This policy applies to staff, consultants, contractors, suppliers and others working with
vulnerable adults on behalf of EM Skills Ltd
As part of our commitment to assuring quality standards and protecting learners EM Skills
ensures that any regulatory requirements are met and provides guidance and support to
employees, centres, consultants, trainers and learners to achieve their learning and
development goals. These processes are reviewed as appropriate to ensure that they
remain fit for purpose.
This policy concerns safeguarding children and vulnerable adults with whom EM Skills
employees, or those acting on our behalf, come into contact, as well as the EM Skills
adherence to the government’s Prevent strategy.
This policy relates to all situations in which EM Skills staff (paid and unpaid), associates,
contractors and suppliers and others instructed by and acting on behalf of the company,
come into contact with children and vulnerable adults.
Definition. The term ‘staff’ for this policy includes any of the following: paid staff and
volunteers, associates, contractors and suppliers and others instructed by and acting on
behalf of the company.
In some of our activities, EM Skills staff, may come into contact with those who are
vulnerable, perhaps because of their age, physical or mental ability or ill health. We are
responsible to ensure that children and other vulnerable adults are not harmed in any way,
or subject to harm through contact with the company or its agents. We have a legal duty to
act prudently and this means that we will take all reasonable steps within our power to
ensure that this does not happen.
Implementation of this policy
EM Skills Ltd will recruit or appoint staff or associates who are deemed suitable to work with
children and vulnerable adults, based on their declarations of unspent and exempt
Staff found in breach of this policy will be subject to disciplinary action. Suppliers may be
subject to legal action.
EM Skills Ltd will comply fully with all relevant legislation in responding to a breach of this
policy. Breaches will be reported to the appropriate authorities. A full record of any
reported incidents or suspicions, including the procedures followed, the feedback received
and to whom the case was referred.
EM Skills makes a positive contribution to a strong and safe community and recognises the
right of every individual to stay safe.
EM Skills comes into contact with children and / or vulnerable adults through the following
Delivery of training
Tutoring of students
Assessing of students
General contract through our normal activities
This policy seeks to ensure that EM Skills undertakes its responsibilities with regard to
protection of children and / or vulnerable adults and will respond to concerns appropriately.
The policy establishes a framework to support paid and unpaid staff in their practices and
clarifies the organisation’s expectations.
The principal pieces of legislation governing this policy are:
o Working Together to Safeguard Children 2010
o Counter Terrorism and Security Act 2015
o The Children Act 1989
o The Adoption and Children Act 2002:
o The Children act 2004
o Safeguarding Vulnerable Groups Act 2006
o Care Standards Act 2000
o Public Interest Disclosure Act 1998
o The Police Act – CRB 1997
o Mental Health Act 1983
o NHS and Community Care Act 1990
o Rehabilitation of Offenders Act 1974
Safeguarding is about embedding practices throughout the organisation to ensure the
protection of children and / or vulnerable adults wherever possible. In contrast, child and
adult protection is about responding to circumstances that arise.
Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by
those in a position of authority. This can be caused by those inflicting harm or those who fail
to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or
It can take a number of forms, including the following:
Financial (or material) abuse
The Prevent strategy, published by the Government in 2011, is part of our overall counter-terrorism
strategy, CONTEST. The aim of the Prevent strategy is to reduce the threat to the UK from terrorism
by stopping people becoming terrorists or supporting terrorism. In the Act this has simply been
expressed as the need to “prevent people from being drawn into terrorism”. 6. The 2011 Prevent
strategy has three specific strategic objectives: • respond to the ideological challenge of terrorism
and the threat we face from those who promote it; • prevent people from being drawn into
terrorism and ensure that they are given appropriate advice and support; and • work with sectors
and institutions where there are risks of radicalisation that we need to address. Prevent duty gui
Definition of a child
A child is under the age of 18 (as defined in the United Nations convention on the Rights of a
Definition of Vulnerable Adults
A vulnerable adult is a person aged 18 years or over who may be unable to take care of
themselves or protect themselves from harm or from being exploited.
This may include a person who:
Is elderly and frail
Has a mental illness including dementia
Has a physical or sensory disability
Has a learning disability
Has a severe physical illness
Is a substance misuser
All staff and associates have responsibility to follow the guidance laid out in this policy and
related policies, and to pass on any welfare concerns using the required procedures.
We expect all staff and associates to promote good practice by being an excellent role
model, contribute to discussions about safeguarding and to positively involve people in
developing safe practices.
The lead officer is John Emmett. This person’s responsibilities are to ensure the policy is:
In place and appropriate
monitored and reviewed
EM Skills will ensure:
Sufficient resources (time and money) are allocated to ensure that the policy can be
They promote the welfare of children and vulnerable adults
Ensure evidence of radicalisation is dealt with according to the correct procedure
Staff and associates have access to appropriate training/information
Staff concerns about safeguarding and radicalization are investigated and will
respond to all of them seriously, swiftly and appropriately
That they keep up to date with local arrangements for safeguarding, DBS
They develop and maintain effective links with relevant agencies
Leadership Prevent duty guidance
For all specified authorities, we expect that those in leadership positions will:
• establish or use existing mechanisms for understanding the risk of radicalisation
• ensure staff understand the risk and build the capabilities to deal with it
• communicate and promote the importance of the duty
• ensure staff implement the duty effectively.
Working in partnership
Frontline staff who engage with the public should understand what radicalisation means and why
people may be vulnerable to being drawn into terrorism as a consequence of it. They need to be
aware of what we mean by the term “extremism” and the relationship between extremism and
terrorism. Staff need to know what measures are available to prevent people from becoming drawn
into terrorism and how to challenge the extremist ideology that can be associated with it. They need
to understand how to obtain support for people who may be being exploited by radicalising
We will provide appropriate training for staff involved in the implementation of this duty. Such
training is now widely available.
5. Implementation Stages
The scope of this Safeguarding Policy is broad ranging and in practice, it will be implemented
via a range of policies and procedures within the organisation.
Whistleblowing – ability to inform on other staff/ practices within the organisation
Grievance and disciplinary procedures – to address breaches of procedures/ policies
Health and Safety policy, including lone working procedures, mitigating risk to staff and
Equal Opportunities policy– ensuring safeguarding procedures are in line with this
policy, in particular around discriminatory abuse and ensuring that the safeguarding
policy and procedures are not discriminatory
Data protection (how records are stored and access to those records)
Confidentiality (or limited confidentiality policy) ensuring that service users are aware of
your duty to disclose
6. Safe recruitment
EM Skills ensures safe recruitment through the following processes:
Job or role descriptions for all roles involving contact with children and/or vulnerable
adults will contain reference to safeguarding responsibilities.
There are person specifications for roles which contain a statement on core competency
with regard to child/vulnerable adult protection/ safeguarding
Shortlisting is based on formal application processes/forms and not on provision of CVs
Interviews are conducted according to equal opportunity principles and interview
questions are based on the relevant job description and person specification
DBS checks will be conducted for specific roles for all staff (paid or unpaid) working with
children and vulnerable adults. It is a criminal offence for individuals barred by the ISA to
work or apply to work with children or vulnerable adults in a wide range of posts.
Service delivery contracting and sub-contracting:
Contracts and memorandums of agreement/understanding for partnership delivery work
will include clear minimum requirements, arrangements for safeguarding and non-
7. Communication training and support for staff
EM Skills commits resources for induction, training of staff and associates, effective
communications and support mechanisms in relation to safeguarding
Induction will include:
Discussion of the Safeguarding Policy (and confirmation of understanding)
Discussion of the Prevent Strategy
Discussion of other relevant policies
Ensure familiarity with reporting processes
Initial training on safeguarding including: safe working practices, safe recruitment,
understanding child protection and the guide for adult safeguarding
All staff who, through their role, are in contact with children and /or vulnerable adults will
have access to safeguarding and Prevent training at an appropriate level.
Communications and discussion of safeguarding issues
Commitment to the following communication methods will ensure effective communication
of safeguarding issues and practice:
one to one meetings (formal or informal)
participation in multi-agency safeguarding procedures and meetings in order to be
involved in child/ adult protection procedures
provision of a clear and effective reporting procedure which encourages reporting of
encouraging open discussion to identify and barriers to reporting so that they can be
inclusion of safeguarding as a discussion prompt during supervision meetings/ appraisals
to encourage reflection
We recognise that involvement in situations where there is risk or actual harm can be
stressful for staff concerned. The mechanisms in place to support staff include:
Debriefing support for staff and associates so that they can reflect on the issues they
have dealt with.
Seeking further support as appropriate e.g. access to counselling.
Staff who have initiated protection concerns will be contacted by line manager within 1
8. Professional boundaries
Professional boundaries are what define the limits of a relationship between a support
worker and a client. They are a set of standards we agree to uphold that allows this
necessary and often close relationship to exist while ensuring the correct detachment is
kept in place.
EM Skills expects staff to protect the professional integrity of themselves and the
We do not accept our staff and associates to:
Use abusive language
Use punishment or chastisement
Pass on personal contact details
Sell to or buy items from a service user
Accept responsibility for a student
Accept money as a gift/
Borrow money from, or lending money to, service users
EM Skills does not encourage staff and associates to give gifts to or receive gifts from
Personal relationships between a member of staff and a student under 18 or vulnerable
adult are not encouraged and could lead to dismissal if EM Skills directors felt the
relationship could harm the student.
The process outlined below details the stages involved in raising and reporting
safeguarding/Prevent concerns at EM Skills.
Communicate your concerns with your immediate manager
Seek medical attention for the vulnerable person (if needed)
Discuss with parents of child or with vulnerable person
Obtain permission to make referral if safe and appropriate
If the immediate manager is implicated, then refer to their line manager or peer.
10. Allegations Management
EM Skills recognises its duty to report concerns or allegations against its staff within the
organisation or by a professional from another organisation.
The process for raising and dealing with allegations is as follows:
First step: Any member of staff from EM Skills is required to report any concerns in the first
instance to their line manager or safeguarding manager. A written record of the concern
will be completed by the safeguarding manager.
Second step- Contact the Hertfordshire Safeguarding Children Board or advice
Third step – follow the advice provided
EM Skills recognises its legal duty to report any concerns about unsafe practice by any of its
paid or unpaid staff to the Independent Safeguarding Authority (ISA), according to the ISA
referral guidance document http://www.isa-
EM Skills will monitor the following safeguarding/Prevent aspects:
Safe recruitment practices
DBS checks undertaken
References applied for new staff
Records made and kept of supervision sessions
Training – register/ record of staff training on child/ vulnerable adult protection
Monitoring whether concerns are being reported and actioned
Checking that policies are up to date and relevant
Reviewing the current reporting procedure in place
Presence and action of designated senior manager responsible for Safeguarding is in
12. Managing information
Information will be gathered, recorded and stored in accordance with the following policies:
Data Protection Policy,
All staff must be aware that they have a professional duty to share information with other
agencies in order to safeguard children and vulnerable adults. The public interest in
safeguarding children and vulnerable adults may override confidentiality interests.
However, information will be shared on a need to know basis only, as judged by the
designated senior manager.
All staff must be aware that they cannot promise service users or their families/ carers that
they will keep secrets.
13. Conflict resolution and complaints
EM Skills adheres to the Hertfordshire Safeguarding Children Board on resolution of
professional disagreements in work relating to the safety of children / Escalation Policy and
if necessary this will be taken forward by John Emmett the Designated Senior Manager.
Conflicts in respect of safety of vulnerable adults will be taken forward by John Emmett
Designated Senior Manager via the local authority and Adult Care Directorate.
14. Communicating and reviewing the policy
EM Skills will make students aware of the Safeguarding Policy through:
a statement about safeguarding arrangements being displayed on our website
We also have a Complaints Policy which outlines how clients can make complaint about the
This policy will be reviewed by EM Skills Directorate annually and when there are changes in
There are some examples below of issues that would come under safeguarding, if any person feels worried or needs support they should contact us immediately:
- Physical abuse
- Domestic abuse
- Sexual abuse
- Emotional abuse
- Forced marriage
- Bullying – including online/cyber bullying
- Faith abuse
- Drug and alcohol abuse
- Gangs and youth violence