Safeguarding Policy

Policy purpose

This document sets out the Cambridge Marketing College (CMC) policy on safeguarding. CMC recognises its statutory and moral duty towards safeguarding the welfare of both young people and adults in its care.

CMC is committed to safeguarding and promoting the welfare of all its learners, staff, stakeholders, visitors, contractors and partners.

In addition, CMC believes that all young people and vulnerable adults have an equal right to protection from abuse or exploitation whatever their race, religion, first language or ethnicity, gender or sexuality, age, health or disability, political or immigration status. It considers the welfare of its learners to be paramount.

The policy is produced to safeguard all adults, vulnerable adults and students under 19, in accordance with Keeping Children Safe in Education 2023. CMC has a statutory requirement to follow guidance referenced in:

• The Children Act 1989 (as amended) - to assist the Local Authority Social Services Department acting on behalf of children in need
• The Children and Social Work Act 2017 – Safeguarding of Children (Chapter 2)
• The Safeguarding Vulnerable Groups Act 2006
• Working Together to Safeguard Children 2018 - safeguard and promote the welfare of children
• Keeping Children Safe in Education 2022 - Safeguarding is Everybody’s Responsibility
• Education and Training (Welfare of Children) Act 2021
• Human Rights Act 1998
• The Equality Act 2010 / Public Sector Equality Duty (PSED)

Our Adult learner and apprentices will fall under the Care Act (2014) legislation and the Care and Support guidance (2014), with guidance from Keeping Children Safe in Education 2022. The Public Sector Equality Duty (PSED) for education settings (Equality Act 2010) highlights a need to be conscious that learner and apprentices with protected characteristics may be more at risk of harm.

CMC has developed this policy and procedure in line with guidance issued by the Department for Education, Ofsted and other relevant bodies, and operates in line with the requirements for, the Cambridgeshire County Council`s Adult safeguarding policy, as well as The Prevent Strategy.

This policy is reviewed annually and will next be reviewed in August 2024.

Active promotion

This policy will be promoted through annually programmed staff development events, the website and Learner and Staff Inductions, as well as learner and staff handbooks. Safeguarding and The Prevent Agenda (see separate policy) will be promoted through all contact with our learners and apprentices.

Each learner is made aware of the Safe & Well Team at induction, at an initial safeguarding check, progress reviews, and monthly tutorials. In addition to a safeguarding officer, the College recognised the need, following the Covid Pandemic for a mental health first aider. As a result, there is now one mental health available for supporting any member of staff, tutors, suppliers and learners.

Regular training will take place for all admin and tutor staff. It takes place at induction and on an annual basis. The College has a zero-tolerance policy of abuse of any kind.

Employers also have a responsibility to the learners and apprentices they employ. We recognise that we have a duty to help the employers we work with, our staff and our learner and apprentices to recognise their responsibilities, through guidance, support and training. As the employer of a learner and apprentice, it is important that they understand their responsibilities to the learner and apprentice and what safeguarding means to them.

Safeguarding is Everyone's Responsibility

Background

Definitions

Any reference in the policy to a child, young person, learner or apprentice applies to all those aged under 18.

Any reference in the policy to a vulnerable adult, or an adult at risk, applies to anyone over the age of 18 who may, for a variety of reasons, be in need of community services and/or unable to protect him or herself from significant harm or exploitation.

Types of Abuse

“Abuse” relates to the mistreatment of an individual’s human and civil rights by any other person or persons and may consist of single or repeated acts. Incidents of abuse can be either to one person or more than one person at a time. Abuse and/or harmful behaviours can be either deliberate or the result of negligence, ignorance, lack of training, knowledge or understanding. Somebody may abuse or neglect an individual by inflicting harm or by failing to prevent harm.

Within the context of this policy, abuse and harmful behaviours are defined through the following main categories:

Physical: this may involve hitting, slapping, pushing, kicking, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, misuse of medication, inflicting inappropriate physical sanctions, or otherwise causing physical harm, including fabricating the symptoms of, or deliberately causing the individual ill health (DfE 2014, DoH 2000)
Emotional/Psychological: this is the persistent emotional ill-treatment of a child, young person or vulnerable adult such as to cause severe and persistent adverse effects on their emotional development. Threats of harm or abandonment; humiliation; blaming; intimidation; coercion; harassment; verbal abuse, bullying (including cyberbullying) and being prevented from receiving services or support are all forms of emotional abuse (DoH 2000).
Sexual: such as rape, sexual assault or sexual acts occurring through force or enticement and which a child, young person or vulnerable adult could not have consented to, or to which they were pressurised into consenting.
Neglect or Acts of Omission: this includes the persistent failure to meet a child, young person or vulnerable adult’s basic physical and/or psycho-social needs, and which are likely to result in a serious impairment of the individual’s health or development. This may include failing to provide adequate food, shelter and clothing, or educational services and/or neglect of, or unresponsiveness to, a child, young person or vulnerable adult’s basic emotional needs (DoH 2000).
Financial or Material: this may include theft, fraud, and exploitation, pressure in connection with money or material possessions. (DoH 2000).
Discriminatory: this may include abuse, bullying and harassment based on the individual’s age, sex, disability, religion, race or sexual orientation (DoH 2000).
Abuse of Trust: under the Sexual Offenders Act 2003 it is an offence for a person over 18 to have a sexual relationship with a young person under 18 where that person is in a position of trust in respect of that young person, even if the relationship is consensual. This includes teaching and a range of support staff within educational establishments.
Radicalisation: The process by which a person comes to support terrorism and forms of extremism leading to terrorism (Prevent Strategy.Gov.uk) See Radicalisation and Acts of Terrorism
Online Abuse: any type of abuse that happens on the web, whether through social networks, playing games online or using mobile Phones (NSPCC 2015)
Harmful sexual behaviour: Children or young people develop sexual behaviours that harm themselves or other. (NSPCC 2015)
Institutional abuse: this takes pace in settings where there are a number of vulnerable people and can range from neglect to outright physical assault.

Radicalisation and Acts of Terrorism - The Counter Terrorism & Security Act (2015) and the Prevent Duty

Prevent is 1 of the 4 elements of CONTEST, the government’s counter-terrorism strategy. It aims to stop people becoming terrorists or supporting terrorism. This Act places a duty on specified authorities including Further and Higher Education, to have due regard to the need to prevent people from being drawn into terrorism (the Prevent Duty).

CMC has a separate policy for its Prevent Strategy.

Safeguarding Process for Adults

What is Safeguarding?

Safeguarding adults includes:

Protecting their rights to live in safety, free from abuse and neglect
People and organisations working together to prevent the risk of abuse or neglect
Making sure people’s wellbeing is promoted, taking their views, wishes, feelings and beliefs into account
Working with partners such as the Care Quality Commission (CQC), police, local councils, health agencies, other regulators and government departments (including the ISA’s Disclosure and Barring Service (DBS))
(Source: Care Quality Commission)
CMC’s employees have a ‘Duty of Care’ to recognise abusive situations and report concerns to the relevant manager. Staff should follow the 4-step process for raising a safeguarding issue:
1. Identification
2. Raising with CMC Safeguarding Officer
3. Raising with organisation’s safeguarding officer
4. Seeking professional advice

Identification

Staff should:

Know and recognise all types of abuse (see types of abuse).
Be alert to and aware of signs of abuse at all times.

Raising a safeguarding issue

If anyone discloses a safeguarding issue

There are 3 rules:

Do listen non-judgmentally & sympathetically
Don`t promise confidentiality
Do report to the Safe and Well Team safeandwell@marketingcollege.com or call 0737 589 2864 - this may be made anonymously.

Safeguarding issues are logged, you will be kept informed of the situation within the limits of confidentiality.

More detail of the actions that should be taken if you have concerns, suspicions, witness abuse or someone discloses abuse:

STEP 1

Take whatever action is required to ensure the immediate safety or medical welfare of the individual
Remain calm and non-judgmental
Do not discourage from disclosure
Use active listening skills and remain sympathetic and attentive
Give reassurance but do not press for more detail or make promises

STEP 2

Explain that you cannot keep information about alleged or suspected abuse confidential
Clarify main facts, summarise what has been said to you
Remain sensitive
Explain that the College’s Safeguarding Officer must be informed
Seek the person’s consent to share this information
Consider issues of capacity, consent, best interest and public protection
Offer future support from yourself or others (Safe and Well Team)

STEP 3

Take all reasonable steps to ensure that the individual is in no immediate danger of further harm
Preserve evidence

What happens next?

A member of the Safe and Well Team will consider the situation and may contact the apprentice confidentially for more information and to offer a listening ear.

The concern will be noted by the Safe and Well Team and stored centrally in a secure area of the CRM. Only members of the Safe and Well Team can access this information. A red, amber or green flag will be placed on the apprentice’s record to indicate to staff and tutors that there is a safeguarding concern – no further details are accessible.

Actions that may be taken will depend on the circumstances but may include:

Discussion with CMC senior management team and the College’s Mental Health First Aider
Contacting the apprentice for more information
Encouraging the apprentice to approach their HR department or Line Manager as appropriate. CMC will offer to do this on their behalf and will offer support.
Seeking professional advice If the situation is serious, the issue can be escalated through the Cambridge and Peterborough Safeguarding Adults and Children Partnership Board https://www.safeguardingcambspeterborough.org.uk/adults-board/reporting-a-concern/ using a Safeguarding Adults Referral Form or to the Apprentice’s local adult safeguarding board

If the issue is caused by CMC staff

The senior management team will investigate. There may be three outcomes:

A safeguarding issue, usually involving intentional harm. The senior management team will involve CMC’s HR Consultant for advice.
An issue of poor performance; the employee was trying to do the correct thing but got it wrong unintentionally and needs training or guidance to improve their standards. Unintended mistakes and more minor one-off issues are an indicator that there is no abusive intent. Take great care in cases where an arguably minor issue is being described in the language of abuse, particularly in more discretionary or subjective areas.
Misconduct which does not amount to safeguarding and is not poor performance, usually involving someone who knew what to do and had the capacity to do it correctly but chose not to. This will be handled by the College’s senior management team on an individual basis.
Any complaints regarding the Senior Management Team will be referred to the College Governor

How to Act on Behalf of a Child or a Vulnerable Adult

Action that should be taken if you have concerns, suspicions, witness abuse or someone discloses abuse:

STEP 1

Take whatever action is required to ensure the immediate safety or medical welfare of the individual
Remain calm and non-judgmental
Do not discourage from disclosure
Use active listening skills and remain sympathetic and attentive
Give reassurance but do not press for more detail or make promises

STEP 2

Explain that you cannot keep information about alleged or suspected abuse confidential
Clarify main facts, summarise what has been said to you
Remain sensitive
Explain that the Safe and Well Team must be informed
Seek the person’s consent to share this information
Consider issues of capacity, consent, best interest and public protection
Offer future support from yourself or others (keyworker or advocate)

STEP 3

Take all reasonable steps to ensure that the individual is in no immediate danger of further harm
Preserve evidence
Make a complete and accurate record of events as soon as possible
Discuss any concerns you have with the local Safeguarding Team who will, within the appropriate timeframe, either make enquiries without raising the question of abuse and evaluate the matter and/or make a referral to the appropriate external authority
Inform the Safe and Well Team as soon as possible

Responsibilities

Cambridge Marketing College

Safe and Well Team

Telephone: 0737 589 2864

Email: safeandwell@marketingcollege.com

Shane Minett (Operations and Finance Director, Mental Health First Aider, Designated Safeguarding Lead (DSL))

Telephone: 01954 234943

Email: shane@marketingcollege.com

Kiran Kapur (CEO, Deputy DSL)

Telephone: 01954 234 947

Email: kiran@marketingcollege.com

Eric Purdy (Governor)

Telephone: 07873 735 782

Email: EricP@marketingcollege.com

Cambridgeshire and Peterborough Safeguarding

Adult Board

telephone: 0345 045 5202

Email: referral.centre-adults@cambridgeshire.gov.uk

Children’s Board (under 18)

Cambridgeshire County Council: 0345 045 5203

or complete a referral online Report abuse of a child – Cambridgeshire County Council

Peterborough City Council: 0345 045 5203

or complete a referral online Report abuse of a child – Peterborough City Council

Emergency Duty Team (Out of Hours) 01733 234724.

Monitoring and Improvement

The policy will be reviewed annually, or in response to major changes in legislation or significant events.

It will be the responsibility of the DSL to review and monitor these procedures and to consult with other agencies as appropriate.

Policy review will include consultation with local Safeguarding Adults Agencies whose support and advice are recognised as crucial to the effective implementation of the policy.

An annual report to the board will be produced.

Records of reported incidents and staff training will inform the monitoring of policy effectiveness

Appropriate steps shall be taken to ensure that vulnerable adults and children are enabled to access relevant support services, appropriate to their need.

The effectiveness of policy promotion will be assessed as part of CMC’s internal quality assurance process. Feedback will be used to facilitate ongoing improvements.