated on subsequent occasions, if it is ongoing. Specific housekeeping arrangements should be announced, and participants should be reminded of the key points of the Code of Behaviour for Summer School, to include:
   1. To follow instructions from University staff or Student Ambassadors and stay with the group at all times;
   2. To engage with the activities, listen, and contribute thoughts and questions at the appropriate times;
   3. To show respect and kindness to classmates, staff and students;
   4. Not to use offensive or discriminatory language or discuss inappropriate subjects not related to the session topic;
   5. Not ask for the contact details of staff or try to contact University staff and students through their personal emails or social media accounts. University staff and students must not contact a person who is under 18 through their personal email or social media accounts;
   6. If a participant or visitor has any concerns, to tell an adult they trust and to contact University staff or ask a trusted adult to do so on their behalf;
   7. To follow the University’s Code of Behaviour for Summer School; any participant or visitor who does not do so may be asked to leave the activity and their parent/guardian will be contacted.
9. University staff and Student Ambassadors must always have a register with a list of children in their group and know whether they are present or absent that day. Group leaders must run head counts of their group at regular intervals, and before moving between locations:
   1. If they cannot find a child, they must alert the Event Lead immediately, check whether the child is with another group, then retrace their steps. If the child is not found, the Event Lead should phone the child. If they cannot be contacted and remain missing, the Event Lead should contact the Designated Safeguarding Lead.
10. If a child needs to go to the toilet, a staff member or a Student Ambassador can escort the group and wait outside to escort them back.
11. Some children may need to pray. Appropriate breaks for prayer should be planned into timetables. Children who need to pray should be gathered in one group and escorted by staff or Student Ambassadors to the prayer room, and then escorted back.
12. If a participant becomes ill during an activity:
    1. Staff should provide first aid, if appropriate;
    2. If the participant recovers, they should be encouraged to rejoin the group if they feel able to do so;
    3. If the participant is too ill to re-join the activity, a staff member will call their parent/guardian to inform them and can either send the participant home (with consent from the parent/guardian) or wait for their parent/guardian to collect them.
13. Challenging behaviour or inappropriate comments should be dealt with immediately, which may involve:
    1. Issuing a general reminder to all participants, or an individual, of expectations and asking them to abide by the Code of Behaviour for Summer School;
    2. Asking a participant to move seats or groups if they are causing disruption to others;
    3. Asking a participant to accompany staff away from the group so that there can be a discussion about their behaviour, what may be causing it, and possible consequences if the behaviour continues;
    4. Reconfiguring groups to minimise confrontation or disruptive behaviour;
    5. Contacting a parent/guardian to discuss the behaviour;
    6. Where there is a serious or repeated breach of the Code of Behaviour, the situation should be discussed with the Event Lead and the Designated Safeguarding Lead;
    7. Following discussion, a participant may be removed from the activity permanently and sent home, after staff have notified a parent/guardian and made arrangements for this to happen.

Events or Activities Supervised by Schools or Other External Organisations

14. The University does not need to collect parent/guardian consent forms for events organised as group visits with schools or other organisations.
15. Staff from the school or organisation arranging the visit are responsible for their students throughout their visit, and while travelling to and from the University. However, the University’s event organisers must satisfy themselves that appropriate measures are in place as it is no defence at law to avoid liability for prosecution by placing reliance on others to discharge the University’s duties on its behalf.
16. For activities such as campus tours where teachers cannot be present with all groups, University staff or Student Ambassadors are responsible for supervision until participants re-join the main group. The person leading the activity should ensure the group stay together and ensure that good health and safety practices are followed. It is not possible to guarantee the safety of children on the university campus. Prior authorisation for children to be on campus must be sought and obtained and the authorising person and the host must complete and submit a risk assessment to the Designated Safeguarding Lead or their deputy.

Events or Activities with Family Groups

17. Where children attend with parents/guardians, the parent/guardian is responsible for their child/children throughout the visit.
18. If there are any sections of the day when parents/guardians and children separate for different activities, University staff/Student Ambassadors are responsible for supervision until participants re-join their family members. The University’s usual supervision levels must be maintained and as above the person leading the activity should ensure the group stays together and that good health and safety practices are followed.

Annex 2: Useful Contact Information

External

• Childline: 0800 1111
• NSPCC: 0808 800 5000
• Police: If there are concerns about the immediate safety of a child, call 999 and ask for the police
• Tower Hamlets Safeguarding Children Partnership: http://www.childrenandfamiliestrust.co.uk/the-lscb/

Internal

• In the event of a first aid emergency, please contact one of the first aiders advertised on signage throughout the University premises or on the number below, who will provide assistance and call the emergency services if required. A list of the University’s first aid trained staff is posted in all kitchens and first aid rooms.Int
• Emergency contact numbers for Security and Facilities are:
  • First Aid: 02045 040485
  • Security: 07594 651771
  • Facilities: 02045 040174