Quillan Education offers coaching for all. We are committed to ensuring the highest possible standard of personal safety, well-being and safeguarding of each student.

These policy and the supporting procedures seek to ensure that Quillan Education undertakes its responsibilities regarding safeguarding children and young people. Our policies establish a framework to support all those who come into contact with Quillan Education.

 

  1. Introduction

Quillan Education offers coaching for all. We are committed to ensuring the highest possible standard of personal safety, wellbeing and safeguarding of each student.

This policy and the supporting procedures seek to ensure that Quillan Education undertakes its responsibilities regarding safeguarding children and young people. This policy establishes a framework to support all those who come into contact with Quillan Education, protect them from abuse and maltreatment.

  1. Scope and Purpose of the Policy

This policy applies to all aspects of Quillan Education in relation to coaching services. Quillan Education acknowledges its duty of care to safeguard and promote the welfare of children and young people and is committed to ensuring safeguarding practices reflect statutory responsibilities, government guidance and  best practice.

The purpose of this policy is to ensure that, regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation or socio-economic background, all students have a positive experience of Quillan Education.

Safeguarding Statement:

Safeguarding is everyone’s business – Quillan Education is committed to safeguarding and promoting the welfare of children and young people.

Confidentiality is essential to the environment of trust with our students, but this will be balanced against the organisation’s duty to protect children and young people.

Quillan Education will collectively manage risks and reduce the likelihood of abuse by:

  • The provision of up-to-date safeguarding policies and procedures that reflect current safeguarding legislation and guidance
  • Protecting students from harm
  • Making sure we can raise safeguarding concerns
  • Handling allegations or incidents in accordance with policies and procedures
  • Report any allegations or incidents to the relevant authorities
  1. Definitions of Abuse

Children are considered to be abused or at risk of abuse by parents/carers when the basic needs of the child are not being met through acts of either commission or omission.  ‘Children’ includes everyone under the age of 18 (KCSIE, 2021).

Knowing what to look for is vital to the early identification of abuse and neglect. We will be aware of indicators of abuse and neglect through our experience and training so that we are able to identify cases of children who may be in need of help or protection.

We will have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and consensual and non-consensual sharing of nudes and semi-nudes images and/or videos can be signs that children and young people are at risk.

‘Safeguarding and promoting the welfare of children and young people’ is defined as:

  • Protecting children from maltreatment
  • Preventing impairment of children’s mental and physical health or development
  • Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and
  • Taking action to enable all children to have the best outcomes

(Keeping Children Safe in Education (KCSIE), DfE, September 2021)

Abuse

Is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children (KCSIE, 2021, para 26).

Types of abuse and neglect

Physical abuse

A form of abuse which 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

The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It 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.

It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature 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. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

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.

They may also include 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. The sexual abuse of children by other children is a specific safeguarding issue (also known as peer on peer abuse) in education and all staff and tutors should be aware of it and adhere to this policy and procedures in dealing with it.

Neglect

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); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Peer on Peer / Child on Child Abuse

Children can abuse other children (often referred to as peer-on-peer abuse) and it can take many forms. It can happen both inside and outside of school/college and online. It is important that all staff recognise the indicators and signs of peer-on-peer abuse and know how to identify it and respond to reports. This can include (but is not limited to): bullying (including cyberbullying, prejudice-based and discriminatory bullying); abuse within intimate partner relationships; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexual violence and sexual harassment; consensual and non-consensual sharing of nude and semi-nude images and/or videos; 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; upskirting and initiation/hazing type violence and rituals. Addressing inappropriate behaviour (even if it appears to be relatively innocuous) can be an important intervention that helps prevent problematic, abusive and/or violent behaviour in the future. (KCSIE 2021, pg 135)

Sexual Violence and Sexual Harassment between children

Child on child sexual violence can happen both inside and outside of education settings. For the purposes of this Policy and Procedures Document, when referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003, specifically rape, assault by penetration, sexual assault and causing someone to engage in sexual activity without consent.

Sexual harassment is unwanted conduct of a sexual nature that can occur online and offline and both inside and outside education settings. Child on child sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated degraded or humiliated and/or create a hostile, offensive or sexualised environment. (Sexual violence and sexual harassment between children in schools and colleges, DfE, Sept 2021)

Child Protection

Is one part of safeguarding and promoting the welfare of children and refers to the activity that is undertaken to protect children who are suffering, or at risk of suffering significant harm.

Significant Harm

The definition of significant harm is not prescriptive. The interpretation will depend largely on professional judgement, based on the known facts. It can include inappropriate touching, an assault, or a series of compounding events e.g., bullying. Other factors to be considered include the age and vulnerability of the child, the degree of force used, the frequency of the harm, the nature of the harm in terms of ill treatment, and the impact on the child’s health and development.

Annexes  A & B of KCSIE 2021 contains important additional information about specific forms of abuse and safeguarding issues. 

  1. Online Safety

Quillan Eeducation aims to protect coaches and students in their use of technology, and specifically our website. All communication between coaches and students take place via Google Meets which will be recorded.

This means that personal details about the student and their parents/carers (including email addresses and telephone numbers) remain private and confidential. We have established mechanisms to identify, intervene in and escalate any concerns where appropriate.

As outlined in KCSIE 2021 we recognise the considerable breadth of issues classified within online safety, which have been categorised into the following four areas:

  • content: being exposed to illegal, inappropriate or harmful content, for example: pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism
  • contact: being subjected to harmful online interaction with other users; for example: 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; for example, 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. If you feel your pupils, students or staff are at risk, please report it to the Anti-Phishing Working Group (https://apwg.org/).
  1. Dealing with a safeguarding concern or disclosure

This policy and the following procedures have been developed to:

  • Prevent and reduce the incidence of abuse;
  • Increase awareness of issues concerning the abuse of children;
  • Provide a process if issues of concern are disclosed or discovered;
  • Improve the quality of life and protection of children with whom we work;
  • Protect people from harm;
  • Make sure people can raise safeguarding concerns;
  • Handle allegations or incidents;
  • Report to the relevant authorities.

We must be alert to the risks from:

  • Neglect
  • Physical abuse
  • Sexual abuse
  • Sexual violence and sexual harassment
  • Emotional abuse
  • Mental health
  • Bullying or harassment
  • Peer on Peer abuse
  • Domestic Abuse
  • Health and safety
  • Child Sexual Exploitation (CSE)
  • Child criminal Exploitation (CCE)
  • Radicalisation and Extremism
  • Forced marriage and honour-based violence
  • Trafficking or modern slavery
  • Female genital mutilation
  • Discrimination on any of the grounds in the Equality Act 2010
  • People targeting our organisation
  • Culture within the organisation allowing poor behaviour
  • People abusing a position of trust they hold within MTW

Coaches may have suspicions that a person is either

  • at risk of harm, or
  • suffering abuse or neglect

because of behavioural, emotional and/or physical factors; or symptoms or conversations and/or written evidence which indicate that abuse or neglect may have taken place, or an individual may disclose information that causes a concern for their safety and welfare.

When making difficult judgements around possible signs and symptoms of abuse and neglect it is crucial that all available information and presenting injuries or behaviours are seen in context. e.g., is the change in behaviour a result of a sudden illness, recent bereavement or exam anxiety?

When information is shared with you which causes concerns of possible abuse, your requirement is to accept the information being shared without influencing it, as well as providing support and reassurance to the child and managing expectations.

Coaches should:

  • Stay Calm.
  • Listen carefully, let the child tell their story and take it seriously.
  • Ask TED questions – Tell me, Explain to me, Describe to me.
  • Keep the child informed about what you are doing and what is happening at every stage.
  • Reassure them that they have done nothing wrong and it is not their fault.
  • Make a full record of what has been said as soon as possible.

Coaches should not:

  • Promise confidentiality. Be honest about your own position, who you will have to tell and why.
  • Ask leading questions (e.g. Did your mother do this to you?)
  • Press the child for more details.
  • Make promises (e.g. this will never happen again)

When responding to a concern or disclosure of sexual violence or sexual harm, coaches MUST NOT view or forward illegal images of a child.

Once a disclosure has been made to us or our independent Safeguarding Officer, we will consider the information, if necessary, taking advice, and will make a decision to either:

  • Keep detailed records of the concern with no further action at the time.
  • Make a child protection referral to Children’s Social Care.

Where a child is suffering, or is likely to suffer from harm, it is important that a referral to children’s social care (and if appropriate the police) is made immediately.

Once an incident of sexual violence or sexual harassment has been disclosed the independent Safeguarding Officer should make an immediate risk and needs assessment. The risk and needs assessment should consider:

  • The victim, especially their protection and support
  • Whether there have been other victims
  • The child displaying the sexualised behaviour
  • All the other children, and if appropriate, staff and tutor, and actions that are appropriate to protect them from further harmful sexualised behaviour.

If deemed necessary, the Independent Safeguarding Officer will contact the relevant Children’s Social Care Team and make a telephone referral. This must be followed up in writing within 24 hours.

Within one working day of a referral being made, a local authority social worker should acknowledge receipt to the referrer and make a decision about the next steps and the type of response that is required. This will include determining whether:

  • the child requires immediate protection and urgent action is required;
  • the child is in need, and should be assessed under section 17 of the Children Act 1989;
  • there is reasonable cause to suspect the child is suffering or likely to suffer significant harm, and   whether enquiries must be made and the child assessed under section 47 of the Children Act 1989;
  • any services are required by the child and family and what type of services;
  • further specialist assessments are required to help the local authority to decide what further action to take; and
  • to see the child as soon as possible if the decision is taken that the referral requires further assessment.

It is important to note that where coaches are delivering tuition to children and young people in a school or college, the Independent Safeguarding Officer must inform the school’s Designated Safeguarding Lead/ Officer.

  1. Sharing Information

Effective sharing of information between Quillan Education, schools, colleges, local authorities and other statutory services is essential for the early identification of need, assessment and intervention in order to keep children safe.

Fears about sharing information cannot be allowed to stand in the way of the need to safeguard and promote the welfare of children and young people identified as being ‘at risk of abuse or neglect’.

Personal information held by Quillan Education is subject to a legal duty of confidentiality and will not normally be disclosed without the consent of a child’s parent/carer.  However, the right to confidentiality and respect for private and family life (Article 8, Human Rights Act, 1998) is not absolute.

The only exceptions to this are where confidentiality can be overridden either by a court order or other legal authority (e.g. Prevent Duty), or in the public interest i.e. in order to safeguard a child.

Public interest justifications usually relate to disclosures to prevent significant or serious harm to third parties or to prevent or to prosecute a serious crime. e.g. suicide pacts, terrorist threats.

Quillan education recognises that information sharing between key organisations is essential to safeguard children and young people at risk of abuse, neglect and exploitation.

Quillan Education will ensure that where coaches need to share special category personal data, they are aware that the Data Protection Act 2018 includes ‘safeguarding of individuals at risk’ as a condition that allows practitioners to share information without consent.

Quillan Education will ensure that confidential information is only shared where it is lawful and ethical to do so. All coaches and tutors must be clear about situations when they can share information with appropriate agencies i.e. when they believe a child is at risk of harm.

Quillan Education will give due regard to relevant legislation and guidance when making decisions on sharing information including the following:

  • The Data Protection Act 1998 and 2018 (GDPR)
  • The Children’s Code (issued under S125 DPA 2018 effective from 5 Oct 2021)
  • Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers, July 2018
  • Working Together to Safeguarding Children, 2018
  • Keeping Children Safe in Education, 2021

The Children’s Code

The Children’s Code (or the age-appropriate design code) is a statutory code of practice that articulates how online services likely to be accessed by children should comply with the UK GDPR when using children’s data. The code sets out 15 flexible standards that allow children to explore, learn and play online. It ensures that the best interests of the child are the primary consideration when designing and developing online services. The code standards are:

  • Best interests of the child
  • Data protection impact assessments
  • Age appropriate application
  • Transparency
  • Detrimental use of data
  • Policies and community standards
  • Default settings
  • Data minimisation
  • Data sharing
  • Geolocation
  • Parental controls
  • Profiling
  • Nudge techniques
  • Connected toys and devices
  • Online tools
  1. Safeguarding Allegations Against Quillan Education

Quillan Education recognises its duty to report concerns or allegations against itself. All coaches must comply with the relevant Code of Conduct when performing their role in order to promote safer working practices.

Allegations of abuse against Quillan Education can be made by either a child or an adult.

Quillan Education recognises that there are two levels of allegation/concern as outlined in KCSIE 2021, Part 4, these are:

  • Allegations that meet the harms threshold.
  • Allegations/concerns that do not meet the harms threshold – referred to as ‘low level concerns’.

Quillan Education will deal appropriately and promptly with all allegations or concerns and refer all safeguarding concerns or allegations immediately to the appropriate local authority designated officer (LADO) in accordance with local safeguarding procedures and practical guidance.

Quillan Education is committed to creating and sustaining an open and transparent culture in which all concerns about adults (including allegations that do not meet the harms threshold) are shared responsibly with the right person, recorded and dealt with in accordance with our policies and procedures. This organisation wide approach to safeguarding will ensure we are able to identify concerning, problematic or inappropriate behaviour early; minimise the risk of abuse;  and ensure that adults working in or on behalf of Quillan Education are clear about professional boundaries and act within these boundaries, and in accordance with the ethos and values of Quillan Education.

  1. Complaints

If a complaint is identified as a potential safeguarding concern, then the Safeguarding Procedures will be followed.

  1. Underpinning Legislation and Guidance

Legislation

  • Children Act 1989
  • Human Rights Act 1998
  • United Nations Convention on the Rights of the Child, 1991
  • Sexual Offences Act 2003
  • Female Genital Mutilation Act 2003
  • Children Act 2004
  • Safeguarding vulnerable Groups Act 2006
  • The Forced Marriage (Civil Protection) Act 2007
  • The Equality Act 2010
  • Children and Families Act 2014
  • Anti-Social Behaviour, Crime and Policing Act 2014
  • Modern Slavery Act 2015
  • Counter Terrorism and Security Act 2015
  • Children and Social Work Act 2017
  • Data Protection Act 2018
  • Voyeurism (Offences) Act 2019
  • Domestic Abuse Act 2021
  • Children’s Code (issued under S125 DPA 2018, effective Oct 2021)

Guidance

  • Working Together to Safeguard Children 2018 places a general duty on schools to work and cooperate with other agencies to safeguard and promote the welfare of children. Quillan Education is committed to doing this by having an open, honest and transparent line of communication.

This document is an update by the Safer Recruitment Consortium of a document previously published for schools by the Department for Education and Skills (DfES). It was initially issued as those working with children had expressed concern about their vulnerability and requested clearer advice about what constitutes illegal behaviour and what might be considered as misconduct. Education staff asked for practical guidance about which behaviours constitute safe practice and which behaviours should be avoided. This safe working practice document is NOT statutory guidance from the Department for Education (DfE); it is for employers, local authorities and/or the Three Safeguarding Partners to decide whether to use this as the basis for their code of conduct / staff behaviour guidelines.

An addendum was published in response to Covid-19 in April 2020.

  • Keeping Children Safe in Education 2021 (KCSIE) is statutory guidance issued from the Department for Education under Section 175 of the Education Act 2002. Schools and colleges must have regard to this when carrying out their duties to safeguard and promote the wellbeing of children.
  • Children’s Code is a statutory code of practice that articulates how online services likely to be accessed by children should comply with the UK GDPR when using children’s data. The code was prepared under s121 of the DPA 2018 and issued under s125 of DPA 2018, coming into effect on 5 October 2021.