Safeguarding Policy

Scope

1. Northeastern London University (the University) is committed to providing a safe and secure environment for all students, staff and visitors who access its facilities and services.
2. This Policy provides a framework for members of the University and contractors in the event that a safeguarding concern arises and to help the University prevent and respond appropriately to significant harm, abuse and exploitation.
3. The University accepts its responsibility to safeguard all its students in University life. It also accepts its responsibility to protect the welfare and wellbeing of any young child, young person or adult at risk who is engaged in University activity and/ or comes on to University premises. This responsibility covers disclosure of, or concerns of significant harm, abuse and/ or exploitation.
4. The University has trained staff to oversee safeguarding at the University and the Designated Safeguarding Lead has overall responsibility for the operational functions of this Policy.
5. Although there is no safeguarding legislation specifically for higher education, there are guidance documents, and in accordance with UK law the University has a statutory duty to have measures in place to protect and promote the wellbeing, health and safety and equal opportunities of its communities. This Policy is developed and reviewed with consideration of the legal frameworks below.
   1. Children Act 1989 and 2004
   2. UK GDPR
   3. Counter Terrorism and Security Act 2015
   4. Care Act 2014
   5. Equality Act 2010
   6. Safeguarding Vulnerable Groups Act 2006
   7. Mental Capacity Act 2005
   8. Sexual Offences Act 2005
   9. Female Genital Mutilation Act 2003
   10. Human Rights Act 1998

Definitions

6. For the University’s purposes an adult at risk is any person aged 18 or over who needs or may need community care services by reason of mental health or disability, age, or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against harm or exploitation.
7. In this Policy, ‘child and adult at risk’ means any person under 18 or an adult at risk.
8. This Policy applies to children and adults at risk who are either students registered at the University, those undertaking apprenticeships or Work Related Learning Programmes, those undertaking work experience/shadowing placements or visitors to the University.
9. A student is anyone registered with the University and enrolled on a programme or course of study leading to an award; this includes apprentices and global experience students.
10. The University has a duty of care to apprentices in their workplace (Annex A).
11. This Policy extends to University employees working off campus, including professional placements, visits to an apprentice’s place of work, widening participation, and recruitment activities in local schools, etc.

Safeguarding Procedure

12. This Policy must be read in conjunction with the following University policies:
    1. Support to Study Policy
    2. Student Welfare Policy
    3. Student Disability Policy
    4. Prevent Policy
    5. Health and Safety Policy
    6. Discrimination, Bullying, and Harassment Policy
    7. Sexual Misconduct Policy
    8. Personal Relationships between Staff & Students Policy
    9. Student Confidentiality Statement
    10. Disciplinary Procedure for Students
    11. Disciplinary Procedure for Staff
13. The Department for Education has defined Safeguarding as:
    1. Protecting children from maltreatment;
    2. Preventing impairment of children’s mental and physical health, or development;
    3. Ensuring that children grow up in circumstances consistent with the provision of safe and effective care;
    4. Taking action to enable all children to have the best outcomes.

Why is Safeguarding necessary in Higher Education?

14. Primary and secondary schools and further education colleges have a statutory duty to safeguard and protect young people in their care. The main legislation is the Children Act 1989, and the Safeguarding Vulnerable Groups Act 2006 as amended by the Protection of Freedoms Act 2012. This duty also applies to apprenticeship and work related learning programmes such as those delivered by the University.
15. There may be occasions where adult students become vulnerable to abuse or exploitation due to deterioration of their mental or physical health or because of personal circumstances and it may be appropriate for the University to act under this Policy to meet its general duty of care to deliver educational and pastoral services to the standard of an ordinarily competent institution.

General

Policy Statement

16. The University is committed to protecting the welfare of all its students, staff and visitors who access its services and activities. The University recognises that the best protection for students on its programmes is the vigilance and forethought of staff in preventing circumstances where abuse of trust could occur.
17. The University’s commitment is not just about protecting children and adults at risk from deliberate harm, neglect, and a failure to act. It relates to broader aspects of the University’s obligations to make reasonable adjustments for disabilities. For further information, please see Student Disability Policy.

University Responsibilities

18. The University will not take on the usual rights, responsibilities, and authority that parents have in relation to a child, and it will not act as if it were the parent in relation to students who are still children or are adults at risk.
19. The University also recognises its responsibility to take appropriate action when a child or student discloses that they are experiencing abuse or neglect, or if staff have a concern about the welfare of a child or student, and to ensure staff understand what might indicate this and what action to take.
20. The University has appointed a Designated Safeguarding Lead who is responsible for the implementation of this Policy and who will be the person 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 who can act in their place when they are unavailable.
21. If a complaint or concern is raised about the Designated Safeguarding Lead, this should be reported to the Director for Student Engagement.
22. The University’s Designated Safeguarding Lead is:

Head of Student Support and Development

23. The University’s Deputy Designated Safeguarding Lead is:

Director of Business and Partnership Development & Apprenticeships

24. The University will maintain policies and procedures geared towards abuse prevention, including:
    1. Selective vetting of staff and volunteers using DBS checks
    2. Disciplinary Procedure for Staff
    3. Clear procedure for staff and students to follow in the instance of a child entering the University who is not registered on a programme or course
    4. Staff induction and training
    5. Confidential reporting procedure
25. All staff will be invited to complete compulsory training during their induction to the University, which will give an overview of the organisation and ensure they know its purpose, values, services, and structure.
26. Training on specific areas such as safeguarding children, identifying and reporting abuse, and confidentiality of personal information and compliance with the University’s Data Protection policy, the legislation, ICO guidance and best practice will be given as a priority to:
    1. Staff who will be in frequent contact with children
    2. New staff
    3. Volunteers
27. In relation to work based learning, including apprenticeships, the University will:
    1. Ensure pre-placement health and safety checks, including insurance checks, are completed, prior to the commencement of work related activity;
    2. Ensure employers are aware of their safeguarding obligations through training and guidance;
    3. Ensure employers understand and commit to their responsibilities through binding contracts.

Individual Staff Responsibilities

28. Staff should maintain a register of children and students working with them at all times.
29. Maintain a professional relationship with children and all students.
30. Ensure that if any form of manual/physical touching is required as an element of a seminar, workshop or similar, it is provided openly and with the person’s explicit written consent.
31. Never give a child or adult at risk personal details such as personal mobile number, personal email, or home address. Do not engage with children through social networking sites, for example Snapchat Contact should be restricted to work and public professional communication channels to ensure a professional relationship is maintained.  
32. It has long been a criminal offence for an adult to have sex with a child. However, the Sexual Offences (Amendment) Act 2000 added a further criminal offence for any person in a position of trust (which may include members of University staff) who engages in sexual activity with a child.
33. Any advising meetings/tutorials/office hour meetings with a child should take place in sight of others or with the doors kept open at all times and where possible an adult should not be alone with a child. Any meeting with apprentices that take place at their place of work, should be done so in sight of others or with the doors kept open at all times and, where possible, with Line Managers or another adult also present.
34. All communication between staff and children must take place via their University email addresses. Apprentices may use their work email as well as their University email address for correspondence.

Student Responsibilities

35. Students must treat staff and fellow students with courtesy and respect, both on and off University premises, in person and on-line.
36. Students are expected to attend induction sessions which will include information on Prevent and Safeguarding, and the University’s Discrimination, Bullying, and Harassment Policy, and Sexual Misconduct Policy, Disciplinary Procedure for Students, and the Health and Safety Policy.
37. Any concerns about the wellbeing or safety of themselves or another student should be brought to the attention of a member of staff as soon as possible, which will then be referred to the Designated Safeguarding Lead for consideration.

What Constitutes Abuse?

38. In drawing up guidance locally, it needs to be recognised that the term ‘abuse’ is subject to wide interpretation.
39. Abuse may consist of a single act or omission or repeated acts or omissions. It may be physical, verbal, or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which they have not consented or cannot consent. Abuse can occur in any relationship and may result in harm to, or exploitation of, the person subjected to it.
40. Abuse may take the following forms:
    1. Physical abuse, including hitting, slapping, pushing, kicking, misuse of medication, restraint, or inappropriate sanctions;
    2. Psychological abuse, including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks;
    3. Discriminatory abuse, including racist or sexist abuse, abuse based on a person’s disability, and other forms of harassment, slurs, or similar treatment;
    4. Sexual abuse, including rape and sexual assault or sexual acts to which the child or adult at risk has not consented, or could not consent or was pressured into consenting;
    5. Financial or material abuse, including theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions, or benefits;
    6. Neglect and acts of omission, including ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate nutrition, and heating.

Procedure if a Child or Student Discloses Abuse by Someone Else

41. If a child or student 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.
42. It is vitally important that no promise is given to keep the information confidential.
43. If a child can understand the implications of making a referral to the Local Authority’s Children’s Services, then they should be asked for their view, but it must be made clear that University staff have a responsibility to take what action is necessary to ensure the child’s safety. The Local Authority for the University’s Campus is Tower Hamlets. Their Children’s Services advice and assessment may be contacted on 020 7364 5601 or 020 7364 5606.
44. If the student is over 18 and an adult at risk and can understand the implications of making a referral to the Local Authority’s Adult Services then they should be asked for their view, but it must be made clear that University staff have a responsibility to take what action is necessary to ensure their safety. If you are unsure whether the student is an adult at risk or not, then you should contact the Designated Safeguarding Lead for their guidance.
45. If the student is over 18 and not an adult at risk, then they should normally decide what, if any, information is shared. However, it must be made clear that University staff have a responsibility to act if there is an imminent risk to their safety or that of others.
46. The steps which should be followed are:
    1. Stay calm;
    2. Listen carefully to what the person 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 person 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 person that they have done the right thing by talking to someone;
    6. Make sure the person 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 or Adult Services may need to be contacted;
    7. Record the disclosure in a Safeguarding Incident Report form, using the person’s words where possible and noting the time and date that you first became aware of the incident;
    8. Contact the Designated Safeguarding Lead as soon as possible;
    9. Do not discuss the disclosure with other staff; Designated Safeguarding Lead discussion should be strictly on a ‘need to know’ basis. Find out when the child/student 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/student remains safe.)
47. Students who are not children or an adult at risk may disclose abuse. While in these cases it would not normally be appropriate to contact Local Authority Children’s Services, advice should be sought from the Designated Safeguarding Lead regarding what action might be required. Actions may include seeking support from the Police, specialist charity services or NHS services, depending on the nature of the abuse reported and the needs and wishes of the student.
48. Where an allegation is made against another student at the University, the Designated Safeguarding Lead may refer the matter to the Registrar as set out under the Disciplinary Procedure for Students.
49. Concerns about the welfare of a child or student, including the possibility of abuse or neglect, may also be raised by behaviour or other indicators noticed by a member of staff, but not disclosed by the child or student. In these instances, it is equally important to act, and these concerns should be raised and discussed with the Designated Safeguarding Lead.

Procedures for Dealing With Suspected Abuse by Members of Staff

50. When dealing with reported or suspected abuse involving allegations against a member of University staff, managers and Board Members must remember that the welfare of children and adults at risk at the University is paramount, but that the University also has a responsibility to ensure that staff are treated fairly and with respect.
51. The accused member of staff should be informed of the allegation as soon as possible and the Disciplinary Procedure for Staff will be followed.
52. The Designated Safeguarding Lead will immediately inform Human Resources on receipt of information suggesting that there is a safeguarding concern.
53. The Designated Safeguarding Lead will ensure that records are kept of all reports and that they are held securely in accordance with the Data Protection policy, procedure, laws, ICO Guidance and best practice and in accordance with the University’s Student Confidentiality Statement.

Investigation of Allegations

54. Where an allegation of inappropriate behaviour, abuse or neglect is made against a staff member, the Disciplinary Procedure for Staff will be invoked.
55. Support will be offered, both to the child or adult at risk and to any member of staff against whom allegations have been made. For the child or adult at risk this might be provided by their parents or carers, who may themselves need support to do this. For a student over the age of 18, this may be a friend, family member or member of Student Support and Development.

Guidance for Staff in the Event of an Allegation

56. Staff should remain calm and not attempt to engage with the party making the complaint. Staff should inform their line manager, and the Designated Safeguarding Lead immediately.
57. Staff should complete the Safeguarding Incident Report Form with a written record of the facts as they recall them.
58. Ensure that no one is placed in a position which could cause further compromise. Do not contact another agency involved with the child, adult at risk or student concerned.

Confidentiality

59. Whatever the nature of the disclosure, suspicion, or complaint, it must be kept confidential.

Staying Safe Online

60. Use of the internet and digital technology is part of most people’s everyday lives. The University uses the internet to support its provision of undergraduate, postgraduate and apprenticeship programmes. It is essential that all students (including apprentices and global experience students) have the knowledge and skills to use the internet safely and appropriately.
61. Staying safe online includes ensuring the security of personal and employer data and being aware of the dangers of:
    1. Bullying
    2. Harassment
    3. Grooming
    4. Revenge porn
    5. Identity theft
    6. Viruses

Recognising Signs of Radicalisation

62. Extremists may seek to exploit vulnerable individuals and draw them into terrorist activities. This therefore represents a safeguarding concern.
63. As part of the Counterterrorism and Security Studies Act 2015, the University is required to pay ‘due regard’ to the need to prevent individuals from being radicalised and drawn into terrorism.
64. There is no single way of identifying a person who may be vulnerable to extremist ideology; 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 of time but is vague about where they are going
    9. Buying or storing large amounts of chemicals for no obvious reason
65. Employers and University staff should follow the University’s Prevent Policy if they become concerned about a child, student or apprentice being radicalised.

Monitoring and Reviewing

66. This Policy will be monitored and reviewed by the Designated Safeguarding Lead.

Version History

Annex A1: Apprenticeships

General Principles

1. The University is committed to ensuring the highest levels of safety and wellbeing for all apprentices, and this is achieved by working in partnership with employers.
2. To ensure the safety and wellbeing of apprentices it is critical that employers understand their responsibilities to them and that they work closely and cooperatively with the University in the event that a safeguarding concern is raised about an apprentice.
3. The Work Related Learning Management Board will ensure that the learning and wellbeing of apprentices is regularly reviewed and monitored and will ensure that employers meet the requirements set out in this Annex.

The Employer’s Responsibilities

4. Employers have a duty to comply with all current and future UK legislation and statutory responsibilities and should familiarise themselves with relevant government legislation such as the requirements of the Equality Act 2010. Employers we work with have the primary responsibility for health and safety in the workplace and managing any significant risk for apprentices or students on Work Related Learning Programmes. Employers will:
   1. Take appropriate steps to understand what safeguarding means in practice at their organisation, in the context of the responsibilities that they have for the people they employ;
   2. Ensure that staff working with apprentices or work related learners in a position of trust, are appropriate for the role and do not present any danger or threat;
   3. Ensure apprentices are aware of organisational policies relating to internet use at work;
   4. Ensure that any people working with children or adults at risk have had an enhanced Disclosure and Barring Service check;
   5. Ensure, if possible, to have a single point of contact within the organisation to coordinate safeguarding across the organization;
   6. Demonstrate a commitment to the principles that underpin the Prevent Duty;
   7. Demonstrate a commitment to British values;
   8. Ensure apprentices are made aware of the organisation’s policies on using the Internet and technology in the workplace;
   9. Take responsibility for an apprentice’s welfare in the workplace and to seek appropriate advice when they feel an apprentice may be at risk in their personal lives;
   10. Sign an Employer’s Declaration to say they have read and understood their duty to safeguard the University’s apprentices;
   11. Complete and sign a health and safety declaration and provide copies of insurance certificates to evidence their suitability, legal cover, responsibility, and commitment to safeguard their apprentices and provide a safe working environment;
   12. Contribute to Safeguarding, British Values, and Prevent conversations with their apprentice at 6-8 weekly tripartite reviews and maintain open channels of communication regarding apprentices.
5. Employers and staff should not:
   1. Buy alcohol for someone under the age of 18 for the consumption on licensed premises. A 16 or 17-year-old may drink beer, wine, and cider with a table meal if they are accompanied by an adult;
   2. Spend excessive time alone with children or adults at risk away from others;
   3. Take children or adults at risk alone in a car journey, however short;
   4. Take children or an adult at risk to their home;
   5. Engage in physical or sexually provocative games including horseplay;
   6. Allow or engage in inappropriate touching of any form;
   7. Make over-familiar or sexually suggestive comments or approaches to a child or adult at risk even as a ‘joke’;
   8. Let allegations, over familiar or sexually suggestive comments or approaches made by a child or adult at risk go unchallenged or unrecorded;
   9. Do things of a personal nature that children or adults at risk can do for themselves;
   10. Take photographs, videos or other images of children or adults at risk without the express permission of their parents or legal guardians;
   11. Allow inappropriate computer activity whether internet or network related. This includes on mobile phones or related technologies.

Safeguarding Warning Signs

6. An apprentice may not always choose to seek help over an issue that would be considered under safeguarding, but there are common characteristics which may help identify a concern:
   1. Absence from work or reluctance to study/go online.
   2. Changes in physical appearance
   3. Changes in behaviour/character (quiet, loud, aggressive, withdrawn)
   4. Changes in emotional health (crying, low mood, anxiety)
   5. Excessive alcohol consumption
   6. Use of controlled/illegal psychoactive substances
   7. Physical injuries (cuts, bruises) and self-harm
7. It is important to stress that this list of examples is not exhaustive, and existence of these signs is not a definitive indicator of a safeguarding concern. However, if an employer suspects an issue, we recommend they speak to the apprentice as soon as possible and report any safeguarding issues to the University’s Designated Safeguarding Lead as set out in the main policy.

What an Apprentice Should Do to Report a Safeguarding Concern at Work

8. An apprentice who has concerns about abuse, bullying, harassment, exploitation, or neglect at work should speak to their line manager or Human Resources Department as soon as possible and follow their employer’s policies and procedures. 
9. An apprentice may also speak to the University’s Business Relations Manager who supports them on their apprenticeship about any safeguarding issues or concerns in their workplace.

Annex A2: Apprentice Employer Declaration

Employer’s Declaration

I have read and understood my obligations as an employer and will ensure that:

1. Staff who have regular contact with apprentices understand their individual and collective responsibility to the health, safety, and well-being of the apprentice at all times.
2. The apprentice will work in a safe and productive work environment.
3. The apprentice will be provided with equality of opportunity.
4. The organisation will work with the University to promote professional business behaviours and report any concerns.
5. The organisation will work in partnership with the University to identify risks in the workplace including health and safety, safeguarding and radicalisation, and will promote equality and diversity and British values.

Name of Organisation:

Employer signature:

Employer name:

Date:

Annex B: Virtual Learning

1. The University continues to be committed to protecting the welfare of all its students, apprentices, work related learners, and staff through virtual learning platforms.
2. It is important that all staff who interact with children and adults at risk, including online, continue to look out for signs a child or adult at risk may be at risk. Any such concerns should be dealt with as per the above policy and, where appropriate, referrals should continue to be made to the Designated Safeguarding Lead.

Code of Behaviour and Good Practice When Interacting Virtually

1. Identify a suitable environment for the call. Discourage, where possible, students and learners from making video calls from their bedroom.
2. Appropriate clothing for all participants.
3. Distractions and disturbances minimised.
4. Use a headset or headphones.
5. Cameras optional but preferred.
6. Adherence of all to relevant behaviour and conduct policies.
7. Maintain a central register of all video calls and contacts – include the link to the call.
8. Adherence to the pre-agreed policy for the recording of sessions.
9. Involve parents and carers to ensure that they are well-informed.
10. Be conscious of confidentiality when working online.

Safeguarding Process Flowchart