Safeguarding Policy

The purpose and scope of this policy statement

The purpose of this policy statement is:

to protect children and young people who receive SPM Development Services Ltd.’s services from harm
to provide staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child protection. This policy applies to anyone working on behalf of SPM Development Services Ltd.’s including senior managers, paid staff, volunteers, sessional workers, agency staff and students.

Legal framework

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation and guidance is available from nspcc.org.uk/child protection

We believe that:

children and young people should never experience abuse of any kind
we have a responsibility to promote the welfare of all children and young people, to keep them safe and to practise in a way that protects them.

We recognise that:

the welfare of children is paramount in all the work we do and in all the decisions we take
working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare
all children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse
some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues
extra safeguards may be needed to keep children who are additionally vulnerable safe from abuse.

We will seek to keep children and young people safe by:

valuing, listening to and respecting them
appointing a nominated child protection lead for children and young people
adopting child protection and safeguarding best practice through our policies, procedures and code of conduct for staff and volunteers
developing and implementing an effective online safety policy and related procedures
providing effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all staff and volunteers know about and follow our policies, procedures and behaviour codes confidently and competently
recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made
recording and storing and using information professionally and securely, in line with data protection legislation and guidance
sharing information about safeguarding and good practice with children and their families via leaflets, posters, group work and one-to-one discussions
making sure that children, young people and their families know where to go for help if they have a concern
using our safeguarding and child protection procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, parents, families and carers appropriately
using our procedures to manage any allegations against staff and volunteers appropriately
creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that does arise
ensuring that we have effective complaints and whistleblowing measures in place
ensuring that we provide a safe physical environment for our children, young people, staff and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance
building a safeguarding culture where staff and volunteers, children, young people and their families, treat each other with respect and are comfortable about sharing concerns.

Designated Safeguarding Officer (DSO)

SPM Development Services Ltd. have a DSO to:

Offer support and training to all employees and volunteers involved in SPM Development Services Ltd.’s work.
To ensure that all SPM Development Services Ltd employees and contractorsare sufficiently vetted.
Act as the main point of contact in the event of any allegation or disclosure
Act as the main point of contact between SPM Development Services Ltd and partner organisation

If there is an allegation, if signs and indicators of abuse are identified or if at any point an adult involved with SPM Development Services Ltd.’s work fails to comply with any element of the Code of Behaviour this information must be passed immediately to SPM Development Services Ltd.’s DSO. It is the DSO’s responsibility to collect all relevant information and make decisions on how to proceed (this will include contacting the Designated Safeguarding Lead (DSL) at the relevant partner organisations). Volunteers, tutors and employees should report all signs, reports and concerns.

DSO

Simon Piper-Masha

simon@spmdevelopmentservices.co.uk

07787530009

Procedures

In all cases related to child protection and safeguarding, the main procedure is to treat the allegation seriously, in strict confidence and immediately contact the SPM Development Services Ltd.’s DSO, and/or allocated school child protection and safeguarding lead(s). In the event of SPM Development Services Ltd.’s DSO being contacted the following protocol will be followed:

The information will immediately be passed on to the school’s/organisation’s DSLs.
The school/organisationshall follow their procedure for contacting the local Police Child Protection Unit or the Social Services Department of the relevant Local Authority (the Authorities). SPM Development Services Ltd. shall support the school/organisationwith any action that they deem appropriate and shall undertake reasonable endeavours to provide them with any assistance or documents.
SPM Development Services Ltd. shall not, under any circumstances, undertake any independent investigation or questioning (as this may jeopardise any enquiry) unless or until SPM Development Services Ltd. is given authorisation by the school/organisationor the authorities. Following authorisation, SPM Development Services Ltd. may independently follow up on the allegation.
All allegations or suspicions shall be referred to the school/organisationno matter how insignificant they seem to be or when they occur. Any information about suspicious behaviour or circumstances will be passed to the local Police Child Protection Unit or the local Social Services within 24 hours or as soon as shall be reasonably practicable.

How to report:

When a safeguarding concern occurs, tutors/mentors will not promise confidentiality.
They will listen carefully to the child/young person and try to remember the key words or phrases used. They will aim to provide an environment that is supportive and respectful. They will not ask leading questions or start to investigate the issue.
Once a safeguarding concern has occurred, tutors/mentors will contact the DSO as soon as practically possible. If they can’t contact their DSO, they will contact the partner organisation’s DSL, or seek guidance from the relevant local authority’s Single Point of Contact team.
SPM Development Services Ltd.’s DSO will listen to the safeguarding concern raised by the tutor/mentor, in an appropriate environment which means only those who need to hear the details of the concern are able to. If a tutor/mentor raises a safeguarding concern in a more public environment (e.g., with other pupils in the room or in a tutor-only debrief session) the DSO will ensure a more appropriate environment is found to hear the safeguarding concern, as soon as practically possible.
The DSO will read and/or listen to the safeguarding concern, depending on the format it has been provided in.
The safeguarding report form will be completed, either by the DSO or the tutor/mentor, as appropriate.
The safeguarding concern/incident will be emailed to the DSL of the school/partner organisation as soon as practically possible.

In the event that a young person discloses abuse to a tutor/mentor of SPM Development Services Ltd:

SPM Development Services Ltd tutors/mentors shall:

Allow the young person to speak without interruption, encouraging them to tell you only what they feel comfortable telling you, and be accepting and be non-judgemental about what is said. Do not ask investigative or leading questions of any kind.
Advise the young person that you will offer support, but that you MUST pass what they tell you and are not able to keep anything they tell you confidential.
If they refuse to tell you anything unless you promise to keep it a secret, inform them that you want to help and that there is one person you have totell. If they then refuse to tell you any more, please respect their decision and report this incident.
Ensure that the young person is not immediately at risk of any further abuse.
Immediately after a disclosure, contact the DSO at SPM Development Services Ltd
Report the facts as you know them/ or understand them, including the young person’s name and the account given to you by the young person using the words that they used as well as including any other information you feel is relevant.
Provide this detailed information to the DSO at SPM Development Services Ltd as soon as you are able.
SPM Development Services Ltd shall retain a copy of all such notifications in accordance with GDPR guidelines.
SPM Development Services Ltd has a legal duty to make a referral to the DBS where they consider an individual has engaged in conduct that harmed (or is likely to harm) a child; or if a person otherwise poses a risk of harm to a child.

In the event that tutor/mentor suspects abuse, but it has not been disclosed by the young person: SPM Development Services Ltd. tutors/mentors shall:

Not discuss your suspicions with the young person in question or conduct any form of investigative work.
Report the facts as you know them/ or understand them, including the pupil’s name and the account given to you by the young person using the words that they used as well as including any other information you feel is relevant.
Provide this detailed information to the DSO at SPM Development Services Ltd. as soon as you are able.
SPM Development Services Ltd. shall retain a copy of all such notifications in accordance with GDPR guidelines.

If you receive an allegation about any adult or about a tutor/mentor (including the person hearing the allegation): SPM Development Services Ltd. tutors/mentors shall

Immediately after receiving an allegation or disclosure, contact the DSO at SPM Development Services Ltd.
Report the facts as you know them/ or understand them, including the names of relevant adults and/or young people and the account given to you using the words that they used as well as including any other information you feel is relevant.
Provide this detailed information to the DSO at SPM Development Services Ltd.as soon as you are able.
SPM Development Services Ltd.shall retain a copy of all such notifications in accordance with GDPR guidelines.
Any allegations against SPM Development Services Ltd.tutors/mentors/staff will be reported to the DSO. If the allegation is against the DSO, then the SPM Development Services Ltd. employee’s whistleblowing policy should be followed.

When dealing with the personal data of young people (including names, grades and school): SPM Development Services Ltd. tutors/mentors shall

Handle all information with sensitivity and confidentiality and in accordance with GDPR guidelines.
The information should be kept securely and not be made available to others without the authority of SPM Development Services Ltd.

Duty of care towards our tutors/mentors SPM Development Services Ltd. must:

Manage and minimise the stress caused by any allegation made about them
Inform the individual as soon as possible, explaining the likely course of action, guided by the Local Authority Designated Officer (LADO), and the police where necessary
Advise the individual to contact their trade union representative, or a colleague for support
Keep the person informed about the progress of the case
Signpost tutors/mentors towards sources of helpand support.
Not prevent social contact with work colleagues and friends, when employees are suspended, unless there is evidence to suggest this may prejudice the gathering of evidence.

Safer Recruitment and Training

SPM Development Services Ltd. maintains a high standard in recruiting tutors/mentors. All tutors/mentors/staff working closely with children and young people will be subject to an enhanced DBS check before they can begin work. All employees without direct contact have a basic DBS check. All individuals are checked against the Barred List for working with children.

Every tutor/mentor must be able to fulfil one of the following:

Have an existing enhanced DBS check not more than two years old verified by a member of SPM Development Services Ltd., with the disclosure number and date of issue recorded, along with a photographic ID. This DBS must check against the barred children’s list and must have ‘child workforce’ listed.

If a tutor/mentor is on the DBS update service, before using this service, SPM Development Services Ltd. must:

Obtain consent from the individual to carry out an online check to view the status of an existing enhanced DBS check
Confirm the DBS certificate matches the individual’s identity
Examine the original certificate to ensure that it is valid for employment with the children’s workforce.
Arrange with SPM Development Services Ltd.to have a new enhanced DBS check processed by SPM Development Services Ltd.

Additionally, all tutors/mentors are vetted in line with the processes and procedures set out in Keeping Children Safe in Education 2022. This includes the appropriate checks for safer recruitment.

All tutors/mentors have had their ID checked – either passport or photo driving license with proof of address.
All our tutors/mentors have had their date of birth checked.
A risk assessment is conducted by our DSO for tutors/mentors with a conviction on their Enhanced DBS certificate.
All our tutors/mentors are checked against the ‘Prohibited from Teaching’ list.
Two satisfactory references are obtained.
All tutors/mentors that have lived or worked overseas for more than six months or more in the past five years have provided either an overseas criminal record check, a letter of good conduct or a risk assessment has been done.
Right to work in the UK checks.

This policy is made available to all adults involved in SPM Development Services Ltd.’s activities and all tutors/mentors confirm they have received safeguarding training and understand their responsibilities in relation to safeguarding.

SPM Development Services Ltd. adheres to Keeping Children Safe in Education (September 2022) and this document is key to our safeguarding approach for all tutors/mentors.

Record keeping and Data Protection

All SPM Development Services Ltd. safeguarding processes, incidents and documentation will be kept securely with restricted access and will refer to the guidance in the Data protection: toolkit for schools to support with data protection activity, including compliance with General Data Protection Regulation (GDPR).

Information will be shared only with individuals who ‘need to know’. Relevant staff have due regard to GDPR principles which allow them to share (and withhold) information. All tutors/mentors must be aware that they have a professional responsibility to share information with other agencies in order to safeguard children and that the Data Protection Act 1998 and GDPR are not a barrier to sharing information where a failure to do so would place a child at risk of harm. There is a lawful basis for child protection concerns to be shared with agencies who have a statutory duty for child protection.
All tutors/mentors must be aware that they cannot promise a child to keep secrets which might compromise the child’s safety or wellbeing.

Code of conduct

All adults coming into contact with children and young people through SPM Development Services Ltd.’s work must comply with this Child Protection and Safeguarding Children Policy and this code of conduct. You must:

Act in accordance with the partner organisation’spolicies and procedures regarding child protection and safeguarding.
Treat all young people with respect.
Avoid being alone with a young person or cause someone else to be alone with a young person because of your actions e.g.,being late. If alone in a room with young people, keep the door open at all times.
Remember that someone else might misinterpret your actions, no matter how well intentioned.
Be aware that any physical contact with a young person can be misinterpreted and should always be avoided. Shaking hands in a public setting is considered acceptable.
Be aware that social networking sites are in the public domain if not protected by privacy settings. Strongly consider strengthening any privacy settings so that young people would not be able to access your online profiles and be privy to any information you would not want in the public domain.
Block any young people that approach you online and inform SPM Development Services Ltd.’s DSO immediately.
Recognise that special caution is required when discussing sensitive issues with young people.
Challenge unacceptable behaviour and report all allegations/suspicions of abuse to the SPM Development Services Ltd.’s DSO.
Operate within SPM Development Services Ltd.’s procedures in the event of any disclosure/concern.
Raise any questions or concerns about child protection and safeguarding with SPM Development Services Ltd.’s DSO, or if unsure of an organisation’s procedure, information should be sought from the DSO.

You must not:

Promise confidentiality to young people in any situation.
Seek out or add young people on any social networking site.
Respond to any online communication from a young person, for example on a social networking site.
Share any personal contact details with young people, or,seek out their personal contact details.
Arrange to meet a young person outside of the allocated tutoring/mentoring time, unless on the prior knowledge of a member of SPM Development Ltd, the partner organisation or parents/carers.
Act in a manner that excludes the young people you are working with.
Make suggestive or derogatory remarks in front of young people.
Have inappropriate physical contact or verbal contact with young people.
Show favouritism to any individual.
Be under the influence of alcohol or other substances when working on activities involving young people.
Take photographs of young people (unless written consent has been given).
According to the Equality Act, you must not unlawfully discriminate against pupils because of their sex, race, disability, religion or belief, gender reassignment, pregnancy and maternity, or sexual orientation (protected characteristics.

Online tutoring (at home and in school)

For all online tutoring completed in the name of SPM Development Services Ltd., SPM Development Services Ltd. will provide:

Clear employee training in how to monitor child protection and safeguarding in online tutoring sessions.
Clear tutor training on how to conduct themselves in a safe and appropriate manner throughout online tutoring sessions.
The safe and limited access storage of all data generated as a result of online sessions. GDPR apply as per the SPM Development Services Ltdpolicy.
A DSO who is responsible for supporting and training allstaffinvolved in SPM Development Services Ltd.’s work, ensuring that all SPM Development Services Ltd. employees and contractors are sufficiently vetted, acts as the main point of contact in the event of any allegation or disclosure, acts as the as the main point of contact between SPM Development Services Ltd. and partner schools.

Online tutor/mentor code of conduct

All tutors/mentors are required to adhere to the following code of conduct:

Only conduct online tutoring with their pupils at the designated tutoring times and dates.
Conduct online tutoring either in a workplace or location that does not expose personal information or access to inappropriate background content.
Tutor/mentors who are temporarily based abroad for work or educational purposes may request to continue tutoring during their time abroad. Only tutors/mentors who will be abroad for six weeks or less will be considered. Schools/organisations/parents/carershave the right to pause tutoring by tutors/mentorswho are abroad if it is in conflict with their own policies.
Tutor/mentors will be dressed appropriately in a manner that would be suitable for their attendance at work in person.
Tutor/mentors will not record video, still images or audio of any tutoring sessions.
Tutors/mentorswill never disclose their personal phone, email or other communication details with their pupils nor request their pupil’sthrough the online platform.
Tutors/mentorswill conduct their sessions without disruption (mobile phones should be set to silent and away from gaze) or supervision by any other persons
Tutors/mentors will report any concerns about safeguarding or child protection as well as follow all SPM Development Services Ltd.safeguarding and child protection procedures outlined in the main text of the ‘SPM Development Services Ltd. Child Protection and Safeguarding Protection Policy dated September 2022’.
Tutors will follow any additional requirements as requested by individual organisation policies regarding digital working.

Online pupil code of conduct

All pupils agree to the following code of conduct for online sessions:

Pupils will only receive online tutoring at the designated tutoring times and dates.
Pupils who receive online tutoring from their home shall do so with a parent or guardian present in the home.
Pupils will be dressed appropriately.
Pupils will conduct online tutoring either in a workplace or location that does not expose personal information.
If broadband speed permits, pupils will keep their video stream ‘on’ for the duration of their sessions.
Pupils will have any mobile phones on silent and out of gaze during sessions, or completely away.
Pupils will not record video, still images or audio of any tutoring sessions.
Pupils will never disclose their phone, email or other communication details with their tutor/mentor nor request those of their tutor through the online platform.
Pupils will not take any screenshots of sessions.

Parent/guardian and/or Responsible Adult code of conduct (for home-based online tutoring):

Parents/guardians or the named Responsible Adult of pupilsin receipt of home-based tutoring will remain at home for the duration of the tutoring session.
Parents/guardians or the named Responsible Adult will support their child with basic IT set up, with the support of the SPM Development Services Ltd.team.
Parents/guardians or the named Responsible Adult will support their child to attend and engage in as many online tutoring sessions as possible.
Only pupils enrolled on the SPM Development Services Ltd.programme may be involved in online tutoring sessions with SPM Development Services Ltd.tutors.
Parents/guardians or the named Responsible Adult will pass on any concerns about safeguarding immediately to the DSO
Parents/guardians or the named Responsible Adult will ensure a safe, quiet and appropriate environment for online tutoring to take place at home for their child.

This policy will be formally reviewed every year, or in line with Governmental guidance.