Contents

1. The purpose and scope of this policy

The definition of safeguarding and promoting the welfare of children, as set out in Working together to safeguard children 2023 is:

• Providing help and support to meet the needs of children as soon as problems emerge

• Protecting children from maltreatment, whether that is within or outside the home, including online

• Preventing impairment of children’s mental and physical health or development

• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care

• Promoting the upbringing of children with their birth parents, or otherwise their family network4 through a kinship care arrangement, whenever possible and where this is in the best interests of the children

• Taking action to enable all children to have the best outcomes in line with the outcomes set out in the Children’s Social Care National Framework5.

Child protection is part of safeguarding and promoting the welfare of children and is defined for the purpose of this guidance as activity that is undertaken to protect specific children who are suspected to be suffering, or likely to suffer, significant harm. This includes harm that occurs inside or outside the home, including online.

Effective safeguarding means practitioners should understand and be sensitive to factors, including economic and social circumstances and ethnicity, which can impact children and families’ lives.

Targeted Provision takes a child-centred approach to safeguarding and promoting the welfare of every child and young person. This approach means keeping the child in focus when making decisions about their lives and working in partnership with them and their families.

Children and young people may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their day-to-day lives. We are aware of indicators of abuse and neglect, and understand that children can be at risk of harm inside and outside of school, inside and outside of home and online.

These threats can take a variety of different forms, including sexual, physical and emotional abuse; neglect; exploitation by criminal gangs and organised crime groups; trafficking; online abuse; sexual exploitation and the influences of extremism leading to radicalisation.

We are aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful. We know children may feel embarrassed, humiliated, or being threatened. This could be due to their vulnerability, disability and/or sexual orientation or language barriers. This does not prevent our staff from having a professional curiosity and speaking to the Designated Safeguarding Lead if they have concerns about a child. Our staff determine how best to build trusted relationships with children and young people in our school that helps facilitate communication.

We also acknowledge the negative experiences and distressing life events associated to Covid 19 and this can still affect the mental health of children and young people and their parents, we are well prepared to offer the right help at the right time.

Whatever the form of abuse, neglect or exploitation, Targeted Provision will always put the needs of children and young people first when determining what action to take.

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.

2. Why we demand strict safeguarding

Anyone working for or on behalf of Targeted Provision will demonstrate relevant Safeguarding Training to Level 2 as a minimum. We provide fully or partially subsidised certified Level 2 Safeguarding CPD to any employee, tutor or mentor.

Where requested, tutors and mentors will carry out specific Safeguarding Children Board training requirements within the time period defined for completion.

Targeted Provision works with children, families, schools, tutors and Local Authorities as part of its activities. These activities include:

• The provision of workers and volunteers to family homes, schools, care homes or other public venues to provide 1:1 bespoke tuition for children and young people in mainstream education and those who are in receipt of alternative provisions.

• The provision of workers and volunteers to provide Special Education Needs & Disability (SEND) provision for children and young people as well as Looked After Children (LAC) and Children In Need (CIN). These children and young people may or may not have a statutory Education, Health and Care Plan (EHC plan).

• The provision of part-time tuition to fulfil statutory education requirements for children and young people in need of Alternative Provision. This may include work with young people who are temporarily or permanently excluded from their mainstream setting.

• Online tutoring between workers or volunteers and children or young people, usually in their family home.

• Communication between our full-time employees, workers and volunteers to families across the UK.

• Working with partners, including Schools, Local Authorities, Children’s Homes, PRUs and other organisations responsible for a child or young person’s education.

The purpose of strict safeguarding is:

• to equally protect children and young people who receive a service via Targeted Provision’s various platforms or employees. This includes all children at risk or otherwise and the children of adults who use our services.

• to provide parents, staff and volunteers with the overarching principles that guide our approach to Safeguarding and Child Protection.

This policy mandatorily applies to anyone working for or on behalf of Targeted Provision, including senior managers and the board, paid staff, volunteers, sessional workers, agency staff and students.

3. Legislative and non-statutory guidance

Being a private educational provider (Non-school alternative provision), in line with HM Government’s December 2023 publication - Working Together to Safeguard Children (WTSC) - Targeted Provision has organisational responsibility under both “Schools, Colleges and other educational providers” and “Voluntary, charity, social enterprise, faith-based organisations and private sectors”

Key areas from the report are highlighted herein, which address our organisational responsibilities:

As an educational provider we are bound by the WTSC guidance which applies [where applicable] to our provision. We also have regard to statutory guidance ‘Keeping children safe in education 2025’, which provides further guidance as to how we should fulfil our duties in respect of safeguarding and promoting the welfare of children in our care.

We also recognise our position in the voluntary, charity, social enterprise (VCSE) and private sector and acknowledge our role in safeguarding children and young people through the services we deliver. 

As part of our work, we provide a wide range of educational activities for children and young people and therefore have an important role in safeguarding children and young people and supporting families and communities that are beneficiaries of our services either directly or indirectly. “Every VCSE, faith-based organisation and private sector organisation or agency should have policies in place to safeguard and protect children and young people from harm. These should be followed, and systems should be in place to ensure compliance in this. Individual practitioners, whether paid or volunteer, should be aware of their responsibilities for safeguarding and protecting children and young people from harm, how they should respond to child protection concerns and how to make a referral to local authority children’s social care or the police if necessary”.

We are aware of how we need to work with the safeguarding partners in a local area, namely schools and Local Authorities across the UK and Channel Islands. This means if the safeguarding partners name Targeted Provision as a relevant partner we must cooperate in line with the relevant partner’s safeguarding policy. 

DSLs from both Targeted Provision and the relevant partner’s DSL should make contact at the first possible opportunity to establish that Safeguarding Policies are in agreement and courses of action for Safeguarding procedures are known.

As we work closely with Local Authorities, we understand that they are guided by the Children Act 1989. This Act requires local authorities to give due regard to a child or young person’s wishes when determining what services to provide under section 17 and before making decisions about action to be taken to protect individual children under section 47. These duties complement requirements relating to the wishes and feelings of children or young persons who are, or may be, looked-after (section 22(4)), including those who are provided with accommodation under section 20 and children taken into police protection (section 46(3)(d)).

In addition to their statutory duties, the role of Virtual School Heads was extended in June 2021, to include a non-statutory responsibility for the strategic oversight of the educational attendance, attainment, and progress of children with a social worker. In offering advice and information to workforces that have relationships with children with social workers, virtual school heads will identify and engage with key professionals, helping them to understand the role they have in improving outcomes for children. This should include Designated Safeguarding Leads, social workers, headteachers, governors, Special Educational Needs Co-ordinators, mental health leads and other local authority officers.

Non-statutory guidance on promoting the education of children with a social worker contains further information on the roles and responsibilities of virtual school heads. Virtual School Head roles for children with a Social Worker.

What to do if you’re worried a child is being abused 2015 - Advice for practitioners is non statutory advice which helps everyone who works with children and young people to identify abuse, neglect or exploitation and take appropriate action. A copy of this guidance is sent to all employees, workers and volunteers in their induction pack after completing the steps of Safer Recruitment.

We are now also guided by the Non-school alternative provision voluntary national standards, August 2025 which place a voluntary code of conduct upon us.

We refuse to work with any partner who does not put safeguarding at the centre of their approach when providing educational provision to children and young people.

We work with a high number of schools and Local Authorities and are therefore aware of the relevant Safeguarding Children’s Board/Partnership measures and specific training requests.

4. Key contacts, roles and responsibilities

Designated Safeguarding Lead (DSL), Senior Mental Health Lead and Online Safety Officer:

Emma Stanway

emma@targetedprovision.com

 

Deputy Designated Safeguarding Lead (DDSL), PREVENT lead, FGM and OBA Spoc and Deputy Online Safety Officer:

Rachel Greathead

rachel@targetedprovision.com

 

Deputy Designated Safeguarding Lead (DDSL):

Laura Dodd

laura@targetedprovision.com

 

Deputy Designated Safeguarding Lead (DDSL)

Beth Garner

beth@targetedprovision.com

 

Safeguarding Director:

Chris Kneale-Jones

chris@targetedprovision.com

5. Role of the Designated Safeguarding Lead

Although we understand that we are not a school or college, our Designated Safeguarding Lead (DSL) follows the duties outlined in HM Government’s statutory guidance for Schools and Colleges, Keeping Children Safe in Education, September 2025. These are the strictest and most stringent Safeguarding guidelines a DSL can follow. Our DSL is trained in Safer Recruitment and DSL level 3 training and will always carry out Local Authority and/or school-specific safeguarding training, where requested.

Our DSL is expected to:

• Be appropriately trained, updating that training every 12 months

• Refer cases of suspected abuse, neglect or exploitation to the local authority children’s social care as required.

• Refer cases of suspected abuse, neglect or exploitation to the police as required.

• Support staff who make referrals to local authority children’s social care; (all tutors and staff of Targeted Provision are provided with safeguarding referral guidance on commencement with the company).

• Refers to the Channel/PMAP programme where there is a radicalisation concern as required.

• Support staff who make referrals via our Response to Concerns documentation.

• Liaises with the Deputy DSLs and other parties as and when appropriate.

• Liaise with the Headteacher (or similar) to inform them of enquiries under section 47 of the Children Act 1989 and police investigations. This includes being aware of the requirement for children to have an Appropriate Adult.

Our Deputy DSL(s) is/are expected to:

• Be appropriately trained, updating that training every 12 months

• Carry out the duties of the DSL in the absence of the DSL

If the DSL is absent for an extended period, a deputy DSL will be appointed to DSL and a new deputy DSL will be established from within the company.

 

6. Operational Framework

We recognise that:

• the welfare of the child or young person is paramount

• all children and young people, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have a right to equal protection from all types of harm or abuse, neglect or exploitation

• some children and young people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues 

• working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.

• the child should be continually involved, and have information fed back to them in a way that they can understand. There should always be evidence that their “voice” has influenced decisions that professionals have made. The child needs to be seen as an active partner who can usually add to what is being set up for them. To be able to put forward their wishes and feelings appropriate to their age and abilities.

We seek to keep children and young people safe by:

• valuing, listening to and respecting them

• having an appointed nominated child protection/safeguarding lead (DSL), a deputy child protection/safeguarding lead and a lead trustee/board member for safeguarding

• using our safeguarding procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, parents, families and carers appropriately

• creating and maintaining an anti-bullying environment, in line with our Anti-Bullying Policy, to help us deal effectively with any bullying that does arise

• Implementing effective Online Safety Policy, Filtering & monitoring processes and related procedures in line with ‘plan technology for your school’ guidance which fulfils our legal safeguarding obligation and legitimate interest to safeguard children, young people and adults. Adhering to the This includes the recording of all online lessons. (N.B. Recordings are encrypted in transit and at rest, stored securely and are only accessible for safeguarding purposes by our safeguarding team and/or Designated Safeguarding Leads)

  • We also record lessons to assess the quality of the teaching and learning. It is a legitimate interest of ours to ensure that all lessons meet our high standards.  Please note that stakeholders have the right to object to our viewing the recordings. If they would like to object, they can put their concerns in writing and send them to tutors@targetedprovision.com

  • Stakeholders can ask to “opt out” of lessons being recorded, which we will always consider, but not necessarily comply with if we believe it compromises the safeguarding of children, young people and adults involved

• Referring to the newly published Generative AI: product safety expectations to support us to use generative artificial intelligence safely, and explains how filtering and monitoring requirements apply to the use of generative AI in our setting.

• Sharing information, in line with our Confidentiality Policy, about child protection and safeguarding best practice with children, their families, staff and volunteers via half-termly newsletters, blog posts, social media and one-to-one discussions

• Recruiting staff and volunteers safely, in line with our Safer Recruitment in Education Policy, ensuring all necessary checks are made

• Providing effective management for staff and volunteers through supervision, support, training and quality assurance measures

• Implementing a Code of Conduct for staff.

• Using our Safeguarding procedures to manage any allegations against staff, volunteers or young people appropriately

• Ensuring that we have effective complaints and whistleblowing measures in place, in line with our Complaints Procedures and Whistleblowing Procedures respectively

• 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, and in line with our Health and Safety Policies

• Recording and storing information professionally and securely, in line with our Privacy Policy

• In line with our detailed Internal Risk Assessment, we gather as much information as possible about the setting in which tutoring or mentoring take place. We ensure that another adult will be present at the setting as we do not, under any circumstances, support lone working.

We seek to keep children, young people and tutors safe by insisting on no lone working at any time. The young people we support are some of the most vulnerable in society. Many require additional assistance to engage successfully in tuition or may present with medical, emotional, physical or safeguarding related needs. It is therefore our duty to always insist that, both they and our tutors, are safe and able to always access the support of an adult with loco parentis during tuition:

• Tutors must report to the primary caregiver on arrival and departure for every session, whether face to face or online.

• Tutors are expected to ensure that they are not left unsupervised with any CYP and always remain in contact with the primary caregiver or appropriate additional adult throughout tuition sessions, whether face to face or online.

• All online sessions are delivered using Zoom Education (All sessions are recorded and stored securely for safeguarding purposes) and tutors should ensure that the additional adult is available to support the CYP (and tutor where required), throughout every online session.

• The supporting adult/primary caregiver is also responsible for supporting any personal care needs of the CYP, including the administration of any medications or first aid that the CYP may require.

• The additional adult/primary care giver is also responsible for supporting the CYP should they become emotionally/physically dysregulated or leave the tuition venue or online session.

• If tutors find that there is no additional adult supporting the tuition, whether face to face or online, they must ensure the CYP is safe, end the session and contact the additional adult/primary caregiver by phone before leaving the venue or online zoom link, to explain that they cannot undertake tuition if they are not present. If the tutor is unable to contact the additional adult/primary caregiver, they should leave a message and ask them to make contact as soon as possible. The tutor should then report this to TP’s DSL as a safeguarding concern.

7. Keeping Children Safe in Education (Sep 2025) specific safeguarding issues

All staff at Targeted Provision, whether employees, workers, or volunteers have an awareness of safeguarding issues through regular training and briefings, some of which are listed below.

We enable our staff to be aware that these behaviours put children in danger. All staff are aware of the Designated Safeguarding Lead, Emma Stanway, who is the expert within our organisation and is there to support staff, volunteers and the Governance body.

Children who are absent from education (updated terminology KCSiE 25 replacing *Children missing education, CME) is defined as those who are of a compulsory school age but are either not registered at a school or else not receiving suitable education in place of a school setting. CME may be at a significant risk of not meeting their academic potential and underachieving.

Children potentially at greater risk of harm  

All children should be protected however our staff and Governing Body recognise that some groups of children are potentially at greater risk of harm than others. This list is not exhaustive but highlights some of these groups: 

• Children who need a social worker (Child in Need & Child Protection)

• Children who are absent from education

• Elective Home Education (EHE)

• Children requiring mental health support

• Looked after children and previously looked after children

• Children with special educational needs & disabilities/health issues

• Children who are lesbian, gay, bi or gender questioning(LGBTQ+) This is currently under review pending the outcome of the gender questioning children guidance consultation (DfE, 2023b).

We support these groups by having: 

• Vigilance: to have adults notice when things are troubling them

• Understanding and action: to be heard and understood; and to have that understanding acted upon.

• Stability: to be able to develop an on-going stable relationship of trust with those helping them.

• Respect: to be treated with the expectation that they are competent, rather than not.

• Information and engagement: to be informed about and involved in procedures, decisions, concerns and plans.

• Explanation: to be informed of the outcome of assessments, decisions and how they have been reached, positive or negative.

• Support: to be provided with support in their own right as well as a member of their family.

• Advocacy: to be provided with advocacy, to assist them in putting forward their views.

For any concerns which are considered emergencies by one of our employees, workers or volunteers, contacting the police may be the most appropriate primary action.

Contact details for specific SCBs/SCPs that we work with are provided as and when work is carried out for a specific local authority or school. These will include, but are not limited to:

• The LADO (Local Authority Designated Officer)

• The CSCT (Children's Social Care Team)

• The SPOC (Single point of contact)

• First Response Teams

• The referrer at the LA/school

The updated 2024 DfE Guidance clarifies that when a school places a pupil with an alternative provision provider, the school continues to be responsible for the safeguarding of that pupil.

8. Recording general concerns about a child

If you have a general safeguarding or wellbeing concern about a child, you should raise this via the “red button” on the left of the tutor portal.

You will be contacted by the TP Safeguarding team within 5-20 minutes of raising your concern. Please keep your phone with you and be ready to receive the call.

During this call the DSL will make a threshold decision and inform you of what you need to do next and what the TP SG team will do next.

You may be advised to complete and submit a Form A (Appendix 6). This should be completed in its entirety where an incident has occurred/or a specific concern has arisen that constitutes a safeguarding concern. You must complete this form in as much factual detail as possible, so the relevant parties can act appropriately.

If the incident or concern involves any visible injuries to the child, you should complete the interactive body map attached to the Form A.

If you have digital evidence (for example a photograph of concerning writing or drawings completed by a young person), you should upload these to the Form A.

The form should then be submitted directly to the DSL or Deputy DSL. On completion of the digital form, all DSLs/DDSL’s will be notified immediately.

The DSL will act accordingly and will document all actions taken, including actions sought, outcomes and which parties were informed/became involved. The DSL will also keep a case chronology of any events recorded on Form A. All information in relation to safeguarding concerns is stored securely on our designated safeguarding database.

If you are delivering tuition within a school or children’s home you should always contact the school/home’s DSL initially to record your concern with them, then follow the above procedure and report to us via the red button alert. Please ensure you report to the School DSL/DDSL in person.

9. Safeguarding emergencies (Service users – parents/carers/CYP and staff and tutors)

Access to all our policies and procedures is made available to our service users at the start of each referral.

It is made clear to parents/carers via the consent form they must sign before a referral can commence regarding what to do if they have any concerns about the tutor or any other adults or peers their young people come into contact with.

It is made clear to students during the very first session regarding what to do if they have any concerns about their tutor or any other adults or peers they work with.

We provide our tutors with guidance about how to deliver their first session and the content of the advice.

Dealing rapidly and effectively with Safeguarding and Child Protection Emergencies are Targeted Provision’s number one priority with respect to Safeguarding Procedures.

Definitions of what constitutes abuse can be found in Appendix 3 – Definitions of Abuse, and also in GOV.UK publications Working Together to Safeguard Children 2023, and Keeping Children Safe in Education, Statutory guidance for schools and colleges September 2025.

A safeguarding emergency may manifest itself as, but is not limited to:

• Severe illness or injury which may be attributable to physical or sexual abuse, or self-harm

• A fearful child or young person’s refusal to engage with their family or go home at the end of day

• Suspicion or disclosure of serious abuse becoming apparent during a tutoring session, school outing or residential trip

• A risk of trafficking or abduction when the child or young person absences their home or school premises

• A risk of the child or young person being abused through sexual exploitation

• A child or young person who is incapacitated through substance misuse

• A missing child or young person with known vulnerabilities

• Credible immediate risk with regard to FGM or Forced Marriage

In some instances, an allegation made against a member of staff can necessitate immediate action to safeguard pupils (see Allegations of abuse are made against an adult below)

The core actions when responding to a safeguarding emergency:

• Stay calm and act quickly, but rationally.

• Call the police as soon as it is safe to do so if appropriate, then contact the TP DSL via the “red button” on the tutor portal.

• You will be contacted by the TP Safeguarding team within 5-20 minutes of raising your concern via the tutor portal. Please keep your phone with you and be ready to receive the call.

• During this call the DSL will make a threshold decision and inform you of what you need to do next and what the TP SG team will do next.

• Where you have raised an alert via the “red button” on the tutor portal and you have not been contacted by a member of the safeguarding team within 20 minutes, it becomes your responsibility to contact the local SCP (Safeguarding Children’s Partnership) directly. (Find your local SCP here)

• Stay child focused. The welfare of the child or young person must come before all other considerations. Explain your actions to them if they are of sufficient age and maturity to understand.

• Exercise professional judgement. Draw on your skills and expertise to decide how to proceed.

• Share information with caution. In a safeguarding emergency (in contrast to health and safety/accidents emergencies) there might be reason to believe that a parent is involved in the abuse, neglect or exploitation. In these circumstances take action to support and protect the child as the primary action.

• Identify social, educational, physical and cultural vulnerabilities. Concerns involving children or young persons with SEND warrant immediate action due to their increased risk of abuse. The vulnerability of other children or young persons, such as those who are or have been sexually exploited, live in challenging family circumstances, are looked after, have or have had a child protection plan or where the risk of FGM or forced marriage is suspected, should also tip the balance in favour of emergency action.

• Be clear about what you can do. Being the child or young person’s advocate is firmly within your remit. Removing them from their home, taking them to your home or confronting a suspect is not.

• Stay with the child or young person. You will remain responsible for them until you can arrange for him or her to be looked after by another appropriate adult.

• Document all actions. Including:

  • the child or young person’s details (name, age, address)

  • what the child or young person said, or did, that give you cause for concern (if the child made a verbal disclosure, write down their exact words)

  • the details of any other children or young persons involved or impacted

  • who you contacted, when you did so and how you took steps to ensure the safety of the child or young person

10. Responding to reports of missing from care or education

If a tutor or member of TP staff are notified/discover that a CYP is missing from care or education they must notify the DSL/DDSL immediately via the “red button” on the tutor portal.

The DSL will immediately contact the primary caregiver or school contact to determine the whereabouts of the CYP.

If their whereabouts cannot be determined the DSL will immediately contact the commissioner and share this information. The commissioner will take responsibility to ensure the following protocol is followed.

When a child or young person is identified as not being at a location they are expected to be at, the reporting individual (commissioner/care provider/foster carer/social worker etc) must take proactive steps to trace the child’s whereabouts prior to contacting the police. Such steps would include:

• Physical checks of the residence, including the child’s bedroom and any other location the child may be hiding within the house/building;

• Checks of any garden, garage, sheds, grounds and surrounding area(s);

• Attempting to contact the missing person directly, via mobile phone, text, or social networking sites (twitter/facebook etc);

• Contacting the missing person’s family and friends;

• Make reference to any risk assessments, placement plans or action plans that allow for some leeway with curfews for ‘boundary testing’.

• In respect of children missing from home it is expected that the parent/carer will inform the police without delay and will provide all relevant information to support enquiries including:

  • Description of the child

  • Details of where last seen and with who

  • Recent photograph

  • Relevant addresses

  • Previous history of absenteeism

• For Children Looked After it is expected that children’s services are contacted also.

• If we are concerned the above actions are not being addressed, we will take responsibility to contact the police directly and report the episode of missing from care/education to the appropriate SCP.

11. Managing allegations of abuse made against an adult

It is imperative that any allegations made against employees, workers or volunteers are dealt with systematically and quickly. The following procedures are in place first and foremost to protect the child or young person involved.

These guidelines follow the duties outlined in HM Government’s statutory guidance for Schools and Colleges, Keeping Children Safe in Education, September 2025 on how best to respond to allegations against an adult working or volunteering for our organisation.

The purpose of these procedures is such that any child or young person feels safe, respected and listened to when making an allegation against an adult representing Targeted Provision.

Any allegation against an adult directly employed by Targeted Provision will be reported directly to our Safeguarding Director, Chris Kneale-Jones chris@targetedprovision.com Any allegation against an adult engaged as a worker (Tutor) will be reported directly to our Principal DSL Emma Stanway emma@targetedprovision.com as soon as physically possible. This is crucial because it helps to:

• minimise the risk to the child or young person (Targeted Provision together with Children's social care and / or police, where they are involved, considers the impact on the child concerned and provides support as appropriate. Liaison between ourselves and other agencies takes place in order to ensure that the child's needs are addressed).

• minimise the impact on the child or young person's academic progress

• minimise pressure and stress on the employee concerned (As soon as possible after an allegation has been received, the accused member of staff will be advised to contact their union or professional association. Targeted Provision will provide appropriate support).

• ensure a fair and thorough investigation for all parties

Where an allegation is made against the specific Senior Manager or indeed, against the DSL, the Deputy DSL will take full DSL leadership responsibility as per this policy, and another Senior Manager will be responsible for following up on the allegation.

Where you consider sharing information with staff at Targeted Provision is inappropriate you should contact the LADO in the geographical area where the young person you are supporting resides. (Find your local LADO here)

11.1. The role of the Local Authority Designated Officer (LADO)

Every local authority is required to have a Local Authority Designated Officer (LADO). The LADO is responsible for providing advice, information and guidance to employers and voluntary organisations where there are concerns that a person may have behaved inappropriately when working or volunteering with children or young people. Managing and overseeing individual cases from all partner agencies. Ensuring the child's voice is heard and that they are safeguarded.

11.2. Confidentiality

Every effort is made to maintain confidentiality and guard against publicity while an allegation is being investigated or considered. Apart from keeping the child, parents and accused person (where this would not place the child at further risk) up to date with progress of the case, information is restricted to those who have a need to know in order to protect children, facilitate enquiries, manage related disciplinary or suitability processes.

The police should not provide identifying information to the press or media, unless and until a person is charged, except in exceptional circumstances (e.g., an appeal to trace a suspect). In such cases, the reasons should be documented and partner agencies consulted beforehand.

Section 13 of the Education Act 2011 introduced restrictions implemented in September 2012 on the publication of any information that would identify a teacher who is the subject of an allegation of misconduct that would constitute a criminal offence, where the alleged victim of the offence is a registered pupil at school.

Such restrictions remain in place unless or until the teacher is charged with a criminal offence, though they may be dispensed with on the application to the Magistrates' Court by any person, if the court is satisfied that it is in the interests of justice to do so, having regard to the welfare of:

• The person who is the subject of the allegation; and

• The victim of the offence to which the allegation relates.

• There is a right of appeal to the Crown Court.

• This restriction will apply to allegations made against any teacher who is engaged by Targeted Provision.

There is a new offence of publishing any information in breach of these restrictions. Publication includes any communication, in whatever form, which is addressed to the public at large or any section of the public.

It is a defence to show that the person publishing was not aware of the allegation having been made as set out in section 141H 'Defences' of the Act.

11.3. Record keeping

We ensure we keep accurate records of concerns raised about children, young people and their families and share these with relevant parties where necessary.

The DSL has ultimately responsibility for the accurate and timely keeping of these records.

In accordance with our Privacy Policy:

• These records are considered sensitive and will be stored securely on a central system.

• Children, young people and families will be granted access to the records we keep on them at their request, unless sharing this information would cause a Safeguarding or Child Protection concern.

• Targeted Provision will keep a clear and comprehensive summary of any case records on a tutor's confidential personnel file and give a copy to the individual. The record will include details of how the allegation was followed up and resolved, the decisions reached and the action taken. It will be kept at least until the person reaches normal retirement age or for ten years if longer.

• The purpose of the record is to enable accurate information to be given in response to any future request for a reference if the person has moved on. It will provide clarification where a future DBS request reveals non convicted information and will help to prevent unnecessary reinvestigation if an allegation re-surfaces after a period of time. In this sense it may serve as a protector to the individual themselves, as well as in cases where substantiated allegations need to be known about to safeguard future children.

Details of allegations that are found to be unsubstantiated, unfounded, false or malicious should be removed from personnel records. There is a need to consider whether the person making the allegation did so as a cry for help. Support should also be considered for the alleged perpetrator. For Education services see Keeping Children Safe in Education: Statutory Guidance for Schools and Colleges.

11.4. Interagency working in relation to Child Safeguarding Practice Reviews or Child Death Review Processes.

Where an LA or commissioning party of tuition finds that they become involved in either a CSPR or a CDRP for a young person that we have tutored, Targeted Provision will ensure swift, collaborative and comprehensive engagement to enable statutory timeframes to be met by the commissioning LA. This will include:

DSL liaison with all appropriate parties as requested, including providing overview documentation and evidence of any communications we may (or may not) have had regarding the young person from a safeguarding perspective.

We will supply, where requested, any documentation that we may hold that is pertinent to the review processes.

The DSL will make themselves available to any investigating officers who wish to interview a member of Targeted Provision in relation to the review processes.

The DSL will, where required, cooperate fully in attending any panel, court of law, Domestic Homicide Review, Multi-Agency Public Protection Arrangements (MAPPA) review or coroners court proceedings if this is deemed necessary, to give evidence as required.

11.5. Resignations and 'compromise agreements'

Every effort is made to reach a conclusion in all cases even if:

• The individual refuses to cooperate, having been given a full opportunity to answer the allegation and make representations.

• It may not be possible to apply any disciplinary sanctions if a person's period of notice expires before the process is complete.

‘Compromise agreements' are not used by Targeted Provision (i.e., where a member of staff agrees to resign provided that disciplinary action is not taken and that a future reference is agreed). A settlement/compromise agreement which prevents the employer from making a DBS referral when the criteria are met for so doing would likely result in a criminal offence being committed for failure to comply with the duty to refer. Targeted Provision will always make a referral to the Disclosure and Barring Service to consider whether to add the individual to the barred list. This applies irrespective of whether a referral has been made to local authority children's social care and/or the designated officer or team of officers. It is an offence to fail to make a referral without good reason.

12. Substantiated allegations

The Disclosure and Barring Service (DBS) was established under the Protection of Freedoms Act 2012 and merges the functions previously carried out by the Criminal Records Bureau (CRB) and Independent Safeguarding Authority (ISA). The relevant legislation is set out in the Protection of Freedoms Act 2012.

If an allegation is substantiated and one of our tutors is dismissed or we cease to use the tutor's service or the tutor resigns or otherwise ceases to provide his/her services, we invite the LADO to discuss with us whether a referral should be made to the Disclosure and Barring Service (DBS).

Referrals should be made to DBS when an employer or organisation believes a person has caused harm or poses a future risk of harm to vulnerable groups, including children.

If a referral is to be made; it should be submitted within one month of the allegation being substantiated.

Targeted Provision recognises their legal duty to refer in these cases.

If the person being referred to the DBS is a teacher in England, they should also be referred to the Teaching Regulation Agency.

12.1. Reporting and recording an allegation against an adult

Where an allegation is made about an adult involved with an activity related to Targeted Provision’s service provision, the following steps should be followed:

Immediately notify the DSL (or Deputy DSL in the absence of the DSL) and Senior Management, unless the situation is considered a Safeguarding Emergency, in which case contacting the police may be the most appropriate reaction.

The allegation should be recorded as soon as physically possible by the DSL on our Reporting an allegation against an adult form (see Appendix 1)

The DSL in consultation with the appropriate (local) LADO will agree to the next steps. These steps will be one of:

• Take no further action

• Continuous monitoring of the situation

• Reporting the allegation with the relevant Local Authority Designated Office (LADO) within 1 working day. They will do so by submitting to the LADO the Reporting an allegation against an adult form (see Appendix 1).

The referral must be made to the LADO where the member of staff to whom the allegation relates, works.

If it is deemed that the safeguarding concern raised against a child or young person is or may imminently become an emergency, the DSL will notify the police and any relevant parties, including the LADO, immediately.

The DSL will always seek advice and guidance from the appropriate local DSL in all cases where there is an allegation against an adult.

12.2. Concern that does not meet the harm threshold

Low-level concerns are treated with equal amounts of attention and urgency. As directed by KCSIE 23 Targeted Provision’s approach to safeguarding ensures that we promote an open and transparent culture in which all concerns about all adults working in or on behalf of Targeted Provision are dealt with promptly and appropriately. The term ‘low-level’ concern does not mean that it is insignificant, it means that the adult’s behaviour towards a child does not meet the threshold set out below:

• behaved in a way that has harmed a child, or may have harmed a child; and/or

• possibly committed a criminal offence against or related to a child; and/or

• behaved towards a child or children in a way that indicates they may pose a risk of harm to children; and/or

• behaved or may have behaved in a way that indicates they may not be suitable to work with children

A low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ – that an adult may have acted in a way that is inconsistent with our code of conduct, including inappropriate conduct outside of work, and does not meet the allegation threshold, or is otherwise not serious enough to consider a referral to the LADO – but may merit consulting with and seeking advice from the LADO, and on a no-names basis if necessary.

13. Allegations made against a child or young person

Where an allegation is made about a child or young person involved with an activity related to Targeted Provision’s service provision, the following steps should be followed:

The DSL will be responsible for first noting

• the child or young person’s details (name, age, address)

• what the child or young person said or did that gave you cause for concern (if the child made a verbal disclosure, write down their exact words)

• the details of any other children or young persons involved or impacted

The DSL will then decide whether the allegation against the child or young person is a safeguarding/child protection concern. In line with NSPCC guidelines on what constitutes a child protection concern where another child or young person has been accused.

“An allegation becomes a child protection concern when there's a significant difference of power between the child who is displaying abusive behaviour and the person being abused, for example when”:

• there's an age difference of more than two years

• there's a significant difference in terms of size or level of ability

• the child or young person displaying abusive behaviour holds a position of power (such as being a helper, volunteer or informal leader)

• the child or young person being abused is significantly more vulnerable than the other child or young person.

• the behaviour involves sexual assault or physical assault

• the child or young person who has experienced the abusive behaviour has suffered significant harm

• the behaviour forms part of a pattern of concerning behaviour by the child or young person who is being abusive

• the child or young person carrying out the abuse is displaying harmful sexual behaviour

• the reporting person is concerned that the child or young person carrying out the abuse may be doing so because they have experienced abuse themselves

Should the DSL deem that the accusation is a safeguarding/child protection concern, in line with this Safeguarding Policy, the DSL will;

Report the allegation with the relevant Local Authority Children’s Social Care Team (CSCT) within 1 working day. They will do so by submitting to the CSCT the Allegations against a Child or Young Person Form (see Appendix 2).

If it is deemed that the safeguarding concern raised against a child or young person is an emergency, the DSL will notify the police and any relevant parties, including the CSCT, immediately.

14. Escalation procedure

With respect to multi-agency disagreements, where members of staff from any agency feel concerns regarding a child are not being addressed it is expected that the escalation process in Appendix 8 should be used until a satisfactory conclusion is reached.

15. Prevent

Since 2010, when the Government published the first version of the Prevent Strategy, there has been an awareness of the specific need to safeguard children, young people and families from extremist ideologies. There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

We value freedom of speech and the expression of beliefs and ideology as fundamental rights underpinning our society’s values. Pupils/students and teachers have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism. The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation.

We are clear that this exploitation and radicalisation must be viewed as a safeguarding concern and that protecting children from the risk of radicalisation is part of our safeguarding duty.

Definitions of radicalisation and extremism, and indicators of vulnerability to radicalisation are in Appendix 5.

We seek to protect children and young people against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right/Neo-Nazi/White Supremacist ideology, Domestic Terrorism, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

With effect from 1 July 2015, all schools are subject to a duty to have “due regard to the need to prevent people being drawn into terrorism” (section 26, Counter Terrorism and Security Act 2015). This is known as The Prevent Duty. Although we are not a school, we have identified Prevent Single Point of Contact (SPOC), our DSL, who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism.

The SPOC for our organisation is Rachel Greathead

When any employee, self-employed tutor or mentor has concerns that a student may be at risk of radicalisation or involvement in terrorism, they should speak with SPOC/DSL.

A Prevent referral is a supported activity which should follow these steps:

• Identification of any student or member of staff at risk of radicalisation

• A referral should be made via our SPOC/DSL or Deputy Designated Safeguarding Lead

• Our DSL gathers more information where possible and identifies what further action is required

• If there is an immediate risk, the DSL will contact the Police directly

• If there is no immediate risk, the DSL will contact the Safer Schools Officer or the social worker and LADO where appropriate

Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action. For this reason, the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

The DfE Prevent Helpline for schools & parents can be reached here:

Tel: 020 7340 7264 (non-emergency)

Email: Counter.extremism@education.gsi.gov.uk

16. Legal framework

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children and young people in England. A summary of the key legislation and guidance is available from The NSPCC.

Safeguarding decisions take account of the ability to give informed consent and comply with the Mental Capacity Act 2005

This policy and our practices have regard to core documentation published by the DfE and the DoH, which gives statutory guidance on the specific services we deliver. The two core documents are Keeping Children Safe in Education (DfE 2025) and the SEND Code of Practice: 0 to 25 years (DfE, DoH 2015).

Anyone who is a direct employee, worker or volunteer of Targeted Provision has no investigative role where child protection is concerned; this is a matter for children’s social care and the police.

This policy should be read alongside our detailed policies on dealing with specific safeguarding scenarios. These are our policies on:

• Safer recruitment procedures

• Complaints procedure 

• Behaviour policy (our Code of Conduct)

• Anti-bullying procedures

• Confidentiality

• Whistleblowing 

Our Terms and Conditions and Privacy Policy/Data Protection Policy contain the following policies which should also be referred to alongside our Safeguarding Policy:

• Health and Safety

• Equal opportunities

More information about what these policies and procedures should include is available from The NSPCC

17. Review

This Safeguarding & Child Protection Policy is reviewed every six months, and, where appropriate, is updated to reflect any statutory changes/improvements to Safeguarding policy.

18. Appendices

Appendix 1: Reporting an allegation against an Adult Form

Appendix 2: Reporting an allegation against a Child or Young Person Form

Appendix 3: Definitions of Abuse, Neglect and Exploitation & Neglect

Appendix 4: Brook Traffic Light Tool

Appendix 5: Indicators of Vulnerability to Radicalisation

Appendix 6: Recording General Concerns about a Child – FORM A

Appendix 7: Safeguarding Referral Guidance

Appendix 8: Escalations Procedure

Appendix 9: Filtering and Monitoring Procedures.