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 convictions. 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 recognizes the right of every individual to stay safe. EM Skills comes into contact with children and / or vulnerable adults through the following activities:
- 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:
- Working Together to Safeguard Children 2010
- Counter Terrorism and Security Act 2015
- The Children Act 1989
- The Adoption and Children Act 2002:
- The Children act 2004
- Safeguarding Vulnerable Groups Act 2006
- Care Standards Act 2000
- Public Interest Disclosure Act 1998
- The Police Act – CRB 1997
- Mental Health Act 1983
- NHS and Community Care Act 1990
- 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 culture. It can take a number of forms, including the following:
- Physical abuse
- Sexual abuse
- Emotional abuse
- 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 Preventstrategy 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 Child).
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
- Is homeless
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 effectively implemented
- 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 influences.
We will provide appropriate training for staff involved in the implementation of this duty. Such training is now widely available.
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 andclients
- Equal Opportunities policy– ensuring safeguarding procedures are in line with thispolicy, 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
- Staff induction
- Staff training
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-compliance procedures.
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:
- team meetings
- management meetings
- one to one meetings (formal or informal)
- participation in multi-agency safeguarding procedures and meetings in order to be involved in child/ adult protection pro
- provision of a clear and effective reporting procedure which encourages reporting ofconcerns.
- encouraging open discussion to identify and barriers to reporting so that they can be addressed.
- inclusion of safeguarding as a discussion prompt during supervision meetings/ appraisals to encourage reflection Support
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 week.
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 organisation.
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 students.
- 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- gov.org.uk/PDF/ISA%20Referral%20Guidance%20%20V2009-02.pdf
SEM 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 post
12. Managing information
Information will be gathered, recorded and stored in accordance with the following policies:
- Data Protection Policy
- Confidentiality 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
- student handbook
We also have a Complaints Policy which outlines how clients can make complaint about the service.
This policy will be reviewed by EM Skills Directorate annually and when there are changes in legislation.
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