Introduction

This policy applies to Gloucestershire College (the “College”) and Betaris Training Limited (a wholly owned
subsidiary company of Gloucestershire College). This policy is reviewed and updated annually (as a minimum).
Definitions of safeguarding and types and signs of abuse
Safeguarding and promoting the welfare of children or young people is defined as protecting children or
young people from maltreatment; preventing impairment of their health or development; ensuring that
children or young people grow up in circumstances consistent with the provision of safe and effective care;
and taking action to enable all children or young people to have the best outcomes.
Abuse is a form of maltreatment of a child or young person. Somebody may abuse or neglect a child or young
person by inflicting harm or by failing to act to prevent harm. Children or young people may be abused in a
family or in an institutional or community setting by those known to them or, by others and online. Abuse can
take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an
adult or adults or by another child/young person or children/young people (also known as peer-on-peer
abuse).
Abuse can be:
• physical abuse;
• emotional abuse;
• sexual abuse/harassment; and/or
• neglect
Staff are referred to Appendix 4 of this policy for further detail of the types of abuse and possible signs of
abuse, as well as further information regarding specific safeguarding issues such as child criminal and/or
sexual exploitation.
Commitment to safeguarding
Gloucestershire College and Betaris Training Limited take a whole-company approach and is committed to
safeguarding its students and staff. The College and Betaris Training Limited maintains the attitude of “it
could happen here” where safeguarding is concerned and ensures safeguarding and child protection underpin
all relevant aspects of process and policy development. All staff at Gloucestershire College and Betaris
Training Limited has a duty to identify any students who may be experiencing or who are at risk of
experiencing abuse or harm in College, at home, through online networks or in relationships and take
appropriate action to ensure their safety. The College and Betaris Training Limited have a duty to consider at
all times the best interest of the student and take action to enable all students to achieve the best outcomes.
Staff do not assume safeguarding or promoting welfare is someone else’s responsibility, and all staff are
responsible for reporting concerns promptly to the Safeguarding Team.
Parents are encouraged to raise any concerns directly with the College or Betaris Training Limited, if
necessary, using this safeguarding policy for concerns about the safety and/or welfare of our students.
Parents may also contact OFSTED directly if they wish.
The College and Betaris Training Limited have arrangements for listening to students and providing early help.
Details of these arrangements can be found in Appendix 1 of this policy.
Gloucestershire College and Betaris Training Limited aim to:
• Provide a safe and welcoming learning environment
• Ensure safe staff recruitment procedures built around Disclosure and Barring Service (“DBS”)
checks, through scrutiny of references and ongoing monitoring and review of practice
• Help staff and students alike to equip themselves with the information and awareness necessary
to keep themselves safe
• Maintain and explicitly promote those procedures, which help to identify suspected cases of
abuse, report and act upon them
• Provide appropriate support for students or staff if they are victims of abuse
• Contribute to effective partnership working between all those in the wider community involved
in providing safeguarding services and the College and Betaris Training Limited
• Work with those partners to provide a co-ordinated offer of help when needed
• Pay particular attention to the most vulnerable students in College and offer early help
In doing this Gloucestershire College and Betaris Training Limited shall provide and maintain a culture where
safeguarding is thoroughly understood and embraced by all members of the College and Betaris Training
Limited and applied with consistency. The College and Betaris Training Limited shall ensure that all resources
in safeguarding serve those groups identified as being vulnerable. In addition, compliance with the Equality
Act 2010 is expected by all members of the College and Betaris Training Limited, both staff and students, and
we recognise that some students with particular protected characteristics may be at higher risk than others.
Mental Health
The College and Betaris Training Limited have an important role to play in supporting the mental health and
wellbeing of its students. All staff should be aware that mental health problems can, in some cases, be an
indicator that a student has suffered or is at risk of suffering abuse, neglect or exploitation.
Staff are well placed to observe students day to day and identify those whose behaviour suggests that they
may be experiencing a mental health problem or be at risk of developing one. In the event of a mental health
concern, advice and guidance will be sought from the College’s Mental Health Lead.

1. Students and Studying

Because Safeguarding is of the utmost importance to us, students can expect the following from the College
and Betaris Training Limited:
• A safe environment to study in
• A visible, trained and informed Safeguarding Team
• Allegations taken seriously and responded to appropriately
• A rigorous approach to investigating Safeguarding concerns
• Timely referrals to Social Care if deemed appropriate and necessary
• Referrals and signposting to relevant external support agencies
• A secure and confidential recording system for disclosures
• Strong links with external support agencies
• Well trained and approachable staff
• Visible internal support links
• When on placement, organisations will be asked to put in place appropriate safeguards
• If undertaking an apprenticeship, the employer will understand their responsibilities for
safeguarding
• Where third party providers are sub contracted in to deliver training, robust safeguarding
procedures will be place
• Safeguarding information (including a copy of this policy) is available on the Betaris Training
Limited website
• Regular updates on key safeguarding themes
• To be taught about safeguarding, including online safeguarding and the safe use of technology
• The opportunity to engage in safeguarding campaigns
• That students who have SEN will be identified as being more vulnerable and therefore receive
additional pastoral support.
• That staff have the skills, knowledge and understanding necessary to keep safe students that are
looked after by a local authority.
We are confident that our students will have a safe and enjoyable learning experience.
So, ours is a company where, for example:
• Safeguarding is a number one priority
• Every member of staff is equipped to take a safeguarding disclosure
• Students are listened to and taken seriously when reporting concerns
• Ignoring a safeguarding concern is unthinkable
• All staff are aware of safeguarding reporting procedures
• Students are educated about how to report a concern
• Students have information available to them on a wealth of safeguarding topics
• If students leave the College the Local Authority is notified.

2. Staff and Working

Because Safeguarding is of the utmost importance to us, the College and Betaris Training Limited:
• Work in accordance with the Department for Education (“DfE”) guidance Keeping Children Safe
in Education 2021
• Have a Designated Safeguarding Lead (“DSL”), Carly Rosser-Mayo and a Deputy DSL Sandra
Tyrrell, who have responsibility for coordinating actions
• Has named Designated Safeguarding Officers (“DSOs”) who are regularly and appropriately
trained to work with our students following a disclosure (Vanessa Pollok /
vanessapollok@betaristraining.com)
• Trains all staff to recognise signs of abuse
• Ensures staff know how to report concerns or suspicions of abuse
• Has procedures in place for handling suspected cases of abuse of students
• Ensures staff with designated responsibility for safeguarding receive regular and appropriate
training
• The DSL/DDSL receives training in accordance with Annex C of Keeping Children Safe In Education
(“KCSIE”), including updated child protection training at least every 2 years and their knowledge
and skills are updated at least annually to keep up with any developments relevant to their role
• Trains all staff and volunteers on safeguarding on their first day and if this isn’t possible then
within the first month
• Trains all Managers on Safer Recruitment within their first 6 months of starting their managerial
role and using the DBS / Teachers’ Regulated Authority to check suitability of teachers (see
Appendix 3)
• Shows all new starters where to find safeguarding information on the intranet and website
• Informs all new staff about the safeguarding campaigns, where they can find additional
information on specific safeguarding topics
• Requires all staff to undertake an online safeguarding training module (which includes Prevent
awareness training), every two years
• All staff are provided with regular informal updates, at least annually, to provide them with
relevant skills and knowledge to safeguard our students effectively. These are provided via, for
example, safeguarding campaigns and termly newsletters.
We know that well-informed and trained staff promote a safe and healthy environment for our
students. We are better placed to support our students when we work together with the agreed
outcome of keeping our students safe. Therefore, at induction we support staff in their awareness
of safeguarding where all staff before or at induction will complete the on-line safeguarding module
(including PREVENT) and be issued with KCSIE Part 1 or Annex A and will confirm that they have read
and understood it. Betaris Training Limited Directors and staff that work directly with children or
young people are also required to read Annex B and Part 5 of KCSIE, and copies of these parts are
provided at induction.
All new staff are also directed to the safeguarding policy and details of the safeguarding team,
including the DSL and deputy DSL.

We know that because abuse does happen, and safeguarding concerns are raised we promote a
culture where, for example:
• Abuse is not acceptable
• Disclosures of abuse are taken seriously
• Students feel confident to talk to any member of staff if they are not feeling safe
Ignoring a safeguarding concern would not be acceptable in any way.
So, ours is a company where, for example
• Staff are confident when dealing with a safeguarding concern
• Extra training is available should a member of staff feel they want it
• Staff ethos is to ensure the safety of our students
• Our staff know how to report a concern and the procedures to follow

3. Leadership and Managing

Ensuring Betaris Training Limited is a safe and secure environment is the responsibility of the Board
of Directors. They will:
• Review the Safeguarding Policy at least annually (which includes Prevent) including an update
and review of the effectiveness of procedures and their implementation, including lessons learnt
• Ensure the Betaris Training Limited operates safe recruitment procedures
• Confirm the Betaris Training Limited has robust procedures in place for dealing with allegations
• Undertake regular safeguarding training
Carly Rosser-Mayo (GC) is the DSL and Sandra Tyrrell (GC) is the Deputy DSL. Their contact details can
be found in the Key Contacts section at the end of this policy.
Whilst the Board of Directors is ultimately responsible for ensuring staff are competent, supported
and regularly reviewed in relation to safeguarding, the ultimate lead responsibility for safeguarding
and child protection remains with the DSL and this responsibility should not be delegated. That being
said, the activities of the DSL can be delegated to appropriately trained deputies.
The DSL has an amendment to their job description outlining their responsibilities. The key
responsibilities are:
• Lead and develop the implementation of safeguarding policy and procedure through the effective
management of the safeguarding team;
• Ensure that the Betaris Training Limited is meeting statutory requirements and best practice by
building strong relationships with external safeguarding stakeholders including PREVENT;
• Refer incidents to third parties (including the local authority children’s services, the DBS, Channel
and the police) where appropriate; Act as a point of contact with the three safeguarding partners
and work with other agencies in line with WT;
• Liaise with the senior mental health lead where safeguarding concerns are linked to mental
health;
• Liaise with the head teacher or principal to inform him or her of issues, especially ongoing
enquiries under section 47 of the Children Act 1989 and police investigations;
• As required, liaise with the “Case Manager” (as per Part four) and the designated officer(s) at the
local authority (“LADO”) for child protection concerns in cases which concern a staff member;
• Liaise with staff and provide support (especially pastoral support staff, College nurses, IT
Technicians, and SENCOs or the named person with oversight for SEN in a college) on matters of
safety and safeguarding (including online and digital safety) and when deciding whether to make
a referral by liaising with relevant agencies; and Act as a source of support, advice and expertise
for all staff.
Full details of the DSL’s role can be found at Annex C of KCSIE.

4. Leadership from the Top

Mary James is the board-level lead designated to take a lead in relation to responsibility for the
safeguarding arrangements in the College. Contact details can be found in the Key Contacts section
at the end of this policy.
A review of the College’s and Betaris Training Limited’s child protection policies takes place at least
annually including an update and review of the effectiveness of procedures and their
implementation. The College and Betaris Training Limited draw on the expertise of staff, including
the DSL(s), in shaping the College’s and Betaris Training Limited’s safeguarding arrangements and
policies.
If there has been a substantiated allegation against a member of staff, the College and Betaris
Training Limited will work with the LADO to determine whether there are any improvements to be
made to procedures or practice to help prevent similar events in the future.

5. Local Community and Employer Engagement

The College and Betaris Training Limited work with a large number of employers on, for example,
apprenticeship schemes and work experience.
Employers will be asked to cooperate with the College and Betaris Training Limited in putting in place
and subscribing to appropriate safeguards but ultimate responsibility will still sit with the College.
The College and Betaris Training Limited ensure that when an apprentice is placed with an employer,
the employer understands their responsibilities for safeguarding particularly if they are under 18.
Working with employers and external agencies allows us to provide a holistic approach to
safeguarding our students whereby we can demonstrate:
• A commitment to safeguarding our students
• A guarantee regarding the well-being of our students
• Involvement with the local community and a commitment to keep our students safe whether
on site, on placement or in the work place
The College and Betaris Training Limited liaise with Gloucestershire Safeguarding Children’s Executive
when disclosures / allegations are made that raise causes for concern. We work with a number of
local external agencies and will signpost out to these agencies when appropriate and necessary.

6. Places and Spaces – Our Environment

Ensuring our staff and students are aware of who our Safeguarding Officers are and how to report a
concern are of paramount importance to us.
Displaying accurate information regarding our Safeguarding Team, and how to contact them makes
them visible and accessible to all – helping to create a safe environment.
Ways in which the Safeguarding Team is accessible and visible are:
• Safeguarding Officers are present on each site of the College
• Safeguarding Officers wear bright pink lanyards which distinguishes them from other staff
• Posters showing photographs of the Safeguarding Team and additional information are displayed
in reception areas, in prominent spaces and in staffrooms throughout the College.
• Designated boards for Safeguarding information can be found in central locations on all sites
• An email address specifically for safeguarding concerns is advertised throughout the College –
safeguarding@gloscol.ac.uk
• The Betaris Safeguarding officer is known to all Betaris staff
Ours is a company where, for example:
• A student can ask any member of staff for help regarding a safeguarding concern and feel
confident in their response and approach in dealing with the situation
Not every student will be safe from abuse, due to factors beyond our control, but we will do our
utmost to protect and educate both staff and students on safeguarding warning signs and make it
clear how staff and students can report any safeguarding concerns.

7. Our Safeguarding Procedures

Our duty is to provide a safe and welcoming learning environment, where students are respected and
valued and are capable of making excellent progress in their learning. We aim to provide an
environment where safeguarding is thoroughly understood and embraced by all members of the
College and Betaris Training Limited and applied with a high degree of consistency.
We are committed to helping staff and students alike to equip themselves with the information and
awareness necessary to keep themselves safe.
Safer Recruitment
We ensure safe staff recruitment procedures built around DBS checks, through scrutiny of references
and ongoing monitoring and review practice. Members of the teaching and nonteaching staff at the
College and Betaris Training Limited (including part-time staff, volunteers, temporary and supply
staff, and visiting staff, such as musicians and sports coaches) are subject to the necessary statutory
child protection checks before starting work, for example, right to work checks, additional overseas
checks (if necessary), verifying identity, taking up references, checking work history and confirming
medical fitness for the role. For most appointments, an enhanced DBS check with ‘barred list’
information will be appropriate. A DBS certificate will be obtained from the candidate before or as
soon as practicable after appointment. Alternatively, if the applicant has subscribed to it and gives
permission, the College may undertake an online update check through the DBS Update Service.
Full details of the College’s and Betaris Training Limited’s safer recruitment procedures for checking
the suitability of staff,
Governors and volunteers to work with children and young people is set out in the College’s
Recruitment and Selection Policy.
Visiting Speakers
Betaris Training Limited has clear protocols for ensuring that any visiting speakers are appropriately
supervised and suitable. Betaris Training Limited’s responsibility to students is to ensure that they
can critically assess the information they receive as to its value to themselves, and that the
information is aligned to the ethos and values of Betaris Training Limited and British values.
Visiting speakers will be expected to understand that, where appropriate, their session should
actively promote the British values of democracy, the rule of law, individual liberty and mutual
respect and tolerance of those with different faiths and beliefs and at no point undermine these.
Prevent duty
The Prevent Agenda is part of the wider counter-terrorism strategy CONTEST. The aim of the Prevent
Agenda is to stop people from taking part in, or supporting, terrorism. The College has a statutory
duty (as set out in Section 26(1) of the Counter-Terrorism and Security Act 2015) known as the
Prevent duty. The College and Betaris Training Limited must have regard to the need to prevent young
people from being drawn into terrorism, when carrying the functions of a college.

The College and Betaris Training Limited ensure regard is given to the Prevent duty throughout the
running of the College and Betaris Training Limited in a number of ways. Risk assessments are carried
out to assess any risk of students or staff being drawn into terrorism. This includes when visiting
speakers attend the College or Betaris Training Limited (as discussed above) and where external
events are held by third party individuals, external bodies or community groups. The College and
Betaris Training Limited has clear procedures and policies in place to support their Prevent duty such
as the Child Protection and Safeguarding Policy, Equality, Diversity and Inclusion Policy,
Whistleblowing Policy and [IT policy].
The College and Betaris Training Limited undertakes Prevent awareness training with all members of
staff at the point of induction and at least every two years.
Managing Allegations
The College and Betaris Training Limited are dedicated to maintaining and explicitly promoting their
safeguarding procedures, which help to identify suspected cases of abuse, reporting and acting upon
them. We will provide appropriate support to students or staff who have been the victim of abuse.
Examples of types of abuse can be found in Appendix 4.
The College’s and Betaris Training Limited procedures for dealing with concerns about a student can
be found in Appendix 1.
The process for reporting and dealing with allegations against members of staff or volunteers can be
found at Appendix 4.
In addition, we will contribute to effective partnership working between all those in the wider
community involved in providing safeguarding services and the College itself.

8. Our Values

Ambition
We want to be the very best we can become for our students – we measure our success by their
success. We value what we do because it matters. We believe that every student can achieve
regardless of their ability and aptitude.
Responsibility
Our success is built on each of us taking personal responsibility for our own actions and work and
committing to doing our best every time.
Improvement
We are committed to continuously improving everything we do for the benefit of our students. We
actively invite feedback from our customers, regularly review completed tasks to identify
opportunities to improve, are receptive to new ideas and learn from our failures as well as our
successes.
Team work
We work collaboratively utilising the different knowledge, skills and experiences we each have; we
openly communicate and resolve issues through helping not blaming each other.
Communication
Everyone is informed, listened to and involved; we take collective responsibility for achieving our
vision; we make our expectations clear.
Respect
We believe that trust, respect and civility bring out the best in people. We celebrate our differences
and treat each other and our students in ways that promote mutual respect. We respect and value
the contribution that we each make.

9. The Legal Context

Betaris Training Limited acts in accordance with the following legislation and guidance:
• Keeping Children Safe in Education September 2021
• Working Together to Safeguard Children 2018 (“WT”)
• CONTEST Counter Terrorism Strategy 2018
• Safeguarding Vulnerable Groups Act 2006
• Safeguarding Vulnerable Adults Act 2006
• The Children’s Act 1989 and 2004
• Sex Offences Act 2003
• Counter Terrorism and Security Act 2015
• Revised Prevent Duty Guidance for England and Wales (updated April 2021)
– The Prevent Duty Guidance: for further education institutions in England and Wales April 2021
– The use of social media for on-line radicalisation (July 2015)
• Gloucestershire Children’s Safeguarding Executive
• Disclosure and Barring Service 2014
• Equality Act 2010
• Children and Families Act 2014
• Procedures for Gloucestershire Children’s Safeguarding Executive
• Child Sexual Exploitation – Definition and Guide for Practitioners – 2017
• Sexual Violence and Sexual Harassment Between Children in Schools and Colleges (September
2021)
• Disqualification under the Childcare Act 2006 (August 2018)
• What to do if you’re worried a child is being abused: advice for practitioners (March 2015)
• Information sharing: advice for practitioners providing safeguarding services (July 2018)
• Sexting in schools and colleges: Responding to incidents and safeguarding young people (August
2016)
• Sharing nudes and semi-nudes: advice for education settings working with children and young
people (December 2020)
This policy also takes into account the procedures and practice of Gloucestershire County Council as
part of the inter-agency safeguarding procedures set up by the Gloucestershire Safeguarding Children
Executive.
In accordance with the DFE guidance KCSIE 2021 the College and Betaris Training Limited complies
with the following responsibilities:
• Staff are trained to recognise the signs of abuse and know to whom they should report concerns
or suspicions
• Procedures are in place (which staff are aware of) for handling suspected cases of abuse of
students, including procedures to be followed if a member of staff is accused of abuse, or
suspected abuse
• The DSL has responsibility for coordinating action in the College and Betaris Training Limited and
for liaising with other agencies
• Staff with designated responsibility for safeguarding receive appropriate training.

Approved by: Louise Lisseman, Betaris Training Limited
Date issued: September2018
Date reviewed: September 2021
Date of next Policy Review: September 2022

Appendix 1

Procedures for dealing with concerns about a child or young person

If staff suspect or hear any allegation or complaint of abuse, exploitation, or neglect from a student or any
third party, they must act immediately and follow the relevant procedure below. Staff should not assume
that somebody else will take action and share information that might be critical in keeping children and young
people safe.
The guidance, Information Sharing: Advice for Practitioners Providing Safeguarding Services to Children,
Young People, Parents and Carers supports staff who have to make decisions about sharing information. Fears
regarding sharing information under the Data Protection Act 2018 (DPA) and the UK GDPR should not be
allowed to stand in the way of the need to promote the welfare, and protect the safety of children and young
people, and neither the DPA 2018 or the UK GDPR prevent the sharing of information for the purposes of
keeping children and young people safe. If in doubt about what information can and should be shared, staff
should speak to the DSL.
All staff should:
• listen carefully
• avoid asking leading questions
• reassure the individual that the allegation/complaint will be taken seriously and that they will be
supported and kept safe
• ensure that the individual is not made to feel ashamed for making the report or given the impression
that they are creating a problem by making the report
• not guarantee absolute confidentiality (as this may ultimately not be in the best interests of the
student) and explain that the information needs to be passed to the appropriate person who will
ensure that the correct action is taken.
All concerns, discussions and decisions (together with reasons) made under these procedures should be
recorded in writing. The record should include a clear and comprehensive summary of the concern, details of
how the concern was followed up and resolved and a note of any action taken, the decision reached and the
outcome. Additionally, the record should include the date, time and place of the conversation and detail of
what was said and done by whom and in whose presence and signed by the person making it. The information
should be kept confidential and stored securely, ensuring that the file is only accessible to those who need to
see it, and is shared in accordance with the guidance set out in Parts one and two of KCSIE 2021.
Where the allegation relates to harmful sexual behaviours, if possible the disclosure should be managed with
two members of staff present (preferably one of them being the DSL or their deputy).
Where there is a safeguarding concern, the College and Betaris Training Limited will ensure the student’s
wishes and feelings are taken into account when determining what action to take and what services to
provide. This is particularly important in the context of harmful behaviours, such as sexual harassment and
sexual violence. The College manages this by providing a Student Mentor who will meet with the students on
a regular basis and raise any concerns with the Safeguarding team and through the safeguarding inbox. The
College and Betaris Training Limited operate their processes with the best interests of its student/s at the
centre.

Contextual Safeguarding

Safeguarding incidents and/or behaviours can be associated with factors outside the College and Betaris
Training Limited and can occur between students outside College and Betaris Training Limited. All staff, but
especially the DSL and any deputies, should consider the context within which such incidents and/or
behaviours occur. The College and Betaris Training Limited will, as part of the wider assessment of students,
consider whether environmental factors are present in a student’s life that are a threat to their safety and/or
welfare. The College and Betaris Training Limited will share as much information with Children’s Social Care
as possible as part of the referral process to enable consideration of all the available evidence and the full
context of any abuse.

Early Help

Any child or young person may benefit from early help but all staff should be particularly alert to the potential
need for early help for a child or young person who:
• Is disabled or has certain health conditions and has specific additional needs
• Has special educational needs (whether or not they have a statutory education, health and care plan)
• Has a mental health need
• Is a young carer
• Is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement
and association with organised crime groups or county lines
• Is frequently missing/goes missing from care or from home
• Is misusing drugs or alcohol themselves
• Is at risk of modern slavery, trafficking or sexual or criminal exploitation
• Is in a family circumstance presenting challenges for the student, such as substance abuse, adult
mental health problems or domestic abuse
• Has returned home to their family from care
• Is showing early signs of abuse and/or neglect
• Is at risk of being radicalised or exploited
• Has a family member in prison, or is affected by parental offending;
• Is experiencing, or is at risk of experiencing family ostracism
• Is at risk of ‘honour’-based abuse such as Female Genital Mutilation or Forced Marriage;
• Is a privately fostered child or young person; and
• Is persistently absent from education, including persistent absences
Early help means providing support as soon as a problem emerges at any point in a child or young person’s
life, from the foundation years through to the teenage years.
In the first instance, staff who consider that a student may benefit from early help should discuss this with a
Safeguarding Officer from the safeguarding team. The Safeguarding Officer will consider the appropriate
action to take in accordance with the Gloucestershire Safeguarding Children Executive referral threshold
document. The Safeguarding Officer will liaise with external agencies and professionals in an inter-agency
assessment, as appropriate. If early help is appropriate, the matter will be kept under review and
consideration given to a referral to children’s social care if the student’s situation does not appear to be
improving.

What staff should do if they have concerns about a child or young person

If staff (including governors, supply staff, agency staff and volunteers) have any concerns about a student (as
opposed to a student being in immediate danger), they should, where possible, speak with a member of the
safeguarding team to agree a course of action, although staff can make a direct referral to children’s social
care. As set out above, staff should not assume that somebody else will take action and share information
that might be critical in keeping children or young people safe; they should maintain an attitude of “it could
happen here”. If anyone other than the safeguarding team make a referral, they should inform the DSL as
soon as possible that a referral has been made. If a student’s situation does not appear to be improving, the
DSL should press children’s social care for reconsideration. Staff should challenge any inaction and follow
this up with the DSL and children’s social care as appropriate. All concerns, discussions and decisions made
and the reasons for those decisions should be recorded in writing.

What staff should do if a child or young person is in danger or at risk of harm

If staff (including governors, supply staff, agency staff and volunteers) believe that a student is in immediate
danger or at risk of harm, they should make an immediate referral to children’s social care and/or the Police.
Anyone can make a referral. Any such referral must be made immediately and in any event within 24 hours
(one working day) of staff being aware of the risk. Parental consent is not needed for referrals to statutory
agencies such as the emergency services. If anyone other than the DSL makes a referral, they should inform
the DSL as soon as possible that a referral has been made. The local authority social worker should
acknowledge receipt to the referrer within 24 hours and make a decision about the next steps and type of
response required. Staff should challenge any inaction and follow this up with the DSL and children’s social
care as appropriate. All concerns, discussions and decisions made and the reasons for those decisions should
be recorded in writing.
The College’s Local Safeguarding Children Executive is Gloucestershire. A full copy of their local procedures
can be found here.

What staff should do if a child or young person is seen as at risk of radicalisation

Staff should follow the College’s and Betaris Training Limited’s normal referral processes when there are
concerns about children or young people who may be at risk of being drawn into terrorism, as set out above.
This may include a referral to Channel or children’s social care depending on the level of risk. However, if staff
have concerns that there is an immediate/significant risk of a child or young person being drawn into
terrorism they must call 999 and submit a referral to the MASH. Advice and support can also be sought from
children’s social care.
The College and Betaris Training Limited, in recognition that students may be at risk of being drawn into
terrorism or other forms of extremism, carry out appropriate risk assessments (following consultation with
local partners, such as the Police) of the potential risk in the local area. Such risk assessments are discussed
with the Principal, DSL and Governor responsible for safeguarding to ensure the College’s and Betaris Training
Limited’s safeguarding arrangements are sufficiently robust to help prevent and protect children and young
people from being drawn into terrorism and are regularly revised.

What staff should do if they discover an act of Female Genital Mutilation (“FGM”)

Staff must report to the Police cases where they discover that an act of FGM appears to have been carried
out. Unless the member of staff has a good reason not to, they should still consider and discuss any such case
with DSL and involve children’s social care as appropriate. Staff are referred to Appendix 4 of this policy for
the procedure to be followed where they suspect that a student may be at risk of FGM.

What staff should do if they have concerns that children or young people are at risk from or involved with
serious violent crime

All staff should be aware of indicators which may signal that children or young people are at risk from, or are
involved with serious violent crime. These may include increased absence from College, a change in
friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, signs of assault or unexplained injuries.
If staff have any concerns about a child or young person (as opposed to being in immediate danger), they
should, where possible, speak with a member of the safeguarding team to agree a course of action, although
staff can make a direct referral to children’s social care.

What staff should do if a child or young person goes missing from education

Children or young people who go missing from education, particularly persistently, can be a vital warning sign
to a range of safeguarding issues, including abuse, neglect, sexual abuse and child sexual and/or criminal
exploitation. It is therefore important that the College’s and Betaris Training Limited’s response to such
absence supports identifying such abuse and helps prevent the risk of them going missing in the future.
Where reasonably possible, the College and Betaris Training Limited will hold more than one emergency
contact number for each student to provide the College and Betaris Training Limited with additional options
to make contact with a responsible adult particularly when a student missing from education is also identified
as a welfare and/or safeguarding concern.
Betaris Training Limited will report to the Gloucestershire College Safeguarding Team a student who fails to
attend college regularly or has been absent from class without the Betaris Training Limited‘s permission for a
continuous period of 4 weeks or more.

How should staff respond to an incident of nudes and semi-nudes being shared by pupils

All members of staff in an education setting have a duty to recognise and refer any incidents involving nudes
and semi-nudes and will be equipped with the necessary safeguarding training and support to enable them
to recognise concerns.
For this purpose, ‘sharing nudes/semi-nudes’ means the sending or posting of nude or semi-nude images,
videos, or live streams by children and young people under the age of 18 online. This could be via social media
(including Snapchat), gaming platforms, chat apps (including WhatsApp and iMessage) or forums. It could also
involve sharing between devices via services like Apple’s AirDrop which works offline. The sharing of nudes
and semi-nudes may happen publicly online, in 1:1 messaging or via group chats and/or via closed social
media accounts. The images, videos or live streams may include more than one child or young person.
Any direct disclosure by a student will be taken seriously and staff will ensure the student is feeling
comfortable and will only ask appropriate and sensitive questions, in order to minimise further distress or
trauma to them.
If staff are notified or become aware of an incident of nudes or semi-nudes being shared by a student or of a
student, they should refer the incident to the [DSL] as soon as possible.
The DSL will follow the DDMSC / UKIS guidance “Sharing nudes and semi-nudes: advice for education settings
working with children and young people” (December 2020) when responding to a report of sharing nudes
and/or semi-nudes. This will include:
– Holding an initial review meeting with appropriate staff. This may include the staff member(s) who
heard the disclosure and the safeguarding team who deal with safeguarding concerns.
– Carrying out interviews with the student involved (if appropriate).
– Informing parents and carers at an early stage and keep them involved in the process in order to best
support the student unless there is good reason to believe that involving them would put the child or
young person at risk of harm. Any decision not to inform them should be made in conjunction with
other services such as children’s social care and/or the police, who would take the lead in deciding
when they should be informed.
– Carrying out a risk assessment to determine whether there is a concern that a child or young person
has been harmed or is at risk of immediate harm at any point in the process
– If not, the incident can be handled in college in accordance with the “sharing nudes” guidance and
the College’s and Betaris Training Limited’s Child Protection and Behaviour policies.
– If it is determined that there is a risk of harm, the DSL must make a referral to children’s social care
and/or the police immediately.
All incidents relating to nudes and semi-nudes being shared need to be recorded, whether they have been
referred externally or not. Betaris Training Limited must record the reason for not reporting incidents
externally and ensure it is signed off by the Director. Records will be kept in line with statutory requirements
set out in KCSIE and local safeguarding procedures. No copies of imagery will be taken or retained. This
guidance does not apply to the sharing of images of children or young people under 18 by an adult over 18 as
this constitutes child sexual abuse. In the event that staff become aware of such an incident, they should
notify the DSL immediately, who should always inform the Police as a matter of urgency.

What staff should do if a student needs a social worker (Children in Need and Child Protection Plans)

Students may need a social worker due to safeguarding or welfare needs. Students may need this help due
to abuse, neglect and complex family circumstances. A student’s experiences of adversity and trauma can
leave them vulnerable to further harm, as well as educationally disadvantaged in facing barriers to
attendance, learning, behaviour, and mental health.
Local authorities should share the fact a student has a social worker, and the DSL should hold and use this
information so that decisions can be made in the best interests of the student’s safety, welfare, and
educational outcomes. This should be considered as a matter of routine.
Where students need a social worker, this should inform decisions about safeguarding (for example,
responding to unauthorised absence or missing education where there are known safeguarding risks) and
about promoting welfare (for example, considering the provision of pastoral and/or academic support,
alongside action by statutory services).

What staff should do if they have concerns about another staff member

If staff have any concerns about another staff member (including supply staff, agency staff, volunteers and
contractors), then this should be referred to the Executive Director. Where there are concerns about the
Director, this should be referred to the Chair of Governors. In the event of allegations of abuse being made
against staff are referred to the procedures set out in Appendix 4 regarding managing allegations of abuse
against staff (including supply staff, agency staff, volunteers and contractors) and refer the matter directly to
the LADO at the Gloucestershire County Council. The contact details for the LADO can be found on the Key
Contacts page at the start of this policy.

What staff should do it they have concerns about safeguarding practices in the College and Betaris Training Limited

The College and Betaris Training Limited aim to ensure there is a culture of safety and raising concerns and
an attitude of ‘it could happen here’. Where staff have concerns about poor or unsafe practices and potential
failures in the College’s and Betaris Training Limited’s safeguarding systems, these should be raised in
accordance with the College’s and Betaris Training Limited’s whistleblowing. There will be no disciplinary
action taken against a member of staff for making such a report provided that it is done in good faith.
If staff and volunteers feel unable to raise an issue with the College and Betaris Training Limited or feel that
their genuine concerns are not being addressed, they may use other whistleblowing channels, such as the
NSPCC whistleblowing advice line. Contact details for the NSPCC helpline can be found on the Key Contacts
page at the start of this policy.

ARRANGEMENTS FOR DEALING WITH PEER-ON-PEER ALLEGATIONS (INCLUDING PEER ON PEER SEXUAL
VIOLENCE AND HARASSMENT)

Peer-on-peer abuse is abuse by one or more children or young people against another child or young person.
It can be standalone or as part of wider abuse and can happen both inside and outside of Betaris Training
Limited, and online. It can manifest itself in many ways and can include abuse within intimate partner
relationships, bullying (including cyber bullying, prejudice-based and discriminatory bullying), physical abuse,
initiation/hazing type violence and rituals, upskirting, sexting, sexual assault, gender-based issues, harmful
sexual behaviours including peer on peer sexual violence and sexual harassment, causing someone to engage
in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage
in sexual activity with a third party.
Children and young people can also abuse their peers online and this can take the form of abusive, harassing
and misogynistic messages, the consensual and non-consensual sharing of nudes and/or semi nudes and
indecent images, especially around group chats, and the sharing of abusive images and pornography, to those
who do not wish to receive such content.
These arrangements apply to all reports and concerns of peer on peer abuse, whether they have happened
in class or outside of it, and/or online. Abuse that occurs online or outside of class should not be downplayed
and should be treated equally seriously.
Staff will address inappropriate behaviour (even if it appears to be relatively innocuous) to help prevent
problematic, abusive and/or violent behaviour in the future. Abusive comments and interactions should never
be passed off or dismissed as “banter” or “part of growing up”. Nor will harmful sexual behaviours be
dismissed as the same or “just having a laugh” or “boys being boys”. Staff will also challenge physical
behaviours (that are potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, pulling
down trousers, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising
them.
The College and Betaris Training Limited acknowledge that even if there have been no reported cases of peer
on peer abuse in relation to students, such abuse may still be taking place and is simply not being reported.
The College and Betaris Training Limited will ensure that students are aware of how they can report abuse,
and that they are aware of the procedures that the College and Betaris Training Limited will follow once a
report has been made. These procedures will be well promoted and in a format that is easily accessible and
easily understood by students.
The College and Betaris Training Limited recognise that a student is likely to disclose an allegation to someone
they trust: this could be any member of staff. By making such a disclosure the student is likely to feel that the
member of staff is in a position of trust. The College and Betaris Training Limited also recognise that students
may not find it easy to tell staff about their abuse verbally and that instead they may show signs or act in ways
they hope adults will notice and react to. It is also recognised that an incident may come to a member of
staff’s attention through a report of a friend, or by overhearing conversations. It is therefore important that
all staff are clear on the College’s and Betaris Training Limited’s policy and procedures with regards to peer
on peer abuse, and can recognise the indicators and signs of peer on peer abuse and know how to identify it
and how to respond to reports.
The College and Betaris Training Limited recognise that a first disclosure to a trusted adult may only be the
first incident reported. It is not necessarily representative of a singular incident. Staff will take all reports of
abuse seriously regardless of how long it has taken for the child or young person to come forward. Staff will
act immediately and will support the victim when they raise a concern.
The College and Betaris Training Limited recognise that children or young people with special educational
needs and disabilities (SEND) or certain health conditions can face additional safeguarding challenges and
may be more prone to peer on peer group isolation or bullying (including prejudice-based bullying) than other
children or young people. The College and Betaris Training Limited will consider extra pastoral support for
those students from a member of the safeguarding team who specialises in such support.
Where an issue of student behaviour or bullying gives ‘reasonable cause to suspect that a child or young
person is suffering, or is likely to suffer, harm’, staff should follow the procedures below rather than the
College’s and Betaris Training Limited’s Anti-Bullying and Behaviour policies.
A student against whom an allegation of abuse has been made may be suspended from the class during the
investigation. The Betaris Training Limited will take advice from the Gloucestershire Safeguarding Children
Executive on the investigation of such allegations and will take all appropriate action to ensure the safety and
welfare of all students involved including the alleged victim and perpetrator/s. If it is necessary for a student
to be interviewed by the Police in relation to allegations of abuse, the Betaris Training Limited will ensure
that, subject to the advice of the Gloucestershire Safeguarding Children Executive, parents are informed as
soon as possible and that the students involved are supported during the interview by an appropriate adult
and until the investigation is completed. Confidentiality will be an important consideration for the College
and Betaris Training Limited and advice will be sought as necessary from Gloucestershire Safeguarding
Children Executive and/ or the Police as appropriate. The College and Betaris Training Limited will have regard
to the procedures set out in KCSIE and the Sexual Violence and Sexual Harassment Between Children in
Schools and Colleges advice (September 2021) (“SVSH”) at all times.
Police may be informed of any harmful sexual behaviours which are potentially criminal in nature, such as
grabbing bottoms, breasts and genitalia. Rape, assault by penetration and sexual assaults will be passed to
the police. Where a report has been made to the police, the College and Betaris Training Limited will consult
the police and agree what information can be disclosed to staff and others, in particular, the alleged
perpetrator(s) and their parents or carers. If the DSL decides to make a referral to children’s social care and/or
a report to the police against a victim’s wishes, the reasons should be explained to the student and
appropriate specialist support offered. The DSL may also decide that the children or young people involved
may benefit from early help, and may make the necessary referral in accordance with the Gloucestershire
Safeguarding Children Executive referral process.
The College and Betaris Training Limited will respond to incidents of sexting in line with the procedure as set
out in the “Sexting in schools and colleges: Responding to incidents and safeguarding young people” guidance
produced by the UK Council for Internet Safety, available here.
In the event of disclosures about peer-on-peer abuse (including sexting), all students involved (both victim
and perpetrator) will be treated as being at risk, and safeguarding procedures in accordance with this policy
will be followed. Victims will be supported by the Deputy DSL and support from external agencies will be
sought, as appropriate.
When there has been a report of sexual violence, the DSL will make an immediate risk and needs assessment.
Where there has been a report of sexual harassment, the need for a risk assessment should be considered on
a case-by-case basis. The risk and needs assessment should consider:
• the victim;
• whether there may have been other victims;
• the alleged perpetrator(s); and
• all the other students (and, if appropriate, staff) in the class especially any actions that are
appropriate to protect them from the alleged perpetrator(s), or from future harms.
Risk assessments will be recorded (written or electronic) and kept under review. In relation to a report of
sexual violence or sexual harassment, the DSL (and indeed all staff) will reassure any victim that they are being
taken seriously and that they will be supported and kept safe. The victim will never be made to feel ashamed
for making a report nor will they be given the impression that they are creating a problem by reporting sexual
violence or sexual harassment; nor would a victim ever be made to feel ashamed for making a report or have
their experience minimised. The College and Betaris Training Limited will consider the age and the
developmental stage of the victim, the nature of the allegations and the potential risk of further abuse. The
College and Betaris Training Limited acknowledge that, by the very nature of sexual violence and sexual
harassment, a power imbalance is likely to have been created between the victim and alleged perpetrator(s).
The DSL will consider the risks posed to students and put adequate measures in place to protect them and
keep them safe and to ensure their educational attainment is not adversely affected as far as is possible. This
may include careful consideration of the proximity of the victim and alleged perpetrator and considerations
regarding shared classes, sharing learning premises (including during any before or after class-based activities)
and College transport. The College and Betaris Training Limited will also consider the risks posed to the victim
from other health needs, including physical, mental and sexual health problems, as well as unwanted
pregnancy which may arise as a result of the incident, and will consider recommending additional support.
The College and Betaris Training Limited will reflect on reported concerns, including the decisions made and
actions taken, in order to identify any patterns of concerning, problematic of inappropriate behaviour which
may indicate an unacceptable culture, or any weaknesses in the College’s and Betaris Training Limited’s
safeguarding system which may require additional training or amendments to relevant policies. Where a
pattern is identified the College and Betaris Training Limited will decide on an appropriate course of action.
In the event that a report is proven to be false, unsubstantiated, unfounded or malicious, the DSL will consider
whether the student and/or the person who has made the allegation is in need of help or may have been
abused by someone else and this is a cry for help. In such circumstances, a referral to children’s social care
may be appropriate. If a report is shown to be deliberately invented or malicious, the Executive Director will
consider whether any disciplinary action is appropriate against the individual who made it in accordance with
the College’s and Betaris Training Limited’s behaviour policy.

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