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Module 3: Welfare and Safeguarding Policy

Defination

This module is very long. You can use the 'Table of Content' to go to the section you want to review.

We have three rules: Ready, Kind, and Safe. 

 

Safeguarding is the action to promote the welfare of children and protect them from harm. Reading and understanding this policy is a part of being ready, and following it makes you safe. It is kind to report any concerns. 

 

Safeguarding is defined as:

  • 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

  • Promoting the upbringing of children with their birth parents, or otherwise their family network through a kinship care arrangement, whenever possible and where this is in the best interests of the child

  • Taking action to enable all children to have the best outcomes in line with the outcomes set out in the Children’s Social National Framework 

(Keeping Children Safe in Education, 2023; Working Together to Safeguarding Children, 2023).

 

Child protection is part of the safeguarding process. It protects individual children identified as suffering or likely to suffer significant harm. This includes child protection procedures. This details how to respond to concerns about a child (NSPCC). All staff have a duty to safeguard and promote the welfare of children (The Children's Act, 1989; 2004).

Table of Content

You can click on the titles to go to each section

1.    POLICY STATEMENT    

  • 1.1 Who the policy applies to    

  • 1.2 Designated Safeguarding Persons    

  • 1.3 Policy Review    

  • 1.4 Policy Availability and Formats    

  • 1.5 Associated Policies and Documents    

2.    CHILDREN’S RIGHTS    
3.    CODE OF CONDUCT: SAFER WORKING PRACTICE FOR STAFF    

  • 3.1  Duties of Staff    

  • 3.2  Adult Interaction    

  • 3.3  Adult Conduct    

  • 3.4  Electronic and Social Media Contact    

               Safe practices:    
4.    WELFARE SYSTEMS    

  • 4.1  Risk Assessments    

  • 4.2  Behaviour and discipline procedures:    

  • 4.3  Staff photo board:    

  • 4.4  Missing students:    

  • 4.5  Safety and First Aid:    

  • 4.6  Supervision ratios    

  • 4.7  Age appropriate activities:    

  • 4.8  Homestay Accommodation:    

               Private fostering    

  • 4.9 Online Safety    

  • 4.10 Mobile and smart technology    

  • 4.11 Mental Health    

  • 4.12   PREVENT Radicalisation & Extremism    

5.    RECOGNISING CHILD ABUSE AND BULLYING    

  • 5.1  Types of abuse:    

  • 5.2  Typical signs of abuse:    

              1. Physical abuse:    
              2. Sexual abuse:    
              3. Emotional abuse:    
              4. Neglect:    

  • 5.3  If a child discloses abuse:    

  • 5.4 Bullying    

              Identifying bullying:    
              How to deal with bullying:    

  • 5.5 Female Genital Mutilation    

             Girls who are more at risk of FGM:    
             Signs that FGM might take place:    
             Signs that FGM has taken place:    

  • 5.6 Harmful Sexual Behaviour    

              Policies and Procedures    

  • 5.7 Sharing nudes and semi nudes    

6.    HANDLING ALLEGATIONS    

  • 6.1  When to react to allegations:    

  • 6.2  If a young person tells you they are being abused    

  • 6.3  Dos and Don’ts    

  • 6.4  If an adult is accused    

  • 6.5  If a child is accused    

  • 6.6  Keeping records    

7.    SAFER RECRUITMENT    

  • 7.1  Overview:    

  • 7.2  Recruitment materials:    

  • 7.3  Information for applicants    

  • 7.4  Safer recruitment at different stages    

              Applying    
              Shortlisting process    
              References    
              During the interview:    
              Background check:    

  • 7.5  Applicants awaiting DBS    

  • 7.6  If a disclosure shows a criminal record:    

8.    STAFF TRAINING    

  • 8.1  Responsibility    

  • 8.2  How training is delivered:    

9.     WHISTLEBLOWING    
10.   FAILURE TO COMPLY    
11.   BIBLIOGRAPHY    

1.  POLICY STATEMENT

Safeguarding children is the responsibility of all adults. SKOLA thus aims to provide a safe and supportive environment for all students and staff. We use safer recruitment procedures to appoint staff. We will train staff to recognise, record, report, and refer to a variety of welfare issues. 

 

All the adults working for / with SKOLA English in London are expected to:

  • Read and sign this policy

  • Always adhere to this policy

  • Always safeguard the welfare of all students

  • Promote a safe environment

  • Report any concerns or allegations to the Designated Safeguarding Lead (DSL)

 

SKOLA English in London is a year-round language school. We offer short term English courses and activities to children aged 5 – 17. We operate on 2 summer sites.

 

  • SKOLA Regent’s Park, Regent's University, Inner Cir, London NW1 4NS

  • SKOLA Gloucester Gate, 14 Gloucester Gate, London NW1 4HG

 

In our centres we provide homestay accommodation. We use three agencies (Perfect Hosts Homestays, Hosts International and Brittania). We also have a door-to-door car service through Atlas Cars.

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1.1 Who the policy applies to

  • The policy applies to all children who are students of SKOLA English in London. All staff employed by SKOLA English in London. All adults who work with the school (e.g., group leaders, DJs, cover teachers, coaches, etc.) at any of our centres. It applies to anyone regardless of sex, gender, race, religion, or sexual orientation.

  • A ‘child’ or ‘student’ in the context of this policy refers to anyone under the age of 18. They are, were or will be a student at SKOLA English in London.

  • An ‘adult’ refers to all members of staff employed by SKOLA or through any contractors. Also group leaders, parents, and any visitors to the school.

  • Homestay hosts will follow the relevant parts of our Safeguarding Policy. Those contracted by homestay providers will also follow the policies of the companies.

  • ‘Employer’ in this context refers to SKOLA English in London.

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1.2 Designated Safeguarding Leads
The designated safeguarding persons are:
Designated Safeguarding Leads:
Connor Middleton, Email: connor@skola.co.uk, Mobile or whatsapp: +44 7787 188382
David Stephenson, Email: david@skola.co.uk

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If you have any concerns about the Designated Safeguarding Leads contact the Director: 
Ben Toettcher, Email: ben@skola.co.uk, Mobile or whatsapp: +44 7340 516781
 

DSL Role & Safeguarding Structure

Areas of the Role

  • be at senior management level, and/or able to make decisions

  • have safeguarding knowledge and overview of organisation’s safeguarding needs...

  • and the drive and resources to make sure the needs are met

  • raise awareness amongst staff and stakeholders so that....

  • a positive safeguarding ethos becomes embedded in the organisation

  • provide advice and support on child welfare and protection issues

  • ensure safer recruitment practices are in place for staff and homestays

  • help promote educational outcomes by sharing the information about the welfare, safeguarding/child protection issues with teachers and school/college staff

  • work with other designated safeguarding staff to achieve aims


Knowledge and Skills

  • be able to produce a fit-for-purpose safeguarding policy

  • training; ensure it happens for stakeholders at the right time and in right way

  • ensure various records are kept, if necessary securely

  • know obligations surrounding Prevent

  • child protection: be able to manage referrals, which means.....

  • having knowledge of LSCP; who to contact, when to contact and what will happen

  • understand thresholds for referring and the difference between Sections 17 & 47

  • know official government documents to refer to


Personal Characteristics

  • at a decision-making level but enough distance from senior management to prevent conflicts of interest

  • can see both the big picture and the detail

  • confident in fulfilling the requirements of the role

  • strong character

  • calm under pressure

  • able to work effectively with different departments

  • understand the importance of safeguarding and not be dismissive of it

  • awareness of problems of ‘one size fits all’;

  • ability to consider context (e.g. cultural aspects of safeguarding)

  • understanding of the organisational context,

  • understanding of children and young people

  • know what to do, what should be in place - and understand why!


1.3 Policy Review
We will review this policy annually. So, it is up to date with all legal and accrediting body requirements or after major updates. We welcome feedback from staff or group leaders to improve our safeguarding systems. All designated safeguarding leads will contribute to reviewing the policy. The Director will sign it off.


1.4 Policy Availability and Formats
This policy is shared with all staff via an online copy. A printed copy will be available in the staff room. The Staff Handbook has a shortened version of this document. 


1.5 Associated Policies and Documents
Staff members should also familiarise themselves with the following policies/ documents:

  • Health and Safety Policy

  • Recruitment Policy

  • Abusive Behaviour Policy

  • Guidelines for Taking Students on Excursions

  • Absence Policy

  • Supervision Policy

  • Use of Electronic Devices Policy

  • Risk assessments

  • Regent’s University Safeguarding Policy

  • Homestay and Transport providers’ Safeguarding Policy
     

2.  CHILDREN'S RIGHTS

 All children have the right to:

  • Be safe and happy

  • Say ‘no’ if any person tries to do something they feel is wrong

  • Be listened to

  • Be taken seriously when reporting any incidents/ allegations

  • Be respected and safeguarded from harm

  • Privacy

  • Be referred to professional help if needed

  • Be protected from abuse and bullying

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Our Students

They arrive in the UK and their life is turned upside down.  They have a lot of adjusting to do, as well as studying English. They need help understanding that things which are normal in their culture may not be acceptable in the UK or for students from other countries at the organisation.

 

Students often don’t understand the social or behavioural signals or their surroundings and this makes them vulnerable. Teenagers and young adults are particularly vulnerable because they think they are grown up when usually they are not.

 

Students should do the following: 

  • Follow the three rules: Ready, Kind, Safe

  • Know the Safeguarding Leads

  • Report any concerns to SKOLA adults

3.    CODE OF CONDUCT: SAFER WORKING PRACTICE FOR STAFF

All adults will aim to create a safer school culture. All staff will try to build trust between them and children. They will avoid possible misconstrued situations. Staff should act as role models for the students. Management will act as role models for staff and students.


3.1 Duties of Staff

  1. Duty of care. All adults have a duty to keep children safe and protect them from any abuse.

  2. Duty to report. Staff should report inappropriate contact with children to senior managers. Report any allegations or suspicions.

  3. Duty to treat all students with respect. No staff member should favour any students. Be fair and consistent.


3.2 Adult Interaction

  1. Professional relationship. Staff to maintain professional boundaries between them and the students. You are in a position of influence. Do not use your position to your advantage.

  2. Physical contact. Keep physical contact brief and never touch a child in a way that is indecent. Seek permission before making physical contact. Be aware of cultural/ religious views on touching and be sensitive to issues of gender. If you need to show something (e.g., in sports or drama) it should be in an open environment and for the least time necessary. Use this procedure: show alone > ask permission > show with student.

  3. Physical intervention. Use only in exceptional circumstances in a way that maintains dignity and safety. Never use force or degrading treatment to punish a child. In case of bad behaviour follow the procedure outlined in the staff handbook.

  4. Any inappropriate contact may be considered a ‘Position of Trust’ offence according to Sexual Offences Act 2003.

  5. Social contact: Do not seek social contact with a student or their family outside the school. 

  6. Infatuations. If a student develops an infatuation with you, inform your manager as soon as possible. Record this information and maintain professional boundaries. 

  7. Sexual comments. No suggestive or sexual remarks about a student (in any form). 

  8. Never alone. Avoid being alone with a child. If you need to speak to them in private, do it in a place where someone can see you.


3.3 Adult Conduct

  1. Use appropriate language. Always be aware of your language when speaking to and around the students. Never lose your temper or raise your voice.

  2. Confidentiality. You may have access to confidential information about the students. However, this should always remain confidential and only shared if it’s in the interest of the student.

  3. Dress code. Dress in a way which is appropriate to your role. Wear the SKOLA shirt provided. Don’t wear anything considered inappropriate. For example, miniskirts (without undershorts), rudely worded t-shirts, anything too tight or revealing. In a residential setting wear appropriate nightwear.

  4. Smoking and alcohol. Staff must not smoke or drink on school premises and/or in the presence of the students.

  5. Gifts to students. All gifts should be given to a student publicly and for positive behaviour (e.g., SKOLA Star Awards) not to favour a student.

  6. Gifts to staff, any and all gifts to staff from students or adults should be reported to your manager (in person, including showing the gift). They will record the details of the gift: time, content, and who from - including reason. You should only open it when in the presence of another staff member.  


3.4 Electronic and Social Media Contact
Electronic contact includes telephone communication and online environments. Staff should maintain the same professional standards in electronic contact.


Safe practices:

  • Do not start, establish, or seek to establish electronic contact with a student

  • Ask the school photographer to take  photos/ recordings of the students. Never store images of students on your personal device.

  • Do not lend your phone to students. Ask the central manager to use the school phone to contract parents. The residential head also has a school phone (for residential students)

  • Do not lend personal removable media (USB sticks, CDs, portable hard drives) to students

  • Do not exchange any personal data with students (i.e., personal phone numbers or emails)

  • Social media: If a student sends you any messages. Don’t reply. Record the details. Notify your manager.

  • Do not send or accept any friend requests from students on social networking sites.

  • Do not post or distribute any photos, videos of or information about the students.

 

SKOLA will not use the images of students without their parents' consent. All staff will know which students have parental consent for pictures (see the register for more details) Staff should ask for consent from students and other staff before taking a picture or video. 

4.  WELFARE SYSTEMS

SKOLA will have certain welfare systems in place to always ensure the students’ safety. These include:


4.1 Risk Assessments
These are in place for all on and off-site activities. They are revised regularly. All students will be inducted before each activity and reminded what to do in case of emergency. They must sign each activity to show they have read and understood the risks. 


4.2 Behaviour and discipline procedures
Staff will follow the SKOLA Behaviour Blueprint (link). Staff should aim to be positive when dealing with behaviour issues. Praise good behaviour.


4.3 Staff photo board
There will be a board in each premises. This has staff photos, names, and titles. So, students know who works in the school and what are the responsibilities of each member of staff. Students will also receive this information during Monday induction.

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4.4 Missing students 
Avoid losing students. But in case a student goes missing follow the procedures below

How to avoid missing students?

What to do if a student goes missing?

In Class

  1. Establish rules with your class:        students are not allowed to go out of class during lessons

  2. Be on time for the lessons; lead by example

  3. Check the register before each lesson

  1. Inform a member of the management or admin team as soon as possible.

  2. If it is the first lesson the admin team will follow the guidelines in the absence policy

  3. If it is the second lesson, ask the other students if they have seen the missing student. Try to establish his/ her whereabouts and inform a member of the management or admin team.

DURING EXCURSIONS/ STUDY TRIPS

  1. Remind the students of the rules before every excursion/ activity

  2. Never allow students to go anywhere alone. Make sure they always walk in pairs.

  3. Make sure all students have the school’s emergency number

  4. Headcount the students as often as possible. Do this before leaving the school, getting to the station, on the platform, on the train, etc..

  5. When reaching your destination establish a meeting point where the students should go in case they get lost

  6. Make sure there is a member of staff at the front and back of the group

  1. Stop the group as soon as you realise that a student has gone missing. One member of staff should go back to search for the student

  2. Try to contact the student, you can call the school and a member of the management team will contact the student and advise them what to do

  3. Call and/ or wait for a call from a member of staff responsible for the emergency number

STUDENTS IN HOMESTAY MISSING CURFEW

  1. Students and parents will receive information about curfew times before arrival

  2. Homestay hosts will remind students about these rules every time students go out

  3. Homestay hosts will ensure students have all necessary travel information and contact numbers

  4. Students will only go out if they have a mobile phone with them

  1. Homestay hosts will attempt to contact the student

  2. Homestay hosts will call the school emergency number

  3. School will attempt to contact the student

  4. If student cannot be contacted within 2 hours police will be notified

4.5 Safety and First Aid
The school has the following in place to ensure the student’s safety:

  • Staying safe information: The students' learning journal and the student code of conduct  includes information on how to stay safe during their time in the UK. 

  • Emergency number. All students should have the 24-hour school emergency number. This is in the student learning journal. You should remind students of this. 

  • Travelling to and from school. Students under 14 must be brought to school by a guardian. Students  14 or over may travel on their own. But only if parents/ guardians have given consent on the student registration form.

 1. If a parent decides they want their 14 or over year old child to travel to and from school on their own: they will send an email requesting this change to info@skola.co.uk and inform the centre manager in-person. The parent will receive an email from info@skola.co.uk approving or rejecting this request. 

2. SKOLA has the right to reject requests for students to travel on their own if SKOLA believes this to be unsafe. For example, the student lives too far away or the student is not mature enough. This will be risk assessed by the DSL and centre manager. 

3. Appropriate guidance will be given to such students to help them with their journey.

 

  • Permission forms: Parents/ guardians sign appropriate permission forms for the students, which include:

1.  Permission to travel to and from school on their own (only for students aged 14-17)

2.  To use student’s photographs, audio recordings, etc. in the school’s promotional materials

3.  For students 14 and over in homestay: to go out unaccompanied in the evenings and at weekends. But students must follow rules set out in a separate document and follow the curfew times. These are 9.00 pm for students aged 14-16 and 10.00 pm for students aged 17.

4.  Consent for emergency medical treatment

  • Transfers. Homestay students travelling alone must book a transfer from the airport/ station. This will be clear to parents/ guardians/ agents. They will receive a warning if they fail to make appropriate arrangements for the child’s arrival. The UK Border Agency may refuse entry (e.g., they may suspect Child Sexual Exploitation). For UMs a departure transfer includes accompanying the student to check-in.

  • Visitor book. All visitors to the school must read the visitor leaflet and sign the visitor book. This is at reception (name, time in and out and purpose of visit). A staff member should oversee any visitors

  • Absence policy. The school will follow a strict absence policy when dealing with student absences.

  • First Aid and medical. First aid given by qualified staff. They should follow the general guidelines. Record all cases of first aid in the incident book.

1.  In case of an emergency. If a parent or guardian is unavailable. A staff member will go with the student into an ambulance or walk-in centre. 

2.  If a student falls ill when in homestay, the homestay provider will look after them. If not, they will make alternative arrangements. They will take the student to the doctor (if necessary). 

  • Road Safety. Induction on how to behave while walking on the street before each excursion. Appropriate supervision will ensure road safety.

  • Fire safety. Induction on what to do in case they hear the fire alarm and where the fire meeting point is. 

  • Going home procedure: This will follow the guidelines outlined in the staff handbook. Parents/ guardians of students who are picked up need to sign a list daily. Students leaving on their own are also required to sign out. If the student will be picked up by someone other than parent/ guardian the school needs to be informed in advance. The appointed person needs to show an ID.

  • Students going home early: students may be allowed to go home early only if consent is given by parents/ guardians. In such cases they need to sign out. 


4.6   Supervision ratios
Two adults per class on trips. 
We are obliged to provide adequate supervision for all the students. This is for lessons, excursions, activities, breaks. Also, for accommodation, when in residential centres. Supervision ratios will be stated in the risk assessments.

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During excursions and activities, we will provide at least the minimum amount of supervision outlined by the DfE publication Health and Safety of Pupils on Educational Visits. But we aim to exceed it. The staff to student ratio will be in the risk assessments.

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When deciding on staff/student ratio several factors need to be considered:
Sex, age, and language ability of the group

  • Pupils with special educational or medical needs

  • Nature of the activity

  • Experience and competence of the adults in the party

  • Requirements of the organisation/location to be visited

  • Competence and behaviour of the children

  • Type of accommodation provided

  • First aid cover.

 
Important notes to staff:

  • Staff should follow the supervision guidelines outlined in the staff handbook. They should never leave the students unattended.

  • Staff should pay extra attention to students while travelling on the underground. 

  • During outside activities, at least two staff members should be with students. This is in case of an emergency.

  • Staff should be always vigilant when outside the school.

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Permission to be out of class:

No students should be out of class without a SKOLA staff member.  Students should visit the toilet during break and before lessons only.  But if necessary, schedule suitable breaks for the toilet. This could be for young students or SEN students.


4.7 Age-appropriate activities 
All activities must be appropriate to the child’s abilities and development stage. This will be outlined in the risk assessment of each activity. Here are some examples of important things to take into consideration:

  • Films: make sure any films or clips are age appropriate. 

  • Contact games: Do not mix younger and older children in contact games. Some girls may not want to be mixed with boys, respect that.

  • Art and Crafts. Use age-appropriate utensils used during art and crafts. Younger students should use plastic needles and safety scissors.


4.8 Homestay Accommodation 
All homestay providers follow the Safeguarding Policy and Code of Conduct. This is provided by the homestay agencies and SKOLA. The Homestay Agencies are Hosts International, Perfect Hosts Homestays and Brittania.


Private fostering
SKOLA, homestay agencies and parents inform local councils about any private fostering. This is when a child (under 16) stays with and is cared for by an unrelated adult for at least 28 days. This private arrangement is agreed between the parent and carer. 


4.9 Online Safety (Filtering and Mentoring)

No wifi for students: outside of the summer dates (June to August) SKOLA Gloucester and SKOLA Regents Park sites are schools for adults (Regents University and British American Drama Academy). So, there are no filters on the internet. Therefore, students should not have access to the schools wifi. 

SKOLA will take all measures to help our students stay safe when they go online. Student folders will contain guidance about being safe: not believing all they read, not sharing personal data or photos with people they don’t know, etc.


All internet usage will be supervised by teachers. Students are not allowed to use mobile phones in the school and during out of class activities. 

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Cybercrime is criminal activity committed using computers and/or the internet. 
There are 4 areas of risk that staff need to be aware of:

  1. content: being exposed to illegal, inappropriate, or harmful content. For example, pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, and extremism. 

  2. contact: being subjected to harmful online interaction with other users. For example, peer-to-peer pressure or advertising. Also, adults posing as children to groom or exploit them. Grooming or exploiting could be sexual, criminal, or financial.

  3. conduct: 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 

  4. 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/). 


4.10 Mobile and smart technology
Classrooms at SKOLA Regent’s Park have interactive smart boards. Most students have mobile phones in the school. Students are not allowed to use their mobile phones inside the school premises or on excursions. Breaking this rule will result in the phone being confiscated (for the day). 

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The Wi-Fi password: NEVER SHARED WITH STUDENTS Only age-appropriate material should be displayed on the interactive smart boards. Websites to be vetted before use in the classroom. Contact the DSL if inappropriate content is seen by students. 


4.11 Mental Health 
All staff should be aware that mental health problems can show a child has suffered abuse. Also, it could be a sign they are at risk of suffering abuse, neglect, or exploitation.

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Only trained professionals should attempt to make a diagnosis.  But staff see children every day. So, they can identify behavioural changes. This could suggest that a child has mental health.

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Schools and colleges should access advice to help them identify children in need of support. This includes working with external agencies.

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If staff have a mental health concern about a child that is also a safeguarding concern, act quick. Follow the child protection policy and speak to the DSPs.


4.12 PREVENT Radicalisation & Extremism 
PREVENT is a government strategy to stop people becoming involved in extremism. This includes supporting terrorism. These could result in entering the criminal justice system. 
To prevent extremism and radicalisation we will:

  1. Ensure all staff are familiar with the term’s radicalisation and extremism. Also aware of the problems related

  2. Educate students about acceptance and tolerance on a range of views

  3. Promote British values. For example, democracy, rule of law, individual liberty, mutual respect, and tolerance.

  4. Educate staff to identify vulnerable students. Some factors which make students vulnerable may include:
     

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Educate staff to be vigilant and look out for signs of extremist behaviour. This may include:

  1. Change in attitude

  2. Becoming intolerant/ closed minded

  3. Being isolated

  4. Overt new religious practices

  5. Fall in work standard

  6. Accommodation changes, e.g., posters, etc.

  7. Asking questions about certain topics

  8. Focus on IT safety

 

Staff will raise any concerns to the Prevent Lead Connor Middleton. Connor is also the Designated Safeguarding Lead. He will train staff at induction and through the summer school on the Prevent strategy. This will include the push and pull factors. These can lead to radicalisation. This training will help staff help identify vulnerable children.

5.    RECOGNISING CHILD ABUSE AND BULLYING

REMEMBER: Respond, Record, Report, and Refer

Note: If you think a child is in immediate danger, report to the police immediately and keep the child safe. 


Respond
Concerns, suspicions, allegations, and disclosures come from two main sources:

  1. A child approaches you with information relating to an individual’s behaviour towards themselves or their friend.

  2. You become aware of an individual through first-hand knowledge or a third party (for example through conversation with another adult/child; through direct observations or signs or indicators that suggest abuse; or anonymous tip-off)

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The NSPCC have provided three simple directions to remember when a child is making a disclosure:

  1. Show you care and help them open up- Give them your full attention and keep your body language open and encouraging. be compassionate, be understanding and reassure them their feelings are important.

  2. Take your time, slow down- respect pauses and don't interrupt them- let them go at their own pace. recognise and respond to their body language. And remember that it may take several conversations for them to share what has happened to them

  3. Show you understand, reflect back- make it clear you are interested in what they are telling you. Reflect back what they've said to check your understanding and use their language to show their experience.

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Record

It’s important to record information as soon as possible and as accurately as possible. Information that needs to be passed on. For example, to the Safeguarding Leads or the Police. So they must be as helpful as possible. This is why it is necessary to make a detailed record at the time of the concern, suspicion or disclosure.


Information should include the following:

  1. The nature of the allegations

  2. A description of any visible bruising or other injuries

  3. The child’s account, if it can be given, of what has happened, a witnesses to the incident(s) (this could be you)

  4. Any times, dates or other relevant information

  5. A clear distinction between what is fact, opinion, or hearsay

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Report
Report to one of the Safeguarding Leads. Always complete this incident form or search ‘incident report form SKOLA’ on the SKOLA google drive. Then inform a Safeguarding Lead.  No concern is ever too small or too big. 

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Everyone has an obligation to report any concerns, suspicions, allegations, or disclosures relating to any child or adult involved at SKOLA. SKOLA also recognises that false concerns, allegations, suspicions, or disclosures can be made. However, they are rare, and a robust complaints/disciplinary procedure will always address these.


Refer
Once you have made your report to the Safeguarding Leads. They will decide whether it needs to be referred to an outside organisation. This could include the Local Authority Designated Officer (LADO)*, police or foreign equivalent. 


*LADOs work within Children's Services and give advice and guidance to employers, organisations and other individuals who have concerns about the behaviour of an adult who works with children and young people.


Although different countries have their own way of dealing with safeguarding issues, the key is educating students. For example, the safeguarding lead may signpost students to the NSPCC website. This website is available in multiple languages. By recognising abuse (including their own), children are more likely to seek help.

  1. If you believe a child is in danger, call 999 and ensure the child is safe.

  2. If the child needs medical treatment, refer to the school nurse or first aiders. Phone an ambulance if required. Inform the Safeguarding Leads immediately. 

  3. Always complete this incident form or search ‘incident report form SKOLA’ on the SKOLA google drive. Then inform a Safeguarding Lead.  No concern is ever too small or too big. 

​

5.1 Types of abuse 
There are four categories of abuse. Use the acronym PENS to help remember them:

  1. Physical. For example, hitting, kicking, shaking, poisoning, burning. Also, female genital mutilation (FGM). This is illegal in the UK. It is also illegal for it to happen to any British national abroad.

  2. Emotional. For example, manipulating a child, never saying anything kind to them, threatening them. 

  3. Neglect. This is failing to meet the child’s basic physical and/ or psychological needs. For example, failing to provide adequate food, clothing, and shelter. Also failing to protect children from harm or not providing adequate supervision.

  4. Sexual. For example, forcing a child to take part in sexual activities. This could be both physical and non-physical. This could include exposing them to pornography or taking indecent pictures. Also grooming a child in preparation for abuse (including over the internet).

​​

Domestic Abuse

Harm can include witnessing harm to others. This is particularly possible in a domestic setting. Domestic abuse includes Psychological, Physical, Sexual, Financial and Emotional. This can happen wholly online. They can have a short term and long-term impact on children’s ability to learn, health and well-being. Domestic abuse can happen to anyone. Teenagers in relationships can also experience domestic abuse from their partner. 

Staff have a key role in recognising the signs of domestic abuse. They should record and report concerns to the DSL. Staff should build a positive relationship built on trust with students. This is so students feel safe to voice their concerns.

​

5.2 Typical signs of abuse 
All the categories of abuse have both physical and psychological signs. Some to watch for are:

  • Physical abuse:

a. Has unexpected bruises, burns, etc.
b. Wearing clothes to cover injuries, even in hot weather
c. Refusal to undress for e.g., sports

 

  • Sexual abuse:

a. Acting in an inappropriate sexual way with objects or peers
b. Becoming withdrawn or clingy
c. Personality changing, seeming insecure
d. Unaccountable fear of places or people
e. Becoming secretive
f. Physical signs such as unexplained soreness around genitals, sexually transmitted diseases

​

 

  • Emotional abuse:

a. Delayed physical or emotional development
b. Shows extremes of passivity or aggression
c. Overreaction to mistakes, or continual self-deprecation
d. Neurotic behaviour (rocking, hair twisting, self-mutilation/harm)

​

 

  • Neglect:

a. Often hungry
b. Badly dressed in clothes that need washing
c. Poor appearance and personal hygiene; unwashed, hair not brushed
d. Lacks needed medical or dental care
e. Often tired
f. Might abuse alcohol or drugs

​

Some of these may appear naturally as the children are in a new environment. But, in extreme cases, these might be indicators of a deeper problem.


5.3 If a child discloses abuse
A child may choose any adult to talk to; so, all adults need to know the right way to respond. If a child discloses abuse follow the procedure outlined in the next section of this Policy.


5.4 Bullying
Bullying is usually a repeated action intended to hurt someone. It can be physical or emotional. It is not tolerated at SKOLA because it breaks one of our rules. Everyone should be Kind to themselves and others. Children who are LGBTQ+ can be targeted by other children. A child who is perceived by other children to be LGBTQ+ can be as vulnerable as children who identify as LGBTQ+.


Identifying bullying:

  1. Bullying can take many forms, it can be: 

  2. Physical assault 

  3. Making threats

  4. Teasing

  5. Name-calling 

  6. Cyber bullying 

  7. Lack of respect for someone’s property

  8. Exclusion

  9. Teenage relationship abuse (TRA)

  10. Harmful sexual behaviour (HSB)

​

Sometimes it is not obvious. Sometimes the bully might not even be aware that they are hurting someone. A bullied student may feel too frightened or worried to tell a member of staff. That is why it’s important for the staff to be always observant. It is best practice to observe during break times and activities.


How to deal with bullying:

  1. Don’t ignore it. React and confront the behaviour. Don’t assume it’s ‘teasing’.

  2. Remain calm. Don’t argue or get into conflict with the students. Displaying anger will not enable the student to reflect on their behaviour.

  3. Report all cases to the Designated Safeguarding Staff however trivial they may seem. Record everything in the incident book

  4. Deal with the students individually. Don’t attempt to sort out the facts while everyone is present. Students may get into an argument with one another. If you talk to them on a one-to-one basis, everyone will be able to tell their side of the story.

  5. Hold bystanders accountable – they provide an audience for the bullies. Explain that this type of behaviour is wrong and is not tolerated. They also have a responsibility to stop bullying.

  6. Listen and don’t prejudge - it’s possible that the person you suspect to be the bully is being bullied.

  7. Elicit examples from the offender: examples of bad behaviour and the cause/ effect of it. Tell them that this kind of behaviour is unacceptable. Ask them to consider an appropriate way of putting things right.

  8. Ensure that any apology is done with a member of staff present and recorded in the Incident Book.

  9. Inform the Designated Safeguarding Staff. They will inform the parents of what happened and how it was resolved.

  10. If the bullying continues EST will do its best to protect the victim which may include changing or restricting the activities of the bully. Parents will be informed.

  11. If a student continuously bullies others he/she will be expelled.

  12. For detailed information please see the Policy for Dealing with Abusive Behaviour in the Staff Handbook


5.5 Child Exploitation
Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE) are growing concerns in the UK. Concern for SKOLA is for children travelling alone to the UK who do not attend the courses. CSE and CCE can be linked to ‘County Lines’ where UK criminal gangs use vulnerable children to move drugs around the country. 


Training to spot the signs of abuse
Staff and students have a relationship built on trust. Staff will have a professional curiosity and create safe spaces for disclosure. No victim blaming or judgement.
Record incidents. The DSL will report to local authority children's social care (The local authority designated officer, LADO). Any immediate risk of harm to students will be reported to the police. 


5.6 Honour Based Abuse
Female Genital Mutilation
This procedure is illegal in the UK (Female Genital Mutilation Act 2003). It is considered child abuse, however most FGM families don’t see it as a form of abuse. This procedure is carried out on a broad age range of girls and always has harmful consequences.
Some short-term consequences involve severe pain, emotional/ physical shock, haemorrhage, wound infections.
Some long-term consequences involve vaginal, pelvic infections, difficulties in menstruating/ passing urine. Also damage to the reproductive system, complications during pregnancy, and PTSD.


Girls who are more at risk of FGM:

  • Girls from less integrated communities

  • Familial history of FGM

  • Sister who underwent FGM

  • Girl withdrawn from personal, social and health education


Signs that FGM might take place:

  1. Older visitor (e.g., from country of origin)

  2. References to FGM in conversation

  3. Girl may confide (e.g., that she will have a special procedure or will become a woman)

  4. Long holiday abroad/ parental statement to take child on long holiday


Signs that FGM has taken place:

  1. Difficulty in walking

  2. Long time in toilet

  3. Urinary/ menstrual problems (e.g., very painful periods)

  4. Behaviour changes

​​

If staff notice any of the above they should notify Designated Safeguarding Staff immediately. If a girl discloses FGM, staff should treat it as abuse and handle it like other forms of abuse, outlined in the next section.


Forced Marriage
Forced marriage this is when you face physical pressure to marry. For example, threats, physical violence, or sexual violence. Also, emotional, and psychological pressure. For example, if you’re made to feel like you’re bringing shame on your family.
Students may be travelling to the UK and using SKOLA as a cover for marriage against their will. Staff need to be aware of the possibility for certain cultures to practise this. Speak to the DSL if they have any concerns.  

​

Forced Marriage Unit
fmu@fcdo.gov.uk 
Telephone: 020 7008 0151
From overseas: +44 (0)20 7008 0151
Monday to Friday, 9am to 5pm 
Out of hours: 020 7008 500


5.7 Harmful Sexual Behaviour
Harmful sexual behaviour (HSB) is age-inappropriate sexual behaviour by children. It is harmful or abusive.

​

Peer-on-peer sexual abuse is a form of HSB between children of a similar age or stage of development. 

​

Child-on-child sexual abuse is a form of HSB that takes place between children of any age or stage of development.


Problematic sexual behaviour (PSB) is developmentally inappropriate or socially unexpected, sexualised behaviour. It doesn’t have an overt element of victimisation or abuse.

​

Statutory guidance for schools in England says staff should act on the assumption that all children and young people could be affected by child-on-child sexual violence and harassment (Department for Education (DfE, 2022)


Policies and Procedures
All staff and students should follow the Code of Conduct. This outlines the expectations of behaviour. Any concerns should be recorded and reported to the DSL. 

​

All staff will be trained in what HBS is and how to report it. The training and policy will be reviewed and updated annually, after an update or incident. 

​

Any concerns, observed or disclosed, should be taken seriously, and reported to the DSL without delay. Do not assume the concern has already been reported. 

​

Take immediate action to keep the student safe. 

A Risk assessment needs to be made if sexual violence or harassment has been reported. These should include the following question:

  • How to protect the victim? 

  • Any other victims?

  • Who is the alleged perpetrator?

  • How to protect all other children at the school?

  • When was the time and location of the incident?

The assessment should also include any action required to make that location safer. 

​

5.8 Sharing nudes and semi nudes 
Sometimes referred to as ‘sexting’. This is the sharing of sexual images or videos of yourself or others. Image refers to moving (video) or still (picture) from now on. 
If the person in the image is under 18, it is an indecent image. 
An indecent image refers to a sexual image of a child (under 18). This includes nude or partially clothed children. Also, children posing sexually in self-generated images. This is according to the Sexual Offences Act 2003 England and Wales. 

​

It is illegal to make, have and distribute any 'indecent' imagery of someone under 18. This includes imagery of yourself or another child if you are under 18. According to the Protection of Children Act 1978 England and Wales; Sexual Offences Act 2003, England, and Wales.


Indecent imagery does not always mean nudity. 

  • But images are likely to be defined as such if they meet one or more of the following criteria:

  • nude or semi-nude sexual posing e.g., displaying genitals and/or breasts or

  • overtly sexual images of young people in their underwear

  • someone nude or semi-nude touching themselves in a sexual way

  • any sexual activity involving a child

  • someone hurting someone else sexually

  • sexual activity that includes animals


Any potential incidents should be reported to the DSL. 

  • If the incident is between a child and an adult, report to the police. See NPCC ‘When to call the police’ document. 

  • If it is between children, the DSL will conduct a further review. This includes an interview with any child or young person involved. So, they can establish the facts and assess the risks. The DSL will define the incident using the Finkelhor and Wolak’s typology of youth-produced assessment model. 


If posted indecent images of child are posted online: 
Send signposts to the IWF and Childline’s Report Remove tool at
www.childline.org.uk/info-advice/bullying-abuse-safety/online-mobile-
safety/sexting/report-nude-image-online/. 

​

Report Remove helps children and young people to report an image shared online, to see if it is possible to get the image removed. This must be done as soon as possible to minimise the number of people that have seen the picture. 
 

6.    HANDLING ALLEGATIONS

6.1 When to react to allegations:
All adults have a duty of care towards the students, in and out of school. They need to respond in the following circumstances:

  1. If you notice any signs of abuse (above), tell the Designated Safeguarding Leads (DSL)

  2. If you suspect any adult may be a threat to a child, or behaves inappropriately towards a child tell the Designated Safeguarding Leads (DSL) 

  3. If a child tells you that they are being abused act according to the outlines below

  4. If you overhear a conversation that relates to safeguarding concern

  5. If you have a gut feeling that something is wrong because of changes in behaviour.

 
Don’t assume that a report has been made or that a concern is too small. 


6.2 If a young person tells you they are being abused
VERY IMPORTANT!!

A child may choose any adult to speak to, therefore it’s very important that all staff know how to react if a child discloses to them.

​

You should do the following:

  1. Allow them to speak freely without interruption and accept what they say

  2. Be understanding and reassuring but do not give your opinion

  3. Tell them you will try to offer support, but you must pass the information on

  4. Tell the Designated Safeguarding Leads

  5. Write careful notes of what was said, using actual words wherever possible

  6. Pass your report to the Designated Safeguarding Leads 

​

6.3 Dos and Don’ts
If a child approaches you to disclose that they are being abused remember about the rules below:
 

Do

React calmly and reassure victims that they are being taken seriously, that they will be supported and kept safe to build trust.

 

Be aware of your non-verbal messages

 

Keep responses short, simple, slow, and gentle

 

Observe and listen but don’t ask for more information than you need 

​

VERY IMPORTANT!!

Ask open questions:

  • Tell me…

  • Explain to me…

  • Describe it to me…

​

Be careful not to ask leading questions and remember you are not conducting an interview

​

If you suspect FGM ask value-neutral questions (Have you been closed? Have you been cut down there? How long does it take to pass urine?)

 

Assure the child:

  • What you are saying is important

  • I’m glad you told me I will help you

  • This is so important I need to talk to Connor about it

 

If you have a difficulty in understanding the child because of language or ‘finding the right words’ give them time or find someone who can help.

 

Tell the child they have done the right thing by telling you

 

Write a report that includes what has happened, what you have seen, suspected, or been told immediately. The location and when it happened.

 Avoid stating your feelings but write a factual description of what happened

You should write word-for-word what the child said.

 

Speak to the Designated Safeguarding Leads as soon as possible

don't

Stop a child who is freely talking about what happened

 

Ask for more information than you need

​

Make comments or judgements about what is shared (e.g., “That must have been awful!”)

 

Victim Blame: don’t focus on the behaviour of the victim or give them the impression they are creating a problem. Focus instead on the behaviour of the person who abused the young person.

 

Speculate or accuse anybody

 

Make promises that you cannot keep

 

Tell the child that you will not tell anyone else

 

Tell all the staff

6.4 If an adult is accused
Our aim is to provide a safe environment for our students. But we do recognise that sometimes behaviour of adults may lead to an allegation of abuse.
You must inform the principal immediately if an allegation is made. Also, if you receive information that someone is not suitable to work with children. The allegation would also suggest a member of staff is not suitable to work with children.
The Principal will notify the Designated Officer within one working day. The designated officer is from the Local Authority Safeguarding Board.

​

For SKOLA Gloucester Gate: 
Camden Local Authority Designated Officer (LADO) 
E. LADO@camden.gov.uk / 020 7974 4556

​

For SKOLA Regent’s Park: 
Westminster Duty Child Protection Advisor/LADO
E. lado@westminster.gov.uk / 020 7641 7668

​

The LADO will guide the school if the allegation is found to be true. If a case is either unfounded, false, malicious, or unsubstantiated, the Principal will lead an investigation to determine if any lessons can be learnt from the incident.  
6.5 If a child is accused
Any allegations made will be investigated by the Principal straight away. The guardians of the child will be notified as well as the Designated Officer. The DSL needs to understand the role of Appropriate Adult if a child is accused of criminal behaviour. See safeguarding.link/pace 


6.6 Keeping records
All records need to be kept in a secure, locked place so when you complete them return them to the Designated Safeguarding Persons. No records don’t mean it isn’t happening. 
 
 

7.    SAFER RECRUITMENT

7.1 Overview
SKOLA English in London aims to recruit suitably qualified and experienced teaching and non-teaching staff appropriate to the type of courses we deliver and the type of students we enrol on our courses. Our aim is to choose staff who are not only appropriately qualified but also aware of safeguarding and child protection issues. To avoid attracting staff who are seeking employment with children for the wrong reasons SKOLA will adopt safer recruitment practices.


7.2 Recruitment materials
Publicity: Publicity will state that we are an organisation that is committed to safeguarding and welfare of children, and we seek to maintain a safe and supportive environment so that any potential staff looking at our publicity will be aware of their expectations.


7.3 Information for applicants
Advertising: Advertisements for any positions will include the information that we are committed to safeguarding. Candidates will be informed that they will have to explain gaps in their CV, will undergo a DBS check and references will specifically ask whether there is any reason that the candidate should not be employed to work with under 18s.


7.4 Safer recruitment stages
Applying
Selected candidates will be sent an application form to retain control of the applicant’s information. This form has a section relating to child protection where the candidate can share any information.


Shortlisting process
Candidates are shortlisted based on the fit between their skills and experience in relation to the job description and person specification. The same criteria will be applied to all the applicants. At least 2 people will be involved in the process of shortlisting candidates to avoid subjective judgments. Also, it is less likely that any information will be missed if two people scrutinise the applications. Any gaps in the person’s history or inconsistencies must be identified. Interviewers should perform an online search of each candidate to identify any incidents or issues that may have happened and explore them at interview. 


References
All candidates will be asked to provide names and contact details of 2 professional referees. One of these should be the current or most recent employer. If a candidate has worked with children previously a reference should be obtained from the person or organisation that employed the candidate in work with children (whether this company/ person is the candidate’s current/ most recent employer).


During the interview: 
At the start of the interview the candidate will be asked to show a photo ID and original documentation confirming qualifications. These documents will be copied during the interview. Before starting the interview, the candidate must sign a declaration regarding suitability to work with children. This is an opportunity to discuss any relevant information at an early stage. However, self-disclosed information cannot be used for short-listing. Fair assessment criteria should be applied. Once short-listing has taken place the disclosed information can then be considered.
The candidates will be informed that a DBS check will be carried out on all successful candidates. The 2 disclosures can be compared against each other to highlight any issues.
The candidate will be asked specific questions to ensure that they are genuinely interested in the post for the right reasons.


Background check: 
All successful candidates will undergo a DBS check before the commencement of employment or, in exceptional circumstances, during the first week of employment. In case of staff living abroad for a long period of time before the start of employment, an appropriate police check from the country of residence will be required. The TRA Teacher Services System will no longer list teachers who have been sanctioned in EEA member states. 

Important note: Under the Rehabilitation of Offenders Act convictions become spent after a period (this depends on the conviction). However, there are some situations in which a person must declare any criminal record (including one that is spent) and one of these situations is when someone is applying to work with children.

 

Overseas police check (updated 24th of May 2024): 

All applicants must provide police checks for countries where they have lived or worked: 

​

7.5 Applicants awaiting DBS and/or overseas police clearance
In case an applicant’s DBS/Overseas Police check does not come through before the start of employment, the new employee can start work under exceptional and justifiable circumstances. 


But only if it is approved by the Safeguarding Leads, Principal, and the Director (minimum three people). If three people are not available, then someone from the senior management can be added. Such as a Director of Studies. But no one else can be considered. 


They will have at least 48 hours to review the case independently. They will then meet again and vote in favour or against the applicant working. Only if the decision is passed with 100% of the votes in favour can the applicant be allowed to work. The voters must all sign the justification of the decision. This will be recorded. Then the applicant will be notified. 

​

We will write a risk assessment for the employee in question. We will do the following:

  • Obtain 2 positive references that state that there is no reason why this employee should not be working with children. The reference must be from where they worked with under 18s, and one from a recent or current employer. No reference will be older than 5 years old. 

  • Observe the employee within the first few days of employment

  • Ask the employee to teach in a classroom near the office with the door open and a senior member of staff supervising

  • In case of afternoon activities, the employee will not be solely responsible for the students, they will be working with other staff who have DBS

The employee will not be solely responsible for any under 18s until the DBS comes through.
 
7.6 If a disclosure shows a criminal record:
The applicant’s suitability will be judged on a case-to-case basis. If a person has a criminal record we will consider those which are relevant to the job. The following factors will be considered:

  1. Seriousness and nature of offence(s)

  2. Nature of appointment

  3. Age of offence(s)

  4. Frequency of the offences

The disclosure will be discussed with the prospective employee and at least 3 people will participate in the decision process.
 

8.    STAFF TRAINING

8.1 Responsibility
SKOLA will do everything we can so that our staff are trained and aware of all safeguarding aspects. The management team is responsible for training and making sure all staff members are familiar with our Safeguarding Policy.

The people responsible for safeguarding will have at least level 3 Safeguarding qualification. At least 1 person in the recruitment team will be qualified in Safer Recruitment.


8.2 How training is delivered:

  • A copy of this Policy will be included in the Staff Handbook. All staff will be asked to read it and sign a form stating that they have read and understood it

  • All staff will complete an online Safeguarding course before starting work. In case any candidates have safeguarding certificates they will be asked to provide a copy

  • The staff induction procedures will include a safeguarding session. All staff (including admin, catering staff, etc.) will be trained in safeguarding.

  •  All group leaders will be given a copy of this Policy to read and sign.

  • Knowledge about safeguarding will be regularly updated and revised during staff meetings

 
 

9.    WHISTLEBLOWING

If you have any concerns about how safeguarding is being handled in the school, report to the Director Ben Toettcher (ben@skola.co.uk). All such concerns will be treated as confidential and will be investigated.

 

Whistleblowing Policy

Statement

Skola has adopted this policy and the accompanying procedure on whistleblowing to enable all members of the Skola community to raise concerns internally and in a confidential fashion about fraud, malpractice, health and safety, criminal offences, miscarriages of justice, failure to comply with legal obligations, inappropriate behaviour or unethical conduct in the school. The policy applies to everyone who works at Skola, whether volunteer or staff, paid or unpaid, permanent or temporary, contracted or visiting. The policy also provides, if necessary, for such concerns to be raised outside the organisation.

​

Employment legislation governs the making of disclosures concerning workplace activities and is intended to protect people who whistleblow on bad practice from being subjected to any detriment or from being unfairly dismissed as a result. This procedure is available to anyone who discovers something they feel that they should pass on. All types of wrongdoing are included, whether they are acts committed by colleagues, faults in Skola procedures or oversights which should be rectified. The procedure should be used even in the event that the act or omission causing you concern has finished or has not yet started.

​

Safeguarding

Nothing within this policy is intended to prevent Skola people from complying with their statutory obligations in accordance with Keeping Children Safe in Education (September 2023).

​

Elements of the policy

The school’s policy on whistleblowing is intended to demonstrate that Skola:

  • will not tolerate malpractice;

  • respects the confidentiality of anyone raising concerns and will provide procedures
    to maintain confidentiality so far as consistent with progressing the issue effectively;

  • will provide the opportunity to raise concerns outside of the normal line
    management structure where this is appropriate;

  • will provide a clear and simple procedure for raising concerns, which is accessible to
    everyone working at Skola.

​​

Scope
This procedure is separate from the Skola adopted procedures regarding grievances. Individuals should not use the whistleblowing procedure to raise grievances about their personal employment situation.

​

This procedure is to enable people to express a legitimate concern regarding suspected malpractice within the School. Malpractice is not easily defined; however, it includes allegations of fraud, financial irregularities, corruption, bribery, dishonesty, acting contrary to the staff Code of Conduct, criminal activities, failing to comply with a legal obligation, miscarriages of justice, or creating or ignoring a serious risk to health, safety or environment.

​

People who feel unable to raise an issue with Skola or feel that their genuine concerns are not being addressed, may use other whistleblowing channels, such as those outlined in section: External Procedures below.

​

Confidentiality

Individuals who wish to raise a concern under this procedure are entitled to have the matter treated confidentially and their name will not be disclosed to the alleged perpetrator of malpractice without their prior approval. In order to preserve confidentiality, it may be appropriate that concerns are raised orally rather than in writing, although members of staff are encouraged to express their concern in writing wherever possible. If there is evidence of criminal activity, then the police will in all cases be informed.

​

Procedure

Anyone working at Skola is at liberty to express their concern to the Principal or to the senior management team. Any concern raised will be investigated thoroughly and in a timely manner, and appropriate corrective action will be pursued. The declarant will be kept informed of progress and, whenever possible and subject to third party rights, will be informed of the resolution.

​

A person who is not satisfied that their concern is being properly dealt with will have a right to raise it in confidence with the Director and then the Council.

​

External procedures

Where all internal procedures have been exhausted, an individual shall have a right of access to an external person/body. This may include (depending on the disclosure subject matter):

  • the Local Authority Designated Officer;

  • Children's Social Care;

  • the Health and Safety Executive;

  • the Environment Agency;

  • the Information Commissioner;

  • the Department for Education (DfE);

  • the Department for Business, Enterprise and Regulatory Reform;

  • the Police;

  • the Charity Commission;

  • the Independent Schools Inspectorate (ISI);

  • the Office for Standards in Education, Children's Services and Skills (Ofsted).

​​

Bypassing the procedure

In extreme circumstances, individuals have the right to raise a concern directly with a relevant and appropriate outside body without first having followed the stages above. This may however cause damage to Skola and its reputation as well as constitute a breach of staff’s own duty of confidentiality towards the school and this action should only be taken in extreme circumstances and after careful thought.

​

Extreme circumstances

The school will consider these exist where the person concerned has a reasonable belief that:

  • the school will subject them to detriment if they inform the Principal or the senior management team;

  • the school would conceal or destroy the relevant evidence;

  • a disclosure made previously in accordance with the stages above has not prompted
    a satisfactory response; or

  • the Secretary of State has ordered it.

​​

The media

Even where extreme circumstances are thought to exist, individuals should under no circumstances approach a commercial body or the media with details of the suspected wrongdoing. If staff approach any such body and/or where a concern is disclosed for personal gain, the school may consider this to be gross misconduct and immediate disciplinary action may be taken against the member of staff concerned; if the person making such an approach is a volunteer and/or not under legal contract with the school, the school reserves the right to terminate their work at Skola.

​

Malicious accusations

False, malicious, vexatious or frivolous accusations will be dealt with under the School's Disciplinary Procedure.

Protection from reprisal or victimisation

No person shall suffer a detriment or be disciplined for raising a genuine and legitimate concern, providing that they do so in good faith and following the Whistleblowing policy.

​

Appendix

NSPCC contact details:

 

The NSPCC have a Whistleblowing Advice Line for professionals who are worried about how child protection issues are being handled in their own or another organisation. The number of the Advice Line is 0800 028 0285. It can also be contacted via the NSPCC Helpline.

 
 

10.  FAILURE TO COMPLY

Non-compliance with the policy on contact with students under 18 will result in disciplinary procedures. Non-compliance with safeguarding is an example of not being ready, being unkind, and unsafe. Therefore, you will have a meeting with the Principal who will assess if you are a risk to children.  

Employers have a duty to and will remove an individual from regulated activity where there is a risk of harm to children. Employers have a duty to refer the suspicion or allegation to external authorities where there is a risk of harm to children. 

Once you have read this document give the DSL a fist pump the next time you see them. 
 
Connor Middleton, SKOLA English in London
Updated: March 2024, next update Oct 2025

11. BIBLIOGRAPHY

Useful contacts:

​​

​

Some key publications: (dates of most recent update in brackets)
(1) Keeping Children Safe in Education + Summary for Staff (September 2023)
(2) Working Together to Safeguard Children (Reissued December 2023 Updated February 2024)
(3) Information Sharing (July 2018)
(4) What to Do if You’re Worried a Child is Being Abused (March 2015)
(5) When to Call the Police NPCC (National Police Chief’s Council)
(6) Sharing nudes and semi-nudes: how to respond to an incident (UK Council for Internet Safety)
Dec 2020
(7) After-school clubs, community activities, and tuition (Updated September 2023)
After-school clubs, community activities and tuition: safeguarding guidance for providers - GOV.UK (www.gov.uk)
(8) CassReview_Final.pdf(2024)
(9) Safeguarding Quizzes and resources - to expand your knowledge

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