1. Purpose & Aims

1. The purpose of Company 57’s safeguarding policy is to ensure everyone is protected from harm. This means we will always work to:

• Protect children, young people & vulnerable adults at our venues from maltreatment;

• Prevent impairment of our children’s and young people’s mental and physical health or development;

• Ensure that children and young people at Company 57 grow up in circumstances consistent with the provision of safe and effective care;

• Undertake that role so as to enable children and young people at Company 57 have the best outcomes.

This policy will give clear direction to all staff about expected behaviour and our legal responsibility to safeguard and promote the welfare of all children, young people & vulnerable adults at Company 57.

We fully recognise the contribution we can make to protect children, young people & vulnerable adults from harm and to support and promote the welfare of all children, young people & vulnerable adults who attend our venues.  The elements of our policy are prevention, protection and support.

2. Our Ethos

2.1 Company 57 believes that it is always unacceptable for a child, young person or vulnerable adult to experience abuse of any kind and recognises its responsibility to safeguard the welfare of all children, young people & vulnerable adults, by a commitment to practice which protects them.

Children, young people & vulnerable adults will be able to talk freely to any member of staff if they are worried or concerned about something. All staff will reassure victims that they are being taken seriously and that they will be supported and kept safe. Victims will never be given the impression that they are creating a problem by reporting abuse, sexual violence or sexual harassment.

2.2 Everyone who comes into contact with children, young people & vulnerable adults and their families has a role to play in safeguarding. All staff are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a child, young person or vulnerable adult, staff members must always act in the best interests of the child, young person or vulnerable adult.

2.3 At Company 57 we ensure that safeguarding and child protection is at the forefront and underpins all relevant aspects of process and policy development.

2.4 Where there is a safeguarding concern, the child’s, young person’s or vulnerable adult’s wishes and feelings are taken into account when determining what action to take and what services to provide. The systems we have in place are well promoted, easily understood and easily accessible for children, young people & vulnerable adults to confidently report abuse, knowing their concerns will be treated seriously, and knowing they can safely express their views and give feedback.

2.5 All staff will, through training and induction, know how to recognise indicators of concern, how to respond to a disclosure from a child, young person or vulnerable adult and how to record and report this information. We will not make promises to anyone and we will not keep secrets.  Every child, young person or vulnerable adult will know what the staff member will have to do with any information they have chosen to disclose. All staff will be trained to recognise that children, young people & vulnerable adults may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful.

2.6 As part of our responsibilities for safeguarding and promoting the welfare of children, young people & vulnerable adults we will provide a co-ordinated offer of early help when additional needs of children, young people & vulnerable adults are identified. These may include if a child, young person or vulnerable adult:

• is disabled 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;

• is frequently missing/goes missing from care or from home;

• is misusing drugs or alcohol themselves;

• is at risk of modern slavery, trafficking or exploitation;

• is in a family circumstance presenting challenges for the child, 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;

• is at risk of ‘honour’-based abuse such as Female Genital Mutilation or Forced Marriage;

• is a privately fostered child

• has a family member in prison, or is affected by parental offending;

• is persistently absent from education

2.7 At Company 57 we understand the importance of working in a way that adheres to the following legislation:

• The Human Rights Act 1998

• Equality Act 2010

• Public Sector Equality Duty

This means we do not unlawfully discriminate against anyone in our community because of their sex, race, disability, religion or belief, gender reassignment, pregnancy and maternity, or sexual orientation (protected characteristics).

3. Roles & Responsibilities

Role: Designated Safeguarding Lead

Name: Eve Naughton

Contact Details: info@company57.com

3.1 It is the responsibility of every member of staff to ensure that they carry out the requirements of this policy and, at all times, work in a way that will safeguard and promote the welfare of all children, young people and vulnerable adults.

The Designated Safeguarding Lead (DSL)

3.2 The Designated Safeguarding Lead is a senior member of staff who takes lead responsibility for safeguarding and child protection. The DSL will carry out their role in accordance with the responsibilities outlined in Annex C of ‘Keeping Children Safe in Education’.

3.3 The DSL will provide advice and support to other staff on child welfare and child protection matters. Any concern for a child’s safety or welfare will be recorded via My Concern.

3.4 The DSL will maintain records and child protection files ensuring that they are kept confidential and stored securely

3.6 The DSL is responsible for ensuring that all staff members and volunteers are aware of our policy and the procedure they need to follow.

4. Procedures For Managing Concerns

4.1 Company 57 adheres to child protection procedures that have been agreed locally through the Norfolk Safeguarding Children Partnership. Where we identify children and families in need of support, we will carry out our responsibilities in accordance with Norfolk Local Assessment Protocol and the Norfolk Threshold Guidance.

4.2 Every member of staff working with children, young people and vulnerable adults are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a child, young person or vulnerable adult, staff members should always act in the interests of the child, young person or vulnerable adult and have a responsibility to take action as outlined in this policy.

4.3 All staff are encouraged to report any concerns that they have and not see these as insignificant. On occasions, a referral is justified by a single incident such as an injury or disclosure of abuse. More often however, concerns accumulate over a period of time and are evidenced by building up a picture of harm over time; this is particularly true in cases of emotional abuse and neglect. In these circumstances, it is crucial that staff record and pass on concerns in accordance with this policy immediately to allow the DSL to build up a picture and access support for the child, young person or vulnerable adult at the earliest opportunity. A reliance on memory without accurate and contemporaneous records of concern could lead to a failure to protect.

4.4 It is not the responsibility of staff to investigate welfare concerns or determine the truth of any disclosure or allegation. All staff, however, have a duty to recognise concerns and pass the information on in accordance with the procedures outlined in this policy.

4.5 The Designated Safeguarding Lead (DSL) should be used as a first point of contact for concerns and queries regarding any safeguarding concern. Any member of staff who receives a disclosure of abuse or suspects that a child is at risk of harm must report it immediately to the DSL or, if unavailable, to the alternate designated person. In the absence of either of the above, the matter should be brought to the attention of the most senior member of staff.

4.6 All concerns about a child, young person or vulnerable adult should be reported without delay and recorded in writing using the My Concern reporting system. Records should include:

• a clear and comprehensive summary of the concern

• details of how the concern was followed up and resolved

• a note of any action taken, decisions reached and the outcome 

Following receipt of any information raising concern, the DSL will consider what action to take and seek advice from the Norfolk Children’s Advice & Duty Service (CADS) as required. All information and actions taken, including the reasons for any decisions made, will be fully documented. 

Company 57 will share information regarding disclosures or concerns with the participants’ school / home educators team or other commissioners involved in the participant’s wellbeing or care without delay.

All referrals will be made in line with Norfolk Children’s Services procedures.

If, at any point, there is a risk of immediate serious harm to a child, young person or vulnerable adult a referral should be made to Norfolk CADS immediately. Anybody can make a referral in these circumstances. If the situation does not appear to be improving the staff member with concerns should press for re-consideration by raising concerns again with the DSL. Concerns should always lead to help at some point.

Staff should always follow the reporting procedures outlined in this policy in the first instance. However, they may also share information directly with Norfolk CADS, or the police if:

• the situation is an emergency and the designated senior person, their alternate and the Chair of the Board are all unavailable;

• they are convinced that a direct report is the only way to ensure safety.

4.7 Any member of staff who does not feel the situation has been addressed appropriately at this point should contact Norfolk CADS directly with their concerns (Please see back of policy for CADS information).

5. Specific Safeguarding Issues

Contextual safeguarding

5.1 At Company 57 we recognise that safeguarding incidents and/or behaviours can be associated with factors outside of the venue environment. This is known as contextual safeguarding. It is key that all staff understand the definition of contextual safeguarding and consider whether children, young people or vulnerable adults are at risk of abuse or exploitation in situations outside their families. Through training we will ensure that staff are aware that extra-familial harms take a variety of different forms and children, young people or vulnerable adults can be vulnerable to multiple harms including (but not limited to) sexual exploitation, criminal exploitation, and serious youth violence.  When reporting concerns, staff should include as much information and background detail as possible so the DSL can make a referral with a holistic view of the child. This will allow any assessment to consider all the available evidence and the full context of any abuse.

5.2 We recognise that children, young people and vulnerable adults with special educational needs and/or disabilities (SEND) can face additional safeguarding challenges and these are discussed in staff training.  These additional barriers can include:

• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the disability without further exploration;

• children, young people and vulnerable adults with SEN and disabilities can be disproportionally impacted by things like bullying- without outwardly showing any signs; and

• communication barriers and difficulties in overcoming these barriers.

5.3 At Company 57 we recognise that a previously looked after child potentially remains vulnerable and all staff should have the skills, knowledge and understanding to keep previously looked after children safe. When dealing with looked after children and previously looked after children, it is important that all agencies work together, and prompt action is taken when necessary to safeguard these children, who are a particularly vulnerable group.

Child Sexual Exploitation (CSE), Child Criminal Exploitation (CCE):

County Lines and serious violence

5.4 At Company 57 we train staff to recognise that both CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources. Victims can be exploited even when activity appears consensual and it should be noted exploitation as well as being physical can be facilitated and/or take place online.

5.5 At Company 57 we recognise that Child Sexual Exploitation is a form of child sexual abuse and this imbalance of power coerces, manipulates or deceives a child or young person into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator. Child sexual exploitation does not always include physical contact, it can also occur through the use of technology.  We understand that some children may not realise they are being exploited e.g. they may believe they are in a genuine romantic relationship.

5.6 At Company 57 we understand that criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity. Drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked for the purpose of transporting drugs.

5.7 We understand that children, young people and vulnerable adults can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. We will treat these children as victims understanding that they have been criminally exploited even if the activity appears to be something they have agreed or consented to. We recognise the experience of girls who are criminally exploited can be very different to that of boys and that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

5.8 At Company 57 staff are aware of the indicators and risk factors which may signal a child or young person is vulnerable to or involved with serious violent crime. We make reference to the Home Office’s Preventing youth violence and gang involvement and Criminal exploitation of children and vulnerable adults: county lines guidance for more information.

5.9 If a child or young person is suspected to be at risk of or involved in county lines, a referral to the Children’s Advice and Duty Service (CADS) will be made alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation.   

So-called ‘honour-based violence (including Female Genital Mutilation and Forced Marriage)

5.10 At Company 57 we recognise that our staff are well placed to identify concerns and take action to prevent children from becoming victims of Female Genital Mutilation (FGM) and other forms of so-called ‘honour-based’ violence (HBV) and provide guidance on these issues through our safeguarding training. If staff have a concern regarding a child that might be at risk of HBV, they should inform the DSL who will activate local safeguarding procedures, using existing national and local protocols for multiagency liaison with police and children’s social care.

5.11 Where FGM has taken place, since 31 October 2015 there has been a mandatory reporting duty placed on teachers. Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) places a statutory duty upon teachers in England and Wales, to report to the police where they discover (either through disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Those failing to report such cases will face disciplinary sanctions. We will provide guidance and support to our teachers on this requirement and further information on when and how to make a report can be found in the following Home Office guidance: Mandatory Reporting of Female Genital

Mutilation- procedural information  Home Office (January 2020)

5.12 At Company 57 we recognise that forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. Since February 2023 it has also been a crime to carry out any conduct whose purpose is to cause a child to marry before their eighteenth birthday, even if violence, threats or another form of coercion are not used. The Forced Marriage Unit has statutory guidance and Multi-agency guidelines and can be contacted for advice or more information: Contact 020 7008 0151 or email fmu@fco.gov.uk

Preventing radicalisation and extremism

5.13 We recognise that safeguarding against radicalisation and extremism is no different to safeguarding against any other vulnerability in today’s society.  At the Company 57, we will ensure that:

• Through training, staff, have an understanding of what radicalisation and extremism is, why we need to be vigilant and how to respond when concerns arise.

• There are systems in place for keeping us all safe from extremist material when accessing the internet by using effective filtering and usage policies.

• The DSL has received Prevent training and will act as the point of contact within our school for any concerns relating to radicalisation and extremism.

• The DSL will make referrals in accordance with Norfolk Channel Procedures and will represent our school at Channel meetings as required.   

Child on child sexual violence and sexual harassment

5.14 At Company 57 all staff are trained so that they are aware that safeguarding issues can manifest themselves via child on child abuse. This is most likely to include, but may not be limited to:

• bullying (including cyberbullying);

• physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm;

• sexual violence and sexual harassment;

• upskirting;

• sexting (also known as youth produced sexual imagery); and

• initiation/hazing type violence and rituals.

We recognise that children, young people and vulnerable adults are vulnerable to physical, sexual and emotional abuse by other children or siblings. Abuse perpetrated by children can be just as harmful as that perpetrated by an adult, so it is important that all staff remember the impact on both the victim of the abuse as well as to focus on the support for the child or young person exhibiting the harmful behaviour. We understand that abuse can occur in intimate personal relationships between children; and that consensual and non-consensual sharing of nudes and semi nude images and or videos1 (also known as sexting or youth produced sexual imagery) is a form of child on child abuse.

We understand, that even if there are no reports in our setting it does not mean it is not happening, it may be the case that it is just not being reported. We recognise that children, young people and vulnerable adults may not find it easy to tell staff about their abuse and can show signs or act in ways that they hope adults will notice and react to. In some cases, the victim may not make a direct report, and this may come from a friend or a conversation that is overheard.  Such abuse will always be taken as seriously as abuse perpetrated by an adult and the same safeguarding children procedures will apply in respect of any child who is suffering or likely to suffer significant harm. Staff must never tolerate or dismiss concerns relating to child on child abuse and they will always challenge this. It must never be tolerated or passed off as ‘banter’, ‘just having a laugh’ or ‘part of growing up’. Doing this can lead to a culture of unacceptable behaviours, an unsafe environment for children and in worst case scenarios a culture that normalises abuse leading to children accepting it as normal and not coming forward to report it.

At Company 57 we regularly review decisions and actions and relevant policies are updated to reflect any lessons learnt. We look out for potential patterns of concerning, problematic or inappropriate behaviour. Where a pattern is identified, we decide upon an appropriate course of action.

At Company 57 all staff will reassure victims that they are being taken seriously and that they will be supported and kept safe. Victims will never be given the impression that they are creating a problem by reporting abuse, sexual violence or sexual harassment. Nor will a victim ever be made to feel ashamed for making a report. We will also offer appropriate support to the perpetrator and any other children involved.

All staff will understand that they should follow our safeguarding procedures for reporting a concern if they are worried about child on child abuse. The DSL will respond to any concerns related to child on child abuse in line with guidance outlined in Part five of ‘Keeping Children Safe in Education’. We will ensure that all concerns, discussions and decisions reached are clearly recorded and any identified actions are followed up.

We will work with other agencies including the police and Children’s Social Care, as required to respond to concerns about sexual violence and harassment.  We will seek consultations where there are concerns or worries about developmentally inappropriate or harmful sexual behaviour from the Harmful Sexual Behaviour (HSB) Team as required so that we ensure we are offering the right support to the child(ren).   

Support will depend on the circumstances of each case and the needs of the child, young person or vulnerable adult, it may include completion of risk assessments, delivery of early intervention in respect of HSB and/or referral to The Harbour Centre Sexual Assault Referral Centre (SARC) where a child, young person or vulnerable adult discloses a rape, an attempted rape or a serious sexual assault whether this has happened recently or in the past. The assault does not have to have taken place in Norfolk but the victim must live in Norfolk to access support. The SARC also has a 24/7 helpline 01603 276381 if pupils or staff need to speak to a Crisis Worker for help & advice. Referral forms can be found on The Harbour Centre website.

Modern Slavery

5.22 At Company 57 we understand that modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. We refer to the DfE guidance Modern slavery: how to identify and support victims for concerns of this nature.

Safeguarding responses to children who go missing

6.23 At Company 57 staff should be aware of the safeguarding responsibilities for children who are missing education, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual abuse or exploitation, and to help prevent the risks of their going missing in future.

5.24 At Company 57 we adhere to the following procedures and processes to ensure there is an appropriate safeguarding response to children who are missing:

• Our tutors are trained to identify, monitor and follow up regular nonattendance

• We make every effort to contact parents and carers and follow up with the emergency contacts held

• We hold emergency contacts for all our participants

Mental Health

5.25 At Company 57 all staff are made aware, through training, that mental health problems can, in some cases, be an indicator that a child, young person or vulnerable adult has suffered or is at risk of suffering abuse, neglect or exploitation. Our staff are well placed to observe and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.   

5.26 We understand that where children have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. Therefore, through training, staff are aware of how children’s experiences, can impact on their mental health, behaviour and education. All staff are aware that if they have a mental health concern about a child, young person or vulnerable adult that is also a safeguarding concern, they should take immediate action by passing the information on to a Designated Safeguarding Lead.

Online Safety

5.28 At The Garage Trust all staff are aware that technology is a significant component in many safeguarding and wellbeing issues. Children, young people and vulnerable adults are at risk of abuse online as well as face to face. We understand that in many cases abuse will take place concurrently via online channels and in daily life. We know that children can also abuse other children online, this can take the form of abusive, harassing, and misogynistic messages, the non-consensual sharing of indecent images, especially around chat groups, and the sharing of abusive images and pornography.

Cybercrime

5.29 We understand that cybercrime is criminal activity committed using computers and/or the internet. It is broadly categorised as either ‘cyberenabled’ (crimes that can happen off-line but are enabled at scale and at speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer). We are aware of the Cyber security standards for schools and colleges.GOV.UK 

5.30 If there are concerns about a child, young person or vulnerable adult in this area, the designated safeguarding lead will consider a referral to the Cyber Choices programme which aims to intervene where young people are at risk of committing, or being drawn into, low level cyber-dependent offences and divert them to a more positive use of their skills and interests.

Domestic Abuse

5.31 At Company 57 staff are aware that domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. We understand that children, young people and vulnerable adults can be victims of domestic abuse, and this can have a detrimental and long-term impact on their health, well-being, development, and ability to learn. We are aware of the Norfolk Integrated Domestic Abuse Service (NIDAS) and signpost victims to the service.

Children with special educational needs and disabilities or physical health issues

5.32 At Company 57 we recognise that children, young people or vulnerable with special educational needs or disabilities (SEND) or certain health conditions can face additional safeguarding challenges such as

• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the condition without further exploration;

• being more prone to peer group isolation or bullying (including prejudice-based bullying)

• the potential for being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs; and

• communication barriers and difficulties in managing or reporting these challenges.

5.33 We work to address these additional challenges and consider extra support, along with ensuring any appropriate support for communication is in place.

Children who are lesbian, gay, bi or trans (LGBT)

5.34 The fact that a child or a young person may be LGBT is not in itself an inherent risk factor for harm. However, in line with ‘Keeping Children Safe in Education’, we recognise that children or young people who are LGBT or those perceived by other children or young people to be LGBT could potentially be more vulnerable and therefore we work to reduce any additional barriers faced.

6. Records & Information Sharing

6.1 If staff are concerned about the welfare or safety of any child, young person or vulnerable adult at our venues, they will record their concern through My Concern. Any concerns should be passed to the DSL without delay.

7. Working With Parents & Carers

7.1 Company 57 is committed to working in partnership with parents/carers to safeguard and promote the welfare of children and to support them to understand our statutory responsibilities in this area.   

7.2 We are committed to working with parents positively, openly and honestly. We ensure that all parents are treated with respect, dignity and courtesy. We respect parents’ rights to privacy and confidentiality and will not share sensitive information unless we have permission, or it is necessary to do so in order to safeguard a child or young person from harm.

7.3 We will seek to share with parents any concerns we may have about their child or young person unless to do so may place a child at increased risk of harm.

8. Safer Recruitment

8.1 We will ensure that the CEO and at least one member of the Senior Leadership Team have completed appropriate safer recruitment training. At all times the CEO and Board of Trustees will ensure that safer recruitment practices are followed in accordance with the requirements of ‘Keeping Children Safe in Education’, DfE (2023).

8.2 At Company 57 we will use the recruitment and selection process to deter and prevent people who are unsuitable to work with children from applying for or securing employment, or volunteering opportunities.

8.3 We require details of a candidate’s present (or last) employment and reason for leaving; full employment history, (since leaving school, including education, employment and voluntary work) including reasons for any gaps in employment and evidence of original academic certificates.  We do not accept testimonials and insist on taking up references prior to a contract of employment.  We will question the contents of application forms if we are unclear about them, and shortlisted candidates will be asked to complete a self-declaration of their criminal record or information that would make them unsuitable to work with children.

8.4 At Company 57 we use a range of selection techniques to identify the most suitable person for the post. Structured questions are agreed by the interview panel and any potential areas of concern are explored to determine the applicant’s suitability to work with children.

8.5 We will undertake Disclosure and Barring Service checks and other preemployment checks as outlined in ‘Keeping Children Safe in Education’ to ensure we are recruiting and selecting the most suitable people to work with our children.

8.6 We will maintain a Single Central Record (SCR) of all safer recruitment checks carried out in line with statutory requirements. A senior member of staff will check the SCR regularly to ensure that it meets statutory requirements.

8.7 At Company 57 we recognise that safer recruitment is not just about carrying out the right DBS checks and is not limited to recruitment procedures. Therefore, we understand the importance of continuous vigilance, maintaining an environment that deters and prevents abuse and challenges inappropriate behaviour.

9. Safer Working Practices

9.1 All adults who come into contact with our children have a duty of care to safeguard and promote their welfare. There is a legal duty placed upon us to ensure that all adults who work with or on behalf of our children are competent, confident and safe to do so.

9.2 All staff will be provided with a copy of our code of conduct at induction.

9.3 If staff are working with children alone they will, wherever possible, be visible to other members of staff. Doors, ideally, should have a clear glass panel in them and be left open.

9.4 Guidance about acceptable conduct and safe practice will be given to all staff and volunteers during induction. These are sensible steps that every adult should take in their daily professional conduct with children.  This advice can be found in ‘Guidance for Safer Working Practices for Adults who work with Children and Young People in Education Settings’ (February 2022). All staff are expected to carry out their work in accordance with this guidance and will be made aware that failure to do so could lead to disciplinary action.

10. Managing Allegations Against Staff & Volunteers

Allegations that may meet the harms threshold

10.1 Our aim is to provide a safe and supportive environment which secures the wellbeing and very best outcomes for children, young people and vulnerable adults. We do recognise that sometimes the behaviour of adults may lead to an allegation of abuse being made.

10.2 Allegations sometimes arise from a differing understanding of the same event, but when they occur, they are distressing and difficult for all concerned. We also recognise that many allegations are genuine and there are some adults who deliberately seek to harm or abuse children. We work to the thresholds for harm as set out in ‘Working Together to Safeguard Children’ (2018) and ‘Keeping Children Safe in Education’, DfE (2023) below. An allegation may relate to a person who works with children who has:

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

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

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

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

The 4th bullet point above recognises circumstances where a member of staff is involved in an incident outside of The Garage Trust which did not involve children but could have an impact on their suitability to work with children; this is known as transferrable risk.

At Company 57 we recognise our responsibility to report / refer allegations or behaviours of concern and / or harm to children by adults in positions of trust to the Local Authority Designated Officer (LADO) service directly at lado@norfolk.gov.uk

We will take all possible steps to safeguard children, young people and vulnerable adults and to ensure that our staff are safe to work with children, young people and vulnerable adults. When concerns arise, we will always ensure that the procedures outlined in the local protocol Allegations Against

Persons who Work with Children and Part 4 of ‘Keeping Children Safe in Education’, DfE (2023) are adhered to and will seek appropriate advice. The first point of contact regarding concerns and/ or allegation issues is via the Local Authority Education Duty Desk on 01603 307797. A Duty Advisor (not a LADO) will give advice and guidance on next steps. If the advice is to make a referral to the LADO service then the LADO referral form should be completed. The completed LADO referral form is then sent via e-mail to: LADO@norfolk.gov.uk.

If an allegation is made or information is received about any adult who works in our setting which indicates that they may be unsuitable to work with children, the member of staff receiving the information should inform the CEO immediately. Should an allegation be made against the CEO, this will be reported to the Chair of Board of Trustees. In the event that neither the CEO nor Chair of Board of Trustees is contactable on that day, the information must be passed to and dealt with by another member of the senior leadership team.

The CEO or Chair of Board of Trustees will seek advice from the LADO within one working day. No member of staff will undertake further investigations before receiving advice from the LADO.

Any member of staff or volunteer who does not feel confident to raise their concerns with the CEO or Chair of Board of Trustees should contact the LADO directly via email to lado@norfolk.gov.uk

Further information and guidance documents in relation to the LADO process, forms, leaflets and the Allegations against Persons who Work/Volunteer with Children Procedures are found on the Norfolk

Safeguarding Children Partnership website. Further national guidance can be found at: Advice on whistleblowing. The NSPCC whistleblowing helpline is also available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285 – line is available from 8:00am to 8:00pm, Monday to Friday or via e-mail: help@nspcc.org.uk.

Company 57 has a legal duty to refer to the Disclosure and Barring Service anyone who has harmed, or poses a risk of harm, to a child, or if there is reason to believe the member of staff has committed one of a number of listed offences, and who has been removed from working (paid or unpaid) in regulated activity or would have been removed had they not left. The DBS will consider whether to bar the person. If these circumstances arise in relation to a member of staff at The Garage Trust, a referral will be made as soon as possible after the resignation or removal of the individual in accordance with advice from the LADO.

Concerns that do not meet the harm threshold

10.10 The term ‘low-level’ concern does not mean that it is insignificant, it means that the behaviour towards a child does not meet the thresholds as stated above. In Norfolk the ‘low level’ concern process is to consult with the Local Authority Education Duty Desk on 01603 307797. At The Garage Trust we recognise a low-level concern to be something which is

• inconsistent with the staff code of conduct, including inappropriate conduct outside of work; and

• does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO.

At Company 57 we promote an open and transparent culture in which all concerns about all adults are dealt with promptly and appropriately. Through training, staff are made aware of what low level concerns are and understand the importance of reporting about these types of concerns in writing.

At Company 57 staff report all low level concerns to the DSL. The DSL will inform the CEO of the concern in a timely fashion. The CEO will always be the ultimate decision maker in respect of all low-level concerns

Through training and induction, we ensure that all staff understand the importance of self-referring, where, for example, they have found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards.

At Company 57 we understand the importance of recording lowlevel concerns and the actions taken in light of these being reported. The records are kept confidential. We will review the records we hold to identify potential patterns and take action. This could be through a disciplinary process but also by referring to the Local Authority Education Duty Desk on 01603 307797. Please note, where a child, parent/carer or staff member makes an allegation of harm, this will not be considered as a ‘low level’ concern without consultation with the Local Authority Education Duty Desk or the LADO service directly.

We recognise that low level concerns should not be included in references unless they relate to issues which would normally be included in a reference, for example, misconduct or poor performance. However, where a low-level concern (or group of concerns) has met the threshold for referral to the LADO and found to be substantiated, it should be referred to in a reference.

11. Use of premises

11.1 We hire our dance studio space at The Workshop and we ensure that appropriate arrangements are in place to keep children, young people and vulnerable adults safe as per the DfE guidance Keeping Children Safe in out-of-school settings

11.2 We will seek assurances that the body concerned has appropriate safeguarding and child protection policies and procedures in place

Safeguarding requirements are included as a condition of use and occupation of the premises; and that failure to comply with this would lead to termination of the agreement.

11.3 If an allegation is made relating to an incident that happened when an individual or organisation was using The Workshop’s premises for non-trust related activities, we will follow our safeguarding policies and procedures.

12. Young People’s Details, Information and Images

12.1 Information and consent collection

For the safety of the children involved Company 57 will require young people who wish to register must complete a registration process asking for the following:

• Parent’s consent for media release

• Parent’s consent for emergency first aid and medical treatment

• Address and contact details of Parents (and emergency contact details if different)

• Details of medical conditions

• Data Protection and Information Storage

• Payment Information

This contains personal and sensitive information. The mishandling of this could lead to a child protection issue, should the address or details of a young person get into the wrong hands. Therefore this information should be stored carefully and accessed strictly on a ‘need to know’ basis.

Information stored on computer systems should be password protected and only accessible to Company 57 Staff

Emergency Contact Registers should be kept, in case of an emergency when computer systems are down.

These should be kept securely and accessed only on a ‘need to know’ basis, by Company 57 staff.

All information should also be treated in line with Company 57’s Data Protection Policy

Child Protection Records and Information

This information is sensitive and divulging this information to the wrong people/persons could result in a child being in greater danger of harm. There is a clear expectation that referral agencies will obtain consent prior to making contact about individual children and families, unless it is not appropriate to do so – if it would place a child at increased risk of harm, prejudice the prevention, detection or prosecution of a serious crime or lead to an unjustified delay in making enquiries about allegations of harm. In general Information should be kept securely, and only accessed by authorised staff on a ‘’need to know’’ basis.

Photography, media and the press

The below applies to all images and portrayals of children taking part in Company 57 activities, and all media and press outlets:

Company 57 will require children’s parents to sign a media release as part of their sign up procedures.

A child’s image will only be used by Company 57t as stated in this, and if release is consented to

Photographs released to the media should not normally identify young people, give their name, address, school etc.

Company 57 will take care that any images or other material used promotionally or released to the press show the children concerned in positive light and are not likely to cause distress to the children involved or their families

Signs will be clearly displayed when photography is used as part of a Company 57 event or activity.   

13. Statutory Framework

This policy has been devised in accordance with the following legislation and guidance:

• Working Together to Safeguard Children  DfE (July 2018)

• Keeping Children Safe in Education DfE (2023)

• Working Together to Improve School Attendance, DfE (2022)

• Norfolk Safeguarding Children Partnership procedures

• Norfolk Safeguarding Children Partnership Protocol: Allegations Against Persons Who Work with Children

• Guidance for Safer Working Practices for Adults who work with Children and Young People in Education Settings (Feb 2022)

• What to do if you're worried a child is being abused DfE (March 2015)

• Information sharing: advice for practitioners providing safeguarding services DfE (July 2018)

• The Prevent duty: Departmental advice for schools and childcare providers DfE (June 2015)

• The Prevent duty: safeguarding learners vulnerable to radicalisation (October 2022)

• Mandatory Reporting of Female Genital Mutilation- procedural information  Home Office (January 2020)

• Multi-agency practice principles for responding to child exploitation and extra-familial harm

• Child sexual exploitation: guide for practitioners DFE (February 2017)

• Teaching online safety in school DfE (January 2023)

• Mental Health and Behaviour in Schools DfE (November 2018)

• Data protection: toolkit for schools DfE (February 2023)

• Promoting the education of children with a social worker (June 2023)

• Preventing youth violence and gang involvement

• Criminal exploitation of children and vulnerable adults: county lines

• Relationships Education, Relationships and Sex Education (RSE) and Health Education