SENse Learning - Safeguarding Policy (full)

Including Child Protection

This is a September 2026 updated policy

This policy was adopted on March 2019

This policy was reviewed on January 2020 -this policy was amended as part of an audit This policy was reviewed on February 2021 - this policy included different Local Authorities additions

This policy was reviewed on September 2021 - this policy included KCSiE ‘21 updates This policy was reviewed on September 2022 - this policy was a re-write with KCSiE ‘22 updates. This policy was reviewed September 2023 - this policy was a re-write with KCSiE ‘23 updates. This policy was reviewed September 2024 - this policy was a re-write with KCSiE ‘24 updates

 

This policy covers all the Local Authorities we work with.

 

Contents

 

Changes to policy from September 26 following KCSIE updates and review:

 

1. Key safeguarding contacts

All DSLs can be reached on 01444 400896.

2. Policy statement, scope and definitions

SENse Learning Limited is a bespoke tuition and alternative provision for children, young people and vulnerable adults up to 25 who are out of school, struggling to attend, or not in education, employment or training (NEET). We believe each young person is unique and that the right support can make a positive and lasting difference.

SENse Learning takes its responsibility to safeguard children, young people and vulnerable adults extremely seriously. We will take all reasonable steps to protect them from harm while respecting their rights, wishes and feelings, and we will meet our legal and statutory safeguarding responsibilities.

This policy sets out what everyone working with students through SENse Learning must be aware of, and what to do if they have a concern. Everyone it applies to must read it. It is reviewed annually, and sooner if legislation or statutory guidance changes.

For each local authority that refers students to us, we follow that area's multi-agency safeguarding arrangements and procedures.

2.1. 1 Definitions

Associates' obligations under this policy arise from SENse Learning's statutory and contractual safeguarding duties, and form part of their contract for services. They do not create an employment or worker relationship.

3. Legislation and guidance

This policy follows Keeping Children Safe in Education 2026 (KCSiE), which is the benchmark for all our safeguarding practice. It also reflects:

• the Children Act 1989 and the Children Act 2004;

• the Education Act 2002;

• Working Together to Safeguard Children (current edition);

• the Counter-Terrorism and Security Act 2015 (section 26, the Prevent duty) and the Prevent duty guidance for England and Wales;

• the Female Genital Mutilation Act 2003, section 5B (the mandatory reporting duty);

• the Domestic Abuse Act 2021;

• the Care Act 2014, for students aged 18 and over;

• the Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012;

• the Data Protection Act 2018 and UK GDPR;

• statutory guidance on children missing education and on working together to improve school attendance; and

• the multi-agency safeguarding arrangements of each local authority we work with.

4. Our aims and approach

SENse Learning will:

• put safeguarding at the heart of everything we do;

• help students learn how to keep themselves safe, online and offline;

• support students' development in ways that build security, confidence and independence;

• make sure every student knows a trusted adult they can talk to if they are worried;

• take the child's wishes and feelings into account when deciding what action to take on a concern, and have systems for students to give their views;

• make sure all SENse professionals know how to report a concern and how to contact child protection agencies;

• monitor children known or thought to be at risk of harm, and contribute to assessments and support plans for them;

• maintain good communication between SENse professionals and with other agencies, especially the police and children's social care;

• make sure everyone who works with students has been checked in line with KCSiE 2026 Part 3, including an enhanced DBS check with barred list check through SENse Learning; and

• keep other policies that support safeguarding up to date.

4.1. Working with families and other agencies

We work respectfully with families, parents and carers, keeping them informed and involved in decisions and plans unless doing so would put a child at greater risk. We work closely with other agencies to share information, identify risks of harm, including harm outside the home, and make sure children and families receive timely support.

4.2. Early help and Family Help

The DSL and staff assess children's needs using each local authority's threshold guidance. The DSL distinguishes between early help that SENse Learning coordinates itself through our enhanced pastoral offer, and multi-agency Family Help provided through local authority children's services. A referral for Family Help is made when a child needs coordinated support, including where they face:

• multiple or overlapping harms, such as domestic abuse alongside online exploitation;

• specific care arrangements, such as kinship care or being looked after; or

• contextual risks, such as a part-time timetable or repeated removal from lessons, which may indicate a risk of criminal exploitation.

4.3. Students who may need additional safeguarding

We keep records of students who may be particularly vulnerable, including students who:

• are pregnant or young parents;

• show early signs of abusive or violent behaviour;

• are on part-time timetables or repeatedly removed from lessons; or

• have medical conditions where medical needs may overlap with a risk of abuse or neglect.

5. Roles, responsibilities and training

5.1. 1 Designated Safeguarding Lead and deputies

The DSL role is set out in Annex C of KCSiE 2026 and in the DSL's and deputies' job descriptions. The DSL and deputies will:

• complete DSL training for their role, refresh it annually, and keep their knowledge and skills up to date;

• make sure all SENse professionals know who the DSLs are and how to contact them;

• make sure all SENse professionals understand the signs of abuse and their duty to report concerns to a DSL;

• keep a record that every SENse professional has read the parts of KCSiE 2026 this policy requires (section 4.3);

• share relevant information about the welfare and safeguarding of children, including children with a social worker, with those who need it to support the child's education;

• liaise with curriculum leads so that relationships, sex and health education is reflected in students' provision;

• keep child protection records and transfer them securely when a student moves to another setting (section 11);

• keep SENse professionals and senior leaders informed of significant changes to local authority safeguarding procedures;

• make sure a DSL or deputy is available during working hours in term time, and agree cover for out-of-hours or out-of-term activities; and

• give each local authority up-to-date emergency contact details for when the provision is closed.

The DSL will be given time to stay up to date with developments relevant to the role.

5.2. 2 All SENse professionals

Everyone working with students through SENse Learning must:

• maintain an attitude of "it could happen here";

• know the signs of abuse, neglect and exploitation, and report any concern about a child to a DSL without delay;

• report any concern about the conduct of an adult working with children (section 13);

• never promise a child that they will keep a secret; and

• follow this policy and the safeguarding procedures of any school or setting they work in.

5.3. 3 Safeguarding training and reading

Staff complete safeguarding and child protection training at induction and receive updates at least annually, including on online safety and Prevent, through SENse Learning's training plan.

Associates must, as a condition of being offered work:

• hold current accredited safeguarding training, renewed annually, using SENse Learning's course or an equivalent SENse Learning accepts;

• complete SENse Learning's safeguarding briefing before their first session; and

• confirm in writing that they have read this policy and KCSiE 2026 [insert required parts, see Points to confirm].

SENse Learning will send associates safeguarding updates, including on online safety and Prevent, at least annually, and whenever local procedures change significantly. Where an associate's training lapses, they will not be offered new sessions until it is renewed.

6. Confidentiality and information sharing

All child protection matters are confidential and shared only on a need-to-know basis, proportionately and where relevant.

• The DSL shares child protection information with staff and associates only where they need it. Full details are shared only between the DSLs and Directors.

• All SENse professionals have a professional responsibility to share information with other agencies where necessary to safeguard a child. Data protection law does not prevent this.

• No one may promise a child to keep a secret that could compromise the child's safety or wellbeing.

• Parents and carers will be told of an intention to refer a child to children's social care, unless doing so could put the child at greater risk of harm or impede a criminal investigation. If in doubt, the DSL will seek advice through the local authority's referral route.

In line with KCSiE 2026, the DSL will share information about welfare and child protection issues, including for children with a social worker, where this helps promote the child's educational outcomes. We approach this sensitively, with the child and their parents or carers. SENse professionals may need to know that a child has been supported by safeguarding agencies, but often will not need the details.

See also our Data Protection Policy.

7. Recognising abuse and neglect

Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family, or in an institutional or community setting, by people known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults, or by another child or children.

Abuse is not always easy to identify, and a child may experience more than one type. The DSL, Jenni Griffiths, is SENse Learning's lead on safeguarding and is there to support all SENse professionals.

7.1. 1 Neglect

The persistent failure to meet a child's basic physical and/or psychological needs, likely to result in serious impairment of the child's health or development. It may occur during pregnancy, for example through maternal substance misuse. After birth, it may involve a parent or carer failing to:

• provide adequate food, clothing and shelter, including exclusion from home or abandonment;

• protect a child from physical and emotional harm or danger;

• ensure adequate supervision, including through inadequate caregivers; or

• ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, a child's basic emotional needs.

7.2. 2 Physical abuse

May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Signs may include unexplained injuries, fractures or bruising, mouth injuries, burns and scalds, and poisoning.

7.3. 3 Sexual abuse

Involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening. It may involve physical contact, including assault by penetration or non-penetrative acts such as masturbation, kissing, rubbing and touching outside clothing. It may also include non-contact activities, such as involving children in looking at or producing sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse, including online. Sexual abuse can be committed by women and by other children, as well as by men.

7.4. 4 Emotional abuse

The persistent emotional maltreatment of a child, causing severe and adverse effects on their emotional development. It may involve conveying to a child that they are worthless, unloved or inadequate; not giving them opportunities to express their views; deliberately silencing them or making fun of what they say or how they communicate; imposing age- or developmentally inappropriate expectations; overprotection or preventing normal social interaction; seeing or hearing the ill-treatment of another; or serious bullying, including cyberbullying. Some level of emotional abuse is involved in all types of maltreatment.

7.5. 5 Fabricated or induced illness

Occurs when a parent or carer exaggerates or deliberately causes symptoms of illness in a child. Possible indicators include:

• discrepancies between reported and observed medical conditions;

• attendance at various hospitals in different areas;

• feeding or eating difficulties linked to unpleasant feeding interactions;

• the child developing abnormal attitudes to their own health;

• failure to thrive with no underlying medical cause;

• speech, language or motor delays;

• poor or restricted peer relationships; and

• poor attendance and under-achievement.

7.6. 6 Other safeguarding issues

SENse professionals should also be aware of the wider safeguarding issues set out in KCSiE 2026, including:

• bullying, including cyberbullying;

• children and the courts;

• children with family members in prison (the Prisoners' Families Helpline is 0808 808 2003);

• children missing education, and children missing from home or care;

• children who are lesbian, gay, bisexual or trans, who may face additional risks;

• drugs;

• faith-based abuse;

• gangs and youth violence;

• gender-based violence and violence against women and girls;

• homelessness;

• mental health;

• private fostering; and

• trafficking and modern slavery.

8. Exploitation and harm outside the home

8.1. 1 Child criminal exploitation (CCE)

CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity, in exchange for something the child needs or wants, for the advantage of the perpetrator, or through violence or threats of violence. It can still be exploitation even if the activity appears consensual, and it can happen online.

CCE can include being forced to work in cannabis factories, moving drugs or money (county lines), shoplifting, pickpocketing, or threatening other young people. It can affect any child, and vulnerable adults. The power imbalance may come from age, gender, cognitive ability, physical strength, status or access to resources. Indicators of CCE may be different for girls than for boys.

8.2. 2 County lines

County lines describes gangs and organised criminal networks that move illegal drugs into other areas using dedicated phone lines. Children and vulnerable adults are exploited to move and store drugs and money, often through coercion, intimidation, violence and weapons. They can be recruited in schools, alternative provision, pupil referral units, special schools and children's homes, and can become trapped by drug debts and threats against them or their families. Missing episodes are a key indicator.

8.3. 3 Child sexual exploitation (CSE)

CSE is where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, in exchange for something the child needs or wants, or for the perpetrator's financial advantage or increased status. It is a form of child sexual abuse. It can happen even if the activity appears consensual, including with 16 and 17 year olds, and can occur online without the child's immediate knowledge. Some children who are being exploited show no outward signs.

8.4. 4 Indicators of exploitation

Indicators of CCE and CSE can include children who:

• have unexplained gifts, money or new possessions;

• associate with other young people involved in exploitation, or with older individuals or groups;

• show changes in emotional wellbeing;

• misuse drugs or alcohol;

• go missing or regularly come home late;

• regularly miss education;

• have older boyfriends or girlfriends; or

• have sexually transmitted infections or become pregnant.

Where we have concerns, we will be persistent in referring them, and escalate using the local authority's professional differences protocol if needed (section 13.5).

8.5. 5 So-called honour-based abuse

So-called honour-based abuse covers incidents or crimes committed to protect or defend the honour of a family or community, including female genital mutilation, forced marriage and practices such as breast ironing. It often involves wider family or community pressure and multiple perpetrators. All such abuse is abuse, whatever the motivation, and is managed and escalated as such.

Female genital mutilation (FGM) comprises all procedures involving partial or total removal of the external female genitalia, or other injury to the female genital organs. It is illegal in the UK and a form of child abuse. Teachers have a legal duty to report known cases of FGM in girls under 18 to the police. Any SENse professional with a concern about FGM must tell a DSL immediately.

Forced marriage is a crime. It is a marriage entered into without the full and free consent of one or both parties, where violence, threats or coercion are used. Some people cannot consent, for example because of a learning disability. Since February 2023, no one under 18 can legally marry or enter a civil partnership in England and Wales, even with parental consent.

8.6. 6 Radicalisation and Prevent

SENse Learning has a duty under section 26 of the Counter-Terrorism and Security Act 2015 to have due regard to the need to prevent people from being drawn into terrorism. Protecting children from radicalisation is part of our wider safeguarding duty.

Children may be exposed to extremist messages through family, friends, groups, social media or the internet. The DSL and senior leaders will be familiar with the Prevent duty guidance for England and Wales, and SENse Learning applies the government's current definition of extremism. Jenni Griffiths, Pastoral Manager and DSL, is SENse Learning's Prevent lead.

All SENse professionals receive Prevent training or updates at least annually (section 4.3). Any concern that a student may be at risk of radicalisation must be reported to a DSL, who will decide whether to make a Prevent referral. Referrals may be considered by a multi-agency Channel panel, which provides voluntary, confidential early support to people vulnerable to being drawn into terrorism. SENse Learning may be asked to attend.

9. Child-on-child abuse, sexual violence and domestic abuse

9.1. 1 Child-on-child abuse

All children have the right to learn in a safe environment, free from harm by adults or other children, including harassment, misogyny, violence and harmful sexual behaviour. Children can abuse other children. Abuse is abuse and will never be tolerated or passed off as "banter", "just having a laugh" or "part of growing up". Girls are more likely to be victims and boys perpetrators, but all child-on-child abuse is unacceptable and will be taken seriously.

Lower-level behaviour is managed under our behaviour and anti-bullying policies, but some allegations are serious enough to be safeguarding concerns. Child-on-child abuse can include:

• bullying, including cyberbullying and prejudice-based bullying;

• abuse in intimate relationships between children;

• physical abuse, which may have an online element;

• sexual violence, such as rape, assault by penetration and sexual assault;

• sexual harassment, including sexual comments, jokes and online harassment;

• causing someone to engage in sexual activity without consent;

• upskirting, which is a criminal offence; and

• consensual and non-consensual sharing of nude and semi-nude images or videos.

Any SENse professional with a concern about child-on-child abuse must report it to a DSL as soon as possible, record the facts in the daily log, and reassure the student that they will speak to someone who can help and that their concern will be taken seriously.

9.2. 2 Sexual violence and sexual harassment between children

Sexual violence and sexual harassment can occur between children of any age and sex, individually or in groups, online and offline. Girls, children with SEND and LGBT children are at greater risk. SENse professionals should:

• make clear that sexual violence and sexual harassment are never acceptable and not an inevitable part of growing up;

• never dismiss them as "banter" or "boys being boys"; and

• challenge behaviours such as grabbing bottoms, breasts and genitalia, flicking bras and lifting skirts, which risk being normalised if tolerated.

Sexual violence refers to offences under the Sexual Offences Act 2003, including rape, assault by penetration and sexual assault, where the victim does not consent and the perpetrator does not reasonably believe they consent.

Sexual harassment is unwanted conduct of a sexual nature, online or offline, that is likely to violate a child's dignity, make them feel intimidated, degraded or humiliated, or create a hostile or sexualised environment. It can include sexual comments, jokes or taunting, physical behaviour such as deliberately brushing against someone, displaying sexual images, and online harassment such as non-consensual image sharing or unwanted sexual messages.

Where students' provision includes relationships and sex education, it will cover consent.

Responding to a report. Our first response to a child's report is critical. Victims must be reassured that they are being taken seriously, will be supported and kept safe, and are not creating a problem by reporting. Any SENse professional who receives a report must tell a DSL immediately.

The DSL will balance safeguarding the victim with supporting the alleged perpetrator, considering their age and developmental stage, the nature of the allegation, and any unmet needs of their own. Harmful sexual behaviour can be a symptom of a child's own abuse. Responses are proportionate and decided case by case. Where both children remain with SENse Learning, a risk assessment must be in place. The DSL is trained to use the Brook Traffic Light Tool.

If an alleged perpetrator moves to another setting, the DSL will make sure the new setting is aware of any ongoing support needs and risks, and transfer the child protection file. The emotional wellbeing of everyone involved will be monitored, and the DSL will consider referral to specialist services, MASH or Early Help.

For upskirting, we will respond as for any other report of abuse, take advice through the local authority's referral route, and be guided by the police where the alleged perpetrator is one of our students, while continuing to support them.

9.3. 3 Domestic abuse

Under the Domestic Abuse Act 2021, domestic abuse is any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between people aged 16 or over who are, or have been, intimate partners or family members, regardless of gender or sexuality. It can be psychological, physical, sexual, financial or emotional. Children who see, hear or experience the effects of domestic abuse are victims in their own right. Domestic abuse can also occur in young people's own relationships.

The DSL will consider any concern about domestic abuse and seek advice through the local authority's referral route. The National Domestic Abuse Helpline is 0808 2000 247.

Operation Encompass. SENse Learning is part of Operation Encompass, a police and education partnership through which the police share information about domestic abuse incidents involving our students before the start of the next day. Our Key Adults, Jenni Griffiths (DSL), Lucy McCully and Amy Attoe, have completed Key Adult training. They receive these notifications and share them with those who need to know to support the student.

10. Online safety

Technology is a significant part of many safeguarding issues, including exploitation, radicalisation and sexual predation. Our approach aims to protect and educate students in their use of technology, and to identify, intervene in and escalate any incident.

KCSiE 2026 groups online risks into four areas:

We will use opportunities in students' provision to teach them to stay safe online, choosing resources that suit their needs.

10.1. 1 Filtering and monitoring

The DSL has overall responsibility for filtering and monitoring. All SENse Learning devices used by students have Securly filtering and monitoring software, which blocks inappropriate material and alerts the safeguarding team to concerning content, such as searches relating to suicide, self-harm or bullying, so that we can support the student promptly. Filtering is set so that it does not unreasonably restrict what students can be taught.

Monitoring applies to activity on SENse Learning devices. SENse professionals who use those devices are told that their activity on them is monitored.

We review our filtering and monitoring arrangements at least once every academic year, and record the review. We are also reviewing our cyber security and the risks of generative AI against government guidance.

10.2. 2 Photographs and video

SENse professionals may need to take photographs as evidence for students' qualifications. These must not identify the student. Where identifying photographs or videos are needed for certification, we will get written consent and store them securely. For looked-after children, and any student where identification may increase safeguarding risk, images are taken only when absolutely necessary and with explicit authorisation from the child's social worker or local authority officer.

Photographs must be shared through Google Chat and not kept on personal devices.

See our Online Safety Policy for more on online safety, gaming, social media and device use.

11. Responding to disclosures and reporting concerns

We want students to feel able to talk to a trusted adult. Commissioners, schools and families will always know which SENse professional is working with their child and where sessions take place, and will be told of any change.

11.1. 1 If a child discloses

• Accept what the child says and stay calm. Let the child set the pace without pressing for detail.

• Do not ask leading questions, such as "Did X touch you there?" Your role is to listen, not to investigate.

• If you need to clarify, use open questions such as "Tell me what happened" or "Describe what happened", in words the child understands.

• Do not ask questions that make the child feel guilty, such as "Why didn't you tell me before?" You may ask "Have you spoken to anyone else about this?"

• Acknowledge how hard it was for the child to tell you, and reassure them they have done the right thing.

• Do not criticise the alleged perpetrator, as the child may have a relationship with them.

• Do not promise confidentiality. Explain that you will need to share what they have told you with the DSL, and why.

• Take every victim seriously and never make them feel they are creating a problem by reporting.

11.2. 2 Recording

Records may be used in later investigations, so:

• make detailed notes at the time or immediately afterwards, recording the date, time, place and context;

• record facts and the child's own words, not assumptions or opinions, and note their non-verbal behaviour;

• describe any injury precisely, such as "right arm above elbow", using a body map if needed;

• never photograph an injury; and

• record when and where you made the notes, and who else was present.

11.3. 3 Reporting

It is everyone's responsibility to report concerns, not to decide whether abuse has happened.

1. If a child is in immediate danger, call 999.

2. If the concern needs immediate attention, call 01444 400896 and ask for a DSL, who will decide what action to take. Also tell the case coordinator, who does not receive safeguarding reports automatically.

3. Record every concern on the student portal using the red safeguarding button on the student's home page, as soon as possible. Include the time, date, location, the concern and any action already taken. The report goes automatically to all DSLs.

4. Give any paper notes to a DSL, who will keep them securely.

The responding DSL will decide next steps, record their actions, communications and reasoning, and give feedback on a need-to-know basis. The DSL will share safeguarding concerns with the student's on-roll school or local authority. The DSLs review students of concern at a monthly safeguarding meeting, and audit reporting systems annually.

If the DSL is unsure whether to refer, they will consult the local MASH or referral service. Each local authority's threshold guidance and referral routes are stored securely and accessible to all DSLs.

12. Record keeping

Child protection records are kept securely on our safeguarding system, separate from other records, and accessed only by those who need to for safeguarding purposes.

• Each student has their own record. Siblings have separate records, cross-referenced where needed.

• Entries are accurate, legible and made as soon as practicable after a concern is raised.

• Each record has a chronology of entries and up-to-date contact details for key professionals.

• Paper records are kept on file even after scanning.

• When a student moves to another setting, the DSL transfers the child protection file securely and separately, and makes sure the new setting knows about any concerns. Records include a clear summary of each concern, how it was followed up and resolved, and any action, decision and outcome.

See our Data Protection Policy for more on information sharing.

13. Safer recruitment

SENse Learning recruits staff and engages associates in line with Part 3 of KCSiE 2026 and our Safer Recruitment Policy. In particular:

• everyone who works with students has an enhanced DBS check with barred list check through SENse Learning;

• CVs are accepted only with a fully completed application form;

• shortlisted applicants are told that we carry out online searches as part of our due diligence;

• all staff who interview applicants have completed safer recruitment training; and

• the HR team keeps a single central record of the checks carried out on everyone who works with students.

14. Allegations, low-level concerns, whistleblowing and escalation

SENse Learning follows Part 4 of KCSiE 2026 when responding to concerns or allegations about anyone working with students, whether staff or associates.

14.1. 1 Allegations

An allegation is any information indicating that a SENse professional may have:

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

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

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

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

This includes conduct in their personal, professional or community life.

Any allegation must be reported immediately to the DSL, Jenni Griffiths (jenni.griffiths@sense-learning.com). The person receiving it should take it seriously, keep an open mind, not investigate or ask leading questions, and not promise confidentiality. The DSL will consult the LADO for the relevant local authority. The DSL keeps up-to-date LADO details for every local authority we work with.

If the allegation is about the DSL or a senior manager, it will be reported to another Director, who will consult the LADO.

Our aims are to minimise the risk and impact on the child, and to make sure the investigation is fair to everyone involved. The person concerned will be advised to contact their union or professional association, and SENse Learning will provide appropriate support. Where an allegation requires investigation, the person's provision with the student will be paused until it is concluded.

The LADO gives advice to employers and organisations where there are concerns about how someone working with children has behaved, oversees the handling of cases, and makes sure the child's voice is heard.

Complaints from parents about any part of our provision must be checked for any allegation that needs referral to the LADO.

14.2. 2 Low-level concerns

A low-level concern is any concern, however small, that a SENse professional may have acted in a way that:

• is inconsistent with the Staff Code of Conduct (staff) or the professional standards in their contract for services (associates), including inappropriate conduct outside work; and

• does not meet the threshold for an allegation or referral to the LADO.

Examples include being over-friendly with children, having favourites, taking photographs of children on a personal phone, being alone with a child in a secluded area or behind a closed door, and using inappropriate sexualised, intimidating or offensive language. Such behaviour can range from the thoughtless to behaviour intended to enable abuse.

We want everyone to feel able to share low-level concerns about themselves or others. We will:

• make clear what appropriate behaviour is, so SENse professionals can recognise concerning behaviour in themselves and others;

• encourage SENse professionals to report low-level concerns through our reporting processes;

• handle concerns responsively and proportionately, and address them early: for staff through line management, and for associates under their contract for services; and

• use concerns to identify weaknesses in our safeguarding arrangements.

Low-level concerns are reported to the DSL, Jenni Griffiths, and recorded in writing with the details, context and action taken. Records are kept securely, separately from any personnel or associate file, and never in a child's child protection file.

14.3. 3 Substantiated allegations and DBS referrals

SENse Learning has a legal duty to refer someone to the Disclosure and Barring Service (DBS) where it removes them from work with children, or would have done had they not left, because they have harmed a child or pose a risk of harm. This applies whether a member of staff is dismissed or resigns, or SENse Learning stops using an associate's services or the associate stops providing them. We will discuss with the LADO whether a referral is needed and make any referral promptly.

Where the person is a teacher, we will also consider a referral to the Teaching Regulation Agency.

14.4. 4 Whistleblowing

All SENse professionals should feel able to raise concerns about poor or unsafe practice, or potential failures in SENse Learning's safeguarding arrangements. The Managing Director will take such concerns seriously. Staff can use the Whistleblowing Policy, and associates can raise concerns directly with the DSL or a Director.

Anyone who feels unable to raise a concern internally, or that their concern has not been addressed, can contact the NSPCC Whistleblowing Advice Line on 0800 028 0285 or help@nspcc.org.uk.

14.5. 5 Escalation

Where the DSL disagrees with a safeguarding decision made by another agency, for example children's social care closing a case too early, the DSL will assess the impact on the child. If concerns remain, the DSL will challenge the decision through the local authority's professional differences or escalation protocol.

15. Adult safeguarding

Some of our students are aged 18 to 25. When a student turns 18, safeguarding responsibility moves from children's to adults' services, under the Care Act 2014.

Adult safeguarding aims to:

• stop abuse and neglect, and prevent harm to adults with care and support needs;

• safeguard adults in a way that supports them to make choices and have control over how they live;

• focus on improving life for the adult concerned; and

• raise awareness so that communities and professionals play their part in preventing, identifying and responding to abuse.

The six principles of adult safeguarding are empowerment, prevention, proportionality (the least intrusive response appropriate), protection, partnership and accountability.

15.1. 1 Types of abuse

15.2. 2 Responding to a disclosure from a student aged 18 or over

• Let the student speak without interruption, and stay calm.

• Do not trivialise or exaggerate the issue, make suggestions, or show anger, disgust or disbelief.

• Ask only enough questions to clarify; do not probe or interrogate.

• Reassure them they were right to tell you and that you are taking it seriously.

• Be honest that you cannot keep it secret and will need to tell someone.

• Make a written record as soon as practicable, using facts and their words, not opinions such as "I think".

15.3. 3 Reporting

Report concerns about students aged 18 or over in the same way as for children (section 10.3), using the red button on the student portal. If the concern needs immediate attention, call the DSL, Jenni Griffiths, on 01444 400896. If there is an immediate risk to safety, call 999.

16. Missing students and attendance

16.1. 1 A student goes missing during a session

Under 18. The SENse professional must phone the parent or carer, the case coordinator and a DSL as soon as possible. Depending on the child's age and vulnerability, or if the parent or carer cannot be reached, they must consider whether immediate action is needed, such as calling the police. The DSL will work with the parent or carer to agree a clear plan to locate the student and keep them safe.

18 and over. The response depends on the student's needs and any risks around the behaviour. The case coordinator must always be told, and the student's safety and welfare considered in every case.

SENse Learning holds, ideally, two emergency contact numbers for each student.

16.2. 2 Missed sessions

If a student refuses a session, does not attend, or is not at home, the SENse professional will try to contact the parent or carer and tell the case coordinator, and a DSL if necessary. If there are safeguarding concerns, the DSL will decide whether further action is needed.

We log and monitor attendance. Where there are child protection concerns and a student misses a session, we will tell the local authority and the child's social worker. Where sessions are repeatedly missed, we will liaise with the local authority and the student's on-roll school. We work with families, schools and local authorities in line with the government's guidance on working together to improve school attendance.

17. Session locations and lone working

These are safeguarding requirements that apply to every session. For associates, they form part of the contract for services. See also the Lone Working Policy.

• Sessions usually take place in the student's home or in the community. Every outing or activity is risk assessed in advance, taking account of the student's needs.

• In the home, sessions take place in a communal area. SENse professionals must not enter a student's bedroom. In rare cases where a student cannot leave their room, a session may take place there for a limited time only if the Pathway Lead has agreed it, a risk assessment with safety measures is in place, and the parent or carer has agreed.

• SENse professionals must never take a student to their own home or to a space they have hired privately. Hired rooms may be used only where arranged by the case coordinator and agreed with the local authority and parent or carer.

• Session locations are confirmed before each session. Any change is shared through Google Chat with SENse Learning and the student's parents or carers.

• SENse professionals must not provide personal care, or go into bathrooms, changing rooms or other private spaces with students.

18. Children with additional vulnerabilities

18.1. 1 Special educational needs and disabilities

As a specialist provision, we recognise that children with SEND can face additional safeguarding challenges. SENse professionals must be aware of:

• the risk of assuming that indicators of possible abuse, such as behaviour, mood or injury, relate to the child's disability without further exploration;

• children with SEND being more prone to peer isolation;

• children with SEND being disproportionately affected by behaviours such as bullying, without showing outward signs; and

• communication barriers, and the difficulty of overcoming them.

SENse Learning provides information and briefings on the SEND needs relevant to the students associates are matched with.

18.2. 2 Looked-after and previously looked-after children

Looked-after and previously looked-after children may remain particularly vulnerable. The DSL will:

• make sure SENse professionals working with them have the information they need, including the child's looked-after status and contact arrangements with birth parents or those with parental responsibility;

• hold details of the child's social worker and the virtual school head for the authority that looks after them; and

• work with the virtual school head and other agencies to support the child's personal education plan, and act promptly where needed to keep the child safe.

Through our enhanced offer, we will work to promote the education of children with a social worker and children in kinship care, in line with KCSiE 2026.

18.3. 3 Children with a social worker

Children may need a social worker because of abuse, neglect or complex family circumstances. Their experiences can leave them vulnerable to further harm and facing barriers to attendance, learning, behaviour and mental health. Local authorities should tell us when a child has a social worker. The DSL will hold and use this information routinely to inform decisions about the child's safety, welfare and education, for example in responding to absence where there are known safeguarding risks.

18.4. 4 Mental health

We have an important role in supporting students' mental health and wellbeing. Mental health problems can sometimes indicate that a child has suffered, or is at risk of, abuse, neglect or exploitation. Unaddressed issues such as self-harm and suicidal thoughts can escalate into safeguarding concerns that need early intervention.

Our Wellbeing Lead is Lucy McCully. Our enhanced offer helps us manage these needs and refer students for support, and associates can use our mental health first aid kit in their work with students. Any SENse professional with a concern about a student's mental health, wellbeing or safety must discuss it with a DSL immediately.