1. Policy Statement

1.1 QA (referring to all divisions of QA Group, including QA Apprenticeships and QA Higher Education) will carry out its responsibilities under all relevant legislation, regulations and formal guidance for the protection of children and adults at risk as stated in the Education Act

1.2 QA holds as one of its highest priorities the health, safety and welfare of all children and adults at risk involved in courses or activities, which come under the responsibility of QA.

1.3 QA have a collective and individual duty to ensure that their employees fulfil their responsibilities to safeguard and promote the welfare of children and adults at risk, and to prevent child abuse and to report any abuse discovered or suspected.

1.4 QA employee recruitment procedures make specific reference to the role and responsibilities of all employees  towards upholding the principles, policy and practice  of effective safeguarding and all appointments are subject to satisfactory DBS checks, as set out in the QA Vetting and Screening policy (please go to G:\People\Policies for policy details).

1.5 QA will advise all parents/guardians/carers of learners under 18 of the existence of the QA’s Safeguarding Policy and Procedures routinely for QA Higher Education and upon request for all other business divisions. This includes the fact that this may require cases to be referred to the investigative agencies in the interests of the child or adult at risk. The process used follows QA’s Safeguarding escalation matrix models found in Appendix  C and D (depending on business division).

1.6 QA will advise children and adults at risk who are learners about the standards of behaviour and conduct they can expect from employees and volunteers and of what to do if they experience or suspect QA does this by introducing Safeguarding standards and how this is managed within the classroom via an induction.

1.7 QA will work with appropriate local agencies, and in particular the Local Authority Designated Officer (LADO) and Safeguarding Partners (SP), to ensure that children and adults at risk are safeguarded through the effective operation of QA's safeguarding procedures.

1.8 QA recognises that any child and adult at risk can be subject to abuse and all allegations of abuse will be taken seriously and treated in accordance with QA's This can be found under section 7 of this document.

1.9 QA recognises that it is the responsibility of all employees to act upon any concern no matter how small or trivial it may seem.

1.10 QA recognises its responsibility to implement, maintain and annually review the procedures that are designed to prevent or notify suspected abuse.

1.11 QA requires all employees to follow the Code of Behaviour on Children and Adults at Risk Protection, which is appended to this policy document, and will draw the attention of employees to this code of conduct and procedures in induction and relevant training.

1.12 QA will have appropriate policies and procedures in place that aim to prevent bullying and harassment.

1.13 QA is committed to supporting, resourcing and training those who work with, or who come into contact with, children and adults at risk and to providing appropriate supervision.

1.14 QA will ensure that any contracted or partner provider used by us in the delivery of services to learners have appropriate safeguarding, child protection and health and safety policies in place where relevant.

1.15 QA will prepare and implement an action plan to ensure that it fulfils its duties to protect children and adults at risk.

1.16 QA takes a Safer Recruitment approach to the on boarding of This is carried out by complying with the recognised set principals and procedures.

1.17 QA’s Whistleblowing policy (please go to G:\People\Policies for policy details).defines the approach to help maintain the accountability, integrity and transparency towards safeguarding all learners.

2. Scope

2.1 This policy deals with the protection of children and adults at risk. Children are those under 18 years of age and will include those on courses and programmes aged 16-18. In addition it includes disclosures regarding any under 18 year old e,g. younger siblings or child of a student. Due to the governments funding rules for 16 – 19 this may mean that those who are 18 and above are likely to be responded to in the same way. Beneficiaries are those who are on Apprenticeship, Traineeship or Degree Apprenticeship courses. An adult at risk may be a student or family member of a student, aged 18 years or All employees must read this Policy along with part one of DfES Keeping Children Safe in Education September 2018 to comply with safeguarding obligations. Key employees and leaders should also be familiar with Working together to safeguard children July 2018 and ‘No Secrets’ Government Guidance.

3. Key Principles - Statutory Framework

3.1 The Children Act 1989 provides the legal framework for the protection of children in the UK. Under the Children Act a child is defined as any person under 18 years of age.

3.2 The Care Act 2014 provides the legal framework for the protection of adults at risk in the UK. An adult at risk is any person who is aged 18 years or over and at risk of abuse or neglect because of their needs for care and or support.

3.3 The Protection of Children Act 1999 requires employers to carry out criminal checks with Disclosure and Barring Service before employees are allowed to come into contact (in line with the regulated activity guidelines) with children and adults at QA is required under this legislation to apply for an enhanced disclosure from the Disclosure and Barring Service for employees working with such learners. Further information relating to this can be found in QA Vetting and Screening Policy.

3.4 Working Together to Safeguard Children July (2018) is a Government Guidance document which sets out how all agencies and professionals should work together to promote children and adults at risk welfare and protect them from abuse and neglect, and requires QA to follow the procedures for protecting children from The guidance makes clear that QA are also expected to ensure that they have appropriate procedures in place for responding to situations in which they believe that a learner/student has been abused or is at risk of abuse – these procedures should cover circumstances in which an employee is accused or suspected of abuse.

3.5 DfES Keeping Children Safe in Education September 2018 derives from the Education Act 2002 and places the following responsibilities in Safeguarding and promoting the welfare of children:

  • Employees should be alert to signs of abuse and know to whom they should report any concerns or
  • A Designated Safeguarding Lead (DSL) should have responsibility for co- coordinating action within QA and for liaising with other agencies.
  • Employees with designated responsibility for children  and adults at risk’s protection, should receive appropriate training.
  • Educational Organisations should be aware of and follow the procedures established by the SP’s and, where appropriate, by the Local Education Authority or Children’s Social Care (England)/Social Services Department (Scotland).
  • Educational Organisations should have procedures, of which all employees are aware, for handling suspected cases of abuse of children, including procedures to be followed if an employee is accused of Section 175 of the Education Act 2002 requires providers to safeguard and promote the welfare of children and adults at risk. QA will follow any guidance issued on this section of the Act. QA will keep its policy and procedures on safeguarding under review to take account of any new Government legislation, regulations or best practice documents to ensure that employees are kept fully up to date with their responsibilities and duties with regard to the safety and well-being of children and adults at risk.

3.6 Safeguarding Partners bring together all services for children and young people in a local area to focus on improving outcomes for all children and young The aims of the Safeguarding partners is to make arrangements to identify and review serious child safeguarding cases which, in their view, raise issues of importance in relation to their area. They must commission and oversee the review of those cases, where they consider it appropriate for a review to be undertaken.

A safeguarding partner in relation to a local authority area in England is defined under the Children Act 2004 (as amended by the Children and Social Work Act, 2017) as:

  • the local authority
  • a clinical commissioning group for an area any part of which falls within the local authority area
  • the chief officer of police for an area any part of which falls within the local authority area

3.8 Prevent - Section 26 of the Counter-Terrorism and Security Act 2015 the Act places a duty on certain bodies, in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. Further information on Prevent can be found in Appendix B at the end of this document.

The Prevent strategy, published by the Government in  2011, is  part of the overall counterterrorism 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”.

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.
  • Work with sectors and institutions where there are risks of radicalisation that we need to address.

3.9 The Children and Social Work Act 2017 (the Act) is intended to improve support for looked after children and care leavers, promote the welfare and safeguarding of children, and make provisions about the regulation of social workers.

Local authorities have on-going responsibilities to the young people who cease to be looked after and become care leavers. That includes  keeping in  touch with them, preparing an assessment of their  needs  and appointing a personal adviser who develops  a pathway plan with the young person. This plan describes how the local authority will support the care leaver to participate in education or training. Designated safeguarding leads should therefore have details of the local authority Personal Advisor appointed to guide and support the care leaver, and should liaise with them as necessary regarding any issues of concern affecting the care leaver.

3.10 Children missing education September Children missing from education are children of compulsory school age, who are not registered pupils at a school and are not receiving suitable education otherwise than at school. All local authorities should have in place arrangements for information sharing and joint working. In the guidance it  states the responsibility of the local authority to work with other agencies to provide a safe and stable upbringing for the learner. QA will report on any absences through the established channels.

4. Monitoring and Review

4.1 This policy will be monitored through update reports presented to QA’s Senior Management Team and will be formally reviewed annually.

5. Safeguarding Procedures

These procedures should be read in conjunction with the Department for Education and Skills document 'What to do if you're worried a child is being abused' March 2015.

5.1 Purpose

The purpose of these guidelines is to ensure that the rights of children and adults at risk are protected through employee awareness of the issues. This includes, the following of the statutory and local guidelines in the reporting of concerns. It is the responsibility of all employees working within QA to record and report Child Protection concerns, i.e. where they believe a child or an adult has been or is at risk of abuse, neglect or significant  harm. This responsibility extends to all employees and not just those specifically working with under 18s.

5.2 Definition of terms

The Safeguarding Policy describes the support and protection procedures for all learners as well as those of specified groups such as a child or adult learners over this age, who may be “at risk” of abuse.

5.2.1 The definition of a “child”

“Child” is defined as all young people under the age of 18, or in the case of those with learning difficulties under 25 years, in accordance with the 1989 Children Act.

5.2.2 The definition of an “Adult at Risk”

“Adult at Risk” is defined as, “a person who is, or may be in need of community  care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”.

5.3 Categories of Abuse

Children can be potentially abused within the family, community, and in QA by employees (including those employed to promote their welfare and protect them from abuse), volunteers, visitors, and fellow learners. The following are broad categories of abuse.

  • Physical Abuse: may involve hitting, shaking, throwing, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child and adult at risk. Physical harm may also be caused when an employer, parent or carer feigns the symptoms of, or deliberately causes ill health to a child or adult at risk who they are looking This is commonly described using terms such as 'fictitious illness by proxy 'or 'Munchausen’s syndrome by proxy'.
  • Female genital mutilation (FGM) is the partial or total removal of external female genitalia for non-medical reasons. It is also known as female circumcision, cutting or sunna. Religious, social or cultural reasons are sometimes given for FGM. 
  • Emotional Abuse: is the persistent emotional ill-treatment of a child or adult at risk such as to cause severe and persistent effects on the child or adult’s emotional development. It may involve conveying to children or adults at risk that they are worthless and unloved, inadequate, or valued only so far as they meet the needs of another person. It may involve age or developmentally inappropriate expectations being imposed in children and adults at risk. It may involve causing children or adults at risk frequently to feel frightened or in  danger, or the exploitation or corruption of children or adults at risk. Some level of emotional abuse is involved in all types of ill-treatment of a child or adult, though it may occur alone. Cyberbullying is the bullying of individuals on line  through various outlets of modern technology. This can include isolating or ignoring someone, verbal abuse, gossiping, threatening or humiliating behaviour. 
  • Sexual Abuse: involves forcing or enticing a child or adult at risk to take part in sexual activities, whether or not the child or adult at risk is aware of what is The activities may involve physical contact, including penetrative (e.g. rape) or non-penetrative acts. They may include non-contact activities, such as involving children or adults at risk in looking at, or in the production of, pornographic materials or watching sexual activities, or encouraging children or adults at risk to behave in sexually inappropriate ways. Children in exploitative situations and relationships may receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual activities on them. Children or adults at risk may be tricked into believing they are in a loving, consensual relationship. They might be invited to parties and given drugs and alcohol. They may also be groomed online.
  • Neglect: is the persistent failure to meet the child or adult’s basic physical and/ or psychological needs, likely to result in the serious impairment of the child or adult’s health or It may involve a parent or carer failing to provide adequate food, shelter and clothing, failure to protect a child or adult at risk from physical harm or danger, or failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child or adult’s basic emotional needs.
  • Significant Harm: Some children or adults at risk may be in need because they are suffering or likely to suffer significant The Children Act part V section 47 (1) introduced the concept of significant harm as the threshold that justifies compulsory intervention in family life in the best interest of the children.
  • Financial Abuse: Some children and adults at risk may be abused or exploited financially including fraud and extortion.
  • County lines: Some children and/or Adults at risk are succeptible to the gang influence that is county This tends to happen when urban drug dealers make contact out of typical city areas, and convince mainly young people to sell the drugs to the local users, often forming a base location where the recruit is forced to stay. This allows the senior drug dealers to maintain income without often having travelled to the area where their drugs are being sold. In this situation the manipulated individual takes all the risk, whilst the dealer is unlikely  to be caught or charged with their offence. Whilst someone is in this situation there is  always the risk of violence to stay put from associated gang members.
  • Honour Based Violence: Can involve many different things, but is when violence is committed against someone in the name of ‘honour’. This takes place when usually a woman (however not exclusive to) is hurt because of behaviour which is seen to be immoral by her Often these family members believe it has bought shame upon them.
  • Honour Based Violence might include; making threats, assaults, rapes or sexual assault, Kidnappings or abductions, Forced abortions or Imprisoning someone.
  • Peer to Peer: Allegations against learners should be reported as stated in part 7 in this document (Advice to Employees on When to Take Action & How) If harmful sexual behaviour is alleged to have occurred, the DSL will have regard to Part 5 KCSIE and take into account the local response of the police and children's social care to these issues. The views of the alleged victim will be taken into account but will not be determinative. All those involved in such allegations will be treated as being at risk and in need of support in accordance with this Policy.
  • Sexual Violence and Harrassment: Sexual violence and sexual harassment can occur between two children of any age and It can also occur  through  a group of children sexually  assaulting or sexually  harassing a single child  or group of children.

Children who are victims of sexual violence and sexual harassment will likely find  the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Staff should be aware that some groups are potentially more at risk. Evidence shows girls, children with SEND and LGBT children are at greater risk.

Staff should be aware of the importance of:

  • making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up;
  • not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”; and
  • challenging behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them.

Any staff who observe any of the afore mentioned behaviour need to report immediately and follow the above procedure at the time, which is to challenge at the time of the incident.

  • Child Trafficking is the act where children find themselves in situations where they are forcibly required to move and/or live in settings which they have no control over. Normally children are trafficked for reason such as; sexual exploitation, slavery or financial gain.

In addition to the categories detailed above the following categories  also apply  to adults at risk

  • Psychological abuse, including emotional abuse, radicalisation, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation, or withdrawal from services or support networks.
  • Financial or material abuse, including theft, fraud, exploitation, pressure in connection with inheritance, property or financial transactions, or the misappropriation of property, possessions or benefits.
  • Neglect and acts of omission, including ignoring medical or physical care needs, failure to provide access to appropriate health, social care or education services, the withholding of the necessities of life, such as medication, adequate nutrition or heating.
  • Discriminatory abuse, including racism or sexism, abuse based on a person’s disability, faith, sexual orientation and other forms of harassment, slurs, or similar treatments.
  • Institutional abuse occurs when the routines, systems and regimes of an institution results in poor and inadequate standards of care and poor practice which affects the whole setting and denies, restricts or curtails dignity, privacy, choice, independence or fulfilment of adults at risk. Institutional abuse can occur in any setting providing health and social care.

6. Designated safeguarding lead (DSL)

6.1 All schools, organisations and providers are required to have a designated employee, who is assigned to act upon child and adults at risk protection concerns.

6.2 At QA this person is called the Designated Safeguarding Lead (DSL) for safeguarding and he or she is responsible for coordinating action within QA and liaising with other  The QA contacts for safeguarding are listed in appendix C and D (depending on business division).

6.3 The DSL for safeguarding is required to know:

  • How to identify the signs and symptoms of abuse and when to make a referral
  • The local child and adult at risk protection procedures and the DSL’s role within them
  • The role and responsibilities of the investigating agencies and how to liaise with them
  • The requirements of record keeping
  • The conduct of a child protection conference* and how the DSL or other employees can make an appropriate contribution to it.

*The local authority will call a child protection conference when they have investigated concerns about child abuse and they believe the child is suffering, or likely to suffer, significant harm.

7.Advice to Employees on When to Take Action & How

7.1 Once you suspect or know of any abuse of any child or adult at risk, you should immediately inform the DSL relevant within your division, in person or by Even if you have only heard rumours of abuse, or you have a suspicion but do not have firm evidence, you should still contact the DSL to discuss your concerns. It is important to understand that your responsibilities extend to suspicion of abuse in any area of the child or adult’s life,  not just in the QA learning environment.

7.2 You must also contact the DSL if you know or suspect that an employee or student has a previous history of abuse of children and/or adults at risk. If you become aware of any allegations against an employee this must always be escalated to the DSL.

7.3 If the DSL is not immediately available you should then contact the People Team You must not try to investigate the matter on your own. Employees are not quipped nor qualified to do so.

7.4 If, following your initial contact with the DSL, it is decided that the matter should be taken further, a written report must be A written report is essential to prevent any misrepresentation of your findings, and should be sent to the DSL within 24 hours of the suspicion arising. The report should be factual and should not include opinions or personal interpretations of the facts presented. The report should contain as much detail as possible, including any apparent physical signs of abuse or other circumstances which led to your suspicions, or the account given to you of abuse by the child or adult concerned, as accurately as you are able to record it. The report should be signed, dated and a copy stored in a secure place. If you are unsure about what to write, you can get advice from the DSL.

7.5 If a child or adult at risk comes to you with a report of apparent abuse, you should listen carefully to the child or adult, using the following When listening to a child or adult, employees must:

  • allow the child or adult at risk to speak without interruption
  • never trivialise or exaggerate the issue
  • never make suggestions
  • never coach or lead the child or adult at risk in any way
  • reassure the child or adult at risk, let them know you are glad they have spoken up and that they are right to do so
  • always ask enough questions to clarify your understanding, do not probe or interrogate – no matter how well you know the child or adult at risk – spare them having to repeat themselves over and over
  • be honest – let the child or adult at risk know that you cannot keep this a secret; you will need to tell someone else
  • try to remain calm – remember this is not an easy thing for them to do
  • not show your emotions – if you show anger, disgust or disbelief, they may stop talking.  This may be because they feel they are upsetting you or they may feel your negative feelings are directed towards them
  • let the child or adult know that you are taking the matter very seriously
  • make the child or adult feel secure and safe without causing them any further anxiety

7.6 At the earliest opportunity involve the DSL.

The DSL will be responsible for liaising with external agencies and recording essential information about each case and for collecting reports and notes as appropriate.

Any detailed information about a case will be confined to the DSL (if not involved in the allegations), Managing Director/Executive responsible for the business area/function and any external agencies, the DSL determines to engage. The Manager(s) and employees reporting the allegations will be kept informed of the progress of the case on a 'need to know' basis.

8. What Happens Next?

8.1 Taking into account all the information available, the DSL will decide on the next steps, which may include taking no further In most cases the DSL will seek advice from the Local Authority Designated Officer (LADO) and agree what further action is necessary, which may include:

  • Seek further advice from the Safeguarding Partners
  • Undertake further investigation under the direction of the LADO or support an investigation by the Safeguarding Partners
  • Make a referral to the appropriate agency, as as signposted.
  • Report the incident to a designated Social Worker, as signposted.
  • Report the matter to the police if a crime is suspected.

8.2 If a referral is made, this must be confirmed in writing to the appropriate agency within 24 hours.

8.3 The DSL may consider that those involved may require counselling. Where it is felt there is a need for counselling (which could be for the children, adults at risk, other learners, employees, parents or carers involved) the DSL will make the necessary arrangements.

9. Confidentiality & Information Sharing

9.1 Confidentiality and trust should be maintained as far as possible, but employees must act on the basis that the safety of the child or adult is the overriding The degree of confidentiality will be governed by the need to protect thechild or adult. The child or adult should be informed at the earliest possible stage of their disclosure that this will then be escalated onto the appropriate agencies. All conversation regarding a child or adult should always be held in private. QA complies with the requirements of the Data Protection Act 2018, which allows for disclosure of personal data where this is necessary to protect the vital interests of a child or adult.

9.2 Employees must not discuss the case with anyone other than those involved in the If employees have any concerns about the progress of the case or have any other concerns these must be discussed with the DSL.

10. Allegations Against Employees

10.1 The primary concern of the organisation is to ensure the safety of the child or adult. It is essential in all cases of suspected abuse by an employee that action is taken quickly and professionally whatever the validity. There are occasions where a child or adult will accuse an employee of physically or sexually abusing them. In some cases, this may be false or However, in some cases the allegations may be true.

10.2 Any instance of a child or adult being abused by an employee is particularly On the other hand, for an innocent person to be accused of such an act is a serious ordeal which can result in long term damage to their health and career. In the event that any employee suspects any other employee of abusing a learner/student, it is their responsibility to bring these concerns to the Managing Director/Executive responsible for the business area/function, the People Team and the DSL.

10.3 On being notified of any such matter the DSL shall:

  • Seek and follow advice from the LADO.
  • Take such steps as he/she considers necessary to ensure the safety of the child or adult in question and any other child or adult who might be at risk.
  • Ensure that a report of the matter is completed by the person who reported the original concern.
  • Put in place the steps necessary to follow the advice of the LADO.

10.4 Additional to point 3, at the early point of the investigation the DSL or DSO’s will investigate the concern with the learner, child or an appropriate adult gathering the appropriate evidence. All learner discussions will be carried out by staff who sit with the recognised safeguarding team within the respective QA divisions. Interviewing of staff regarding an investigation will always be carried out by QA’s HR team by those who are recognised as DSL’s in the event where point 10.3 needs to be observed. The names of all DSL’s or DSO’s can be found in the below Escalation Matrix (page 22). All face to face interviews, including arranging, liaising with Line Managers and lastly the management of referrals, will be carried out by The People Team in cases described in this section.

10.5 If the allegation concerns the DSL, the matter should be discussed with the DSL’s line manager with the Deputy DSL managing the learner This is in addition to following the above stated safeguarding procedures outlined in this section of the document.

APPENDIX A: Safeguarding code of behaviour for QA employees

QA recognises that it is not practical to provide definitive instructions that would apply to all situations at all times whereby employees come into contact with children and adults at risk, or to guarantee the safeguarding and protection of children and adults at risk and employees.

However, below are the standards of behaviour required of employees  in  order  to fulfil  their roles and duty of care within the organisation. This code should assist in the safeguarding and promotion of the welfare of children and adults at risk and in the protection of both children and adults at risk and employees.

These guidelines also apply to volunteers who work in an unpaid capacity in QA premises.

Employees must:

Implement the Safeguarding Policy and Procedures at all times, including acting to promote children and adults at risk’s welfare, prevent abuse and report any abuse discovered or suspected.

Employees must never:

  • Engage in rough, physical games including horseplay with children or adults at risk.
  • Allow or engage in inappropriate touching of any The main principles of touch are:
    • Touch should always be in response to the child or adult’s need – for example to administer first aid.
    • You should not touch a learner/student (of any age) in response to an emotional need – such as hugging, placing an arm around Instead use empathetic language/ facial expressions and offer tissues.
    • Touch should always be appropriate to the age and stage of development of the child or adults.
  • Touch should always be with a child or adult’s permission.
  • Do things of a personal nature for a child or adult that they can do for themselves or that their parent can do for them.
  • Physically restrain a child or adult unless the restraint is to prevent physical injury of the child or adult/other children/visitors or employees/yourself. In all circumstances physical restraint must be appropriate and reasonable; otherwise the action can be defined as assault.
  • Make sexually suggestive comments to or within earshot of a child or adult.
  • Have children or adults at risk on their own in a Where circumstances require the transportation of children or adults at risk in their vehicle,  another member of employees/volunteer must travel in the vehicle. Also it is essential that there is adequate insurance for the vehicle to cover transporting children or adults at risk as part of the business of your work. In extreme emergencies (for medical purposes) where it is required to transport a child or adult on their own, it is essential that another leader and the parent is notified immediately.
  • Take a child or adult to the toilet unless another adult is present or has been made aware (this may include a parent or QA employee).
  • Where there is shared use of toilet facilities all male QA employees should use the cubicles rather than urinals.
  • Spend time alone with a child or adult on his/her own outside of the normal tutorial/ classroom If you find you are in a situation where you are alone with a child or adult, make sure that you can be clearly observed by others.
  • Engage in a personal relationship with a child or adult who is a learner/student, beyond that appropriate for a normal teacher/ student relationship.
  • Give their personal contact details (personal mobile telephone number/home telephone number or personal email address) to a child or adult.

Employee Guidance on the Use of Social Networking

  • Interaction with learners through a social networking site should be avoided unless this has been agreed by the Managing Director/Executive responsible for the business area/function as part of a marketing role or for managing collaborative learning.
    • Collaborative learning must be done by setting up an “invitation only” business/professional group discussion group for the course with appropriate privacy settings where the content can be monitored.
  • Employees should only contact learners and parents using the Company’s mail, SMS, telephone and e-mail/intranet systems.
  • Employees can make a judgment on whether to accept an invitation to connect on social media from a former learner/student, however, no employee should instigate or make extra efforts to connect with these individuals.
  • Acceptable reasons for connecting with former learners would be for  business or professional networking purposes.

It is unacceptable for employees to:

  • allow learners to access their personal social networking spaces; privacy settings should be set to ensure that access is restricted to friends only.
  • add learners as ‘friends’ to their personal social networking space.
  • access as a ‘friend’ on the individual social networking sites of learners/student.
  • post comments, photographs critical of QA on any forum, website, social networking site, blog etc.
  • post comments critical of any other employees or learner/student on any forum, web-site, social networking site, blog
  • post comments that run counter to the QA’s Equality and Diversity Policy.
  • post comments that recommend, or appear to endorse, law-breaking of any kind.
  • post comments that exhibit grossly irresponsible behaviour, or appear to endorse irresponsible behaviour, that could be argued to encourage “copycat” behaviour by This would include, for example, dangerous driving or alcohol abuse.
  • incite violence and hatred based on ethnic, racial or religious grounds.

Implications for employees

Employees who breach any of the above may be subject to the disciplinary procedure. If an allegation against an employee has occurred, then an investigation will be carried out.

QA reserves the right to suspend any employee under the Safeguarding Policy to protect children and adults at risk whilst an internal and/or external investigation takes place. The organisation can implement its own internal investigation during any stage of this process. This may result in disciplinary action being taken against an employee.

Suspension of employees under the Safeguarding Procedure.

Should QA decide to suspend the employee because of a safeguarding concern the company disciplinary policy will be utilised.

APPENDIX B: Radicalisation and Extremism

QA recognises the positive contribution it can make towards protecting its learners from radicalisation to violent extremism and is committed to fulfilling its duties under the Prevent Duty Guidance *(please see points 3.7 and 3.8). QA will empower its learners to create communities that are resilient to extremism and to protect the wellbeing of particular learners who may be at risk to being drawn into violent extremism or crime.

Radicalisation is the process by which individuals come to support terrorism or violent extremism. It is recognised that radicalisation can occur to an individual from any section of society and is not particular to any racial, ethnic or social group. It is further recognised that in many instances the process of radicalisation is essentially one of grooming by others.

Possible behaviour indicators are below:

  • Discriminatory language or actions towards specific groups or people with a particular protected characteristic
  • Possession or sharing of violent extremist literature
  • Showing or sharing online material of an extreme nature to others
  • Behavioural changes (for example, becoming withdrawn)
  • Expression of extremist views
  • Advocating violent actions and means
  • Association with known extremists
  • Seeking to recruit others to an extremist ideology

In respect of safeguarding individuals from radicalisation, QA works to the Prevent element  of the Government’s Counter Terrorism Strategy, and where deemed appropriate seeks external support for learners through referrals to the Channel Programme.  This programme aims to work with the individual to address their specific vulnerabilities, prevent them becoming further radicalised and possibly entering the criminal justice system because of their actions. More information can be found within the Channel Duty Guidance document available at https://www.gov.uk/government/publications/channel-guidance

If you have concerns about a learner, contact the relevant Designated Safeguarding Lead.

APPENDIX C: SAFEGUARDING ESCALATION MATRIX for QAA

Risk Level

Responsible

Accountable

Consult (as required)

Immediately Inform Always

Inform Post Case Analysis

1

Negligible risk

Employee

Employee

DSO / DSL

SGI

 

2

Low impact / risk

DSO

DSO / DSL

HLS / DSL

HLS / SGI

 

3

Medium impact / risk

DSO / DSL

DSO / DSL

HLS / LA

HLS/ QD / SGI

HLS / QD / Q

4

High impact / risk

DSO / DSL

HLS

HLS / LA

HLS / QD / SGI / AOBD

HLS / QD / AOBD / Q

5

Very high impact

/ risk

DSO / DSL

HLS

HLS / LA / 999

HLS / QD /

SGI / AOBD / ST

HLS / QD /

AOBD / Q / ST

 

Role/Area

Description or named persons

DSO

Designated safeguarding officer

Katie Colborn, Stephen Smith, Clare Stuart, Declan Smith

DSL

Designated safeguarding lead

Stephen Smith 01753 898 740. Deputy - Katie Colborn

DSL

Designated safeguarding leads for employees

Priya Karda, Kiran Bhachu

HLS

Head of Learner Services

Katie Colborn

SGI

Safeguarding Inbox

safeguarding@qa.com

QD

Delivery Director

Gerwyn House

LA

Local Authority

Local authority or relevant other local partner

AOBD

Area of Business Director

Chris Neale, Paul O’Hagan, Ben Pike, Sara Roberts, Mary Sansom, James Swaffield, Ben Sweetman, Jamie Thomas, Jonathan Warner

Q

Quality Team

All quality team members

999

Emergency services

 

ST

Strategic Team

Senior Management Team

APPENDIX D: SAFEGUARDING ESCALATION MATRIX for QAHE

Risk Level

Responsible

Accountable

Consult

(as required)

Immediately

Inform Always

Inform

Post Case Analysis

1

Negligible risk

Employee

Employee

DSO / DSL

WT

 

2

Low impact

/ risk

DSO

DSO / DSL

/ DSL

WT

 

3

Medium impact / risk

DSO / DSL

DSO / DSL

DSL/ LA

DSL

OD

4

High impact

/ risk

DSO / DSL

DSL

DSL / LA

WT / DSL

OD

5

Very high impact / risk

DSO / DSL

DSL

DSL / LA

/ 999

DSL

OD

 

Role/Area

Description or named persons

DSO

Designated safeguarding officer

Heather Page, Amy Luxford, Simon Pateman, Marisa

Silva

DSL

Designated safeguarding lead

Lorraine Walsh

DSL

Designated safeguarding leads for employees

Priya Karda, Kiran Bhachu

WT

Welfare team

Referrals to be hand delivered

OD

Operations Director

Mike Goodwin

LA

Local Authority

Local authority or relevant other local partner

999

Emergency services