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Safeguarding children, young people and vulnerable adults


‘It is not our responsibility to decide whether or not child abuse is occurring, but it is the responsibility of all of us to act on any concerns and do something about it.’
Milnthorpe Family Centre will work with children, parents and the community to ensure the rights and safety of children and to give them the very best start in life.
Cumbria Local Safeguarding Board (Cumbria LSCB) provide procedures to follow in the event of suspected child protection incidents.
These procedures can be accessed on the Internet at: www.cumbrialscb.com
By clicking on the tab ‘Procedures, Guidance and Protocols’
To make a safeguarding referral:
Phone Safeguarding Hub 03332401727
Creating a 'culture of safety'
We are committed to building a 'culture of safety' in which children, young people and vulnerable adults are protected from abuse and harm.
Joeys designated person, ‘Safeguarding Lead’, who co-ordinates child, young person and vulnerable adult protection issues is:
Katie Smyth (Joeys Manager)
In her absence Zoe Scrogham (Joeys Deputy Manager) will fulfil this role
In the unlikely event that neither the Manager nor Deputy is available the following senior staff are trained to step up:
Gemma Gott, Nicky Casey, Jen Bateman, Sophie Wightman
The setting is supported by a named Safeguarding Director:
Shirley Bennett
When the setting is open but the designated person is not on site, a suitably trained deputy is available at all times for staff to discuss safeguarding concerns. We also have a designated safeguarding director who is available for advice and support: Shirley Bennett
The designated person, the suitably trained deputy and the safeguarding director ensure they have relevant links with statutory and voluntary organisations with regard to safeguarding.
The designated person (and the person who deputises for them) understands LSCB safeguarding procedures, attends relevant LSCB training at least every two years and refreshes their knowledge of safeguarding at least annually.
We ensure all staff are trained to understand our safeguarding policies and procedures and that parents are made aware of them too.
All staff have an up-to-date knowledge of safeguarding issues, are alert to potential indicators and signs of abuse and neglect and understand their professional duty to ensure safeguarding and child protection concerns are reported to the local authority children’s social care team or the NSPCC. They receive updates on safeguarding at each staff meeting.          
§  All staff are confident to ask questions in relation to any safeguarding concerns and know not to just take things at face value but can be respectfully sceptical.
§  All staff understand the principles of early help (as defined in Working Together to Safeguard Children, 2018) and are able to identify those children and families who may be in need of early help and enable them to access it.
§  All staff understand LSCB thresholds of significant harm and understand how to access services for families, including for those families who are below the threshold for significant harm.
§  All staff understand their responsibilities under the General Data Protection Regulations and the circumstances under which they may share information about you and your child with other agencies.
§  All staff understand how to escalate their concerns in the event that they feel either the local authority and/or their own organisation has not acted adequately to safeguard.
§  All staff understand what the organisation expects of them, in terms of their required behaviour and conduct, and follow our policies and procedures on positive behaviour, online safety (including use of mobile phones), whistleblowing and dignity at work.
§  Children have a key person to build a relationship with, and are supported to articulate any worries, concerns or complaints that they may have in an age appropriate way.
§  All staff understand our policy on promoting positive behaviour and follow it in relation to children showing aggression towards other children.
§  Adults will not be left alone for long periods with individual children or with small groups in a place where they are not visible by other staff. 
§  Adults will not take children unaccompanied to the toilet without a DBS.
§  Children will be encouraged to develop a sense of autonomy and independence through adult support in making choices and in finding names for their own feelings and acceptable ways to express them.  This will enable children to have the self-confidence and the vocabulary to resist inappropriate approaches.
§  The layout of the rooms will permit constant supervision of all children.
§   Staff, students’ and visitors mobile phones should never be on their person within the Koala room, Little Jumpers room, Out of School Club, toilets or outdoor play areas. They should be stored in the designated area in the office.
§   Under no circumstance should staff take photographs of any children using their personal mobiles. Any staff doing so will face disciplinary proceedings. (see Social Networking and mobile phones Policy and Procedure for further details)
Safe Recruitment
§  Applicants for posts within the setting are clearly informed that the positions are exempt from the Rehabilitation of Offenders Act 1974.
§  Enhanced criminal records and barred lists checks and other suitability checks are carried out for staff and volunteers prior to their post being confirmed, to ensure that no disqualified person or unsuitable person works at the setting or has access to the children.
§  Where applications are rejected based on information disclosed, applicants have the right to know and to challenge incorrect information.
§  Enhanced criminal records and barred lists checks are carried out on anyone living or working on the premises.
§  To count in ratio volunteers must:
-            be aged 17 or over;
-            be considered competent and responsible;
-            receive a robust induction and regular supervisory meetings;
-            be familiar with all the settings policies and procedures;
-            Never be left with children, unsupervised at any time.
§  Information is recorded about staff qualifications, and the identity checks and vetting processes that have been completed including:
-            the criminal records disclosure reference number;
-            certificate of good conduct or equivalent where a UK DBS check is not appropriate;
-            the date the disclosure was obtained; and
-            Details of who obtained it.
§  All staff and volunteers are informed that they are expected to disclose any convictions, cautions, court orders or reprimands and warnings which may affect their suitability to work with children (whether received before or during their employment with us).
§  All staff and volunteers are required to notify us if anyone in their household (including family members, lodgers, partners etc.) has any relevant convictions, cautions, court orders, reprimands or warnings or has been barred from, or had registration refused or cancelled in relation to any childcare provision or have had orders made in relation to care of their children.
§  We notify the Disclosure and Barring Service of any person who is dismissed from our employment, or resigns in circumstances that would otherwise have led to dismissal for reasons of a child protection concern.
Keeping Children Safe
§  Procedures are in place to record the details of visitors to the setting.
§  Security steps are taken to ensure that we have control over who comes into the setting so that no unauthorised person has unsupervised access to the children.
§  Steps are taken to ensure children are not photographed or filmed on video for any other purpose than to record their development or their participation in events organised by us. Parents sign a consent form and have access to records holding visual images of their child.
§  Any personal information is held securely and in line with data protection requirements and guidance from the ICO.
§  The designated person in the setting has responsibility for ensuring that there is an adequate online safety policy in place.
§  We keep a written record of all complaints and concerns including details of how they were responded to.
§  We ensure that robust risk assessments are completed, that they are seen and signed by all relevant staff and that they are regularly reviewed and updated, in line with our health and safety policy.
§  The designated safeguarding director will support the designated person to undertake their role adequately and offer advice, guidance, supervision and support.
§  The designated person will inform the designated safeguarding director at the first opportunity of every significant safeguarding concern, however this should not delay any referrals being made to children’s social care, the LADO, Ofsted or RIDDOR.
Responding promptly and appropriately
We are committed to responding promptly and appropriately to all incidents, allegations or concerns of abuse that may occur and to work with statutory agencies in accordance with the procedures that are set down in 'What to do if you’re worried a child is being abused' (HMG, 2015) and the Care Act 2014.
Responding to suspicions of abuse
Joeys has a duty to report any suspicions of abuse to the Local Authority.  The Children Act 1989 (Section 47 (1)) places a duty on the Local Authority to investigate such matters.
§   We acknowledge that abuse of children can take different forms - physical, emotional, and sexual, as well as neglect.
§  We ensure that all staff have an understanding of the additional vulnerabilities that arise from special educational needs and/or disabilities, plus inequalities of race, gender, language, religion, sexual orientation or culture, and that these receive full consideration in relation to child, young person or vulnerable adult protection.
§  When children are suffering from physical, sexual or emotional abuse, or experiencing neglect, this may be demonstrated through:
-          significant changes in their behaviour;
-          deterioration in their general well-being;
-          their comments which may give cause for concern, or the things they say (direct or indirect disclosure);
-          changes in their appearance, their behaviour, or their play;
-          unexplained bruising, marks or signs of possible abuse or neglect; and
-          Any reason to suspect neglect or abuse outside the setting.
§  We are aware of the ‘hidden harm’ agenda concerning parents with drug and alcohol problems and consider other factors affecting parental capacity and risk, such as social exclusion, domestic violence, radicalisation, mental or physical illness and parent’s learning disability.
§  We are aware that children’s vulnerability is potentially increased when they are privately fostered and when we know that a child is being cared for under a private fostering arrangement, we inform our local authority children’s social care team.
§  We are prepared to take action if we have concerns about the welfare of a child who fails to arrive at a session when expected. The designated person will take immediate action to contact the child’s parent to seek an explanation for the child’s absence and be assured that the child is safe and well. If no contact is made with the child’s parents and the designated person has reason to believe that the child is at risk of significant harm, the relevant professionals are contacted immediately and LSCB procedures are followed. If the child has current involvement with social care the social worker is notified on the day of the unexplained absence.
§  We are aware of other factors that affect children’s vulnerability that may affect, or may have affected, children and young people using our provision, such as abuse of children who have special educational needs and/or disabilities; fabricated or induced illness; child abuse linked to beliefs in spirit possession; sexual exploitation of children, including through internet abuse; Female Genital Mutilation and radicalisation or extremism.
§  In relation to radicalisation and extremism, we follow the Prevent Duty guidance for England and Wales published by the Home Office and LSCB procedures on responding to radicalisation.
§  From July 2015 all schools, registered early years childcare providers and registered later years childcare providers are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015 to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty.
§  The Prevent duty reinforces our existing responsibilities in respect of radicalisation of children.
§  The Prevent duty does not require childcare providers to carry out unnecessary intrusion into family life but they must take action when they observe behaviour of concern. (Please see our Prevent policy)
§  The designated person completes online Channel training, online Prevent training and attends local WRAP training where available to ensure they are familiar with the local protocol and procedures for responding to concerns about radicalisation.
§  We are aware of the mandatory duty that applies to teachers, including early years practitioners, and health workers to report cases of Female Genital Mutilation to the police.
§  We also make ourselves aware that some children and young people are affected by gang activity, by complex, multiple or organised abuse, through forced marriage or honour based violence or may be victims of child trafficking. While this may be less likely to affect young children in our care, we may become aware of any of these factors affecting older children and young people who we may come into contact with.
§  Where we believe that a child in our care or that is known to us may be affected by any of these factors we follow the procedures below for reporting child protection concerns and follow the LSCB procedures.
§  Where such evidence is apparent, the child's key person makes a dated record of the details of the concern and discusses what to do with the designated person. The information is stored on the child's personal file.
§  In the event that a staff member or volunteer is unhappy with the decision made of the designated person in relation to whether to make a safeguarding referral they must follow escalation procedures.
§  We refer concerns to the local authority children’s social care team and co-operate fully in any subsequent investigation. In some cases this may mean the police or another agency identified by the Local Safeguarding Children Board.
§  We take care not to influence the outcome either through the way we speak to children or by asking questions of children.
§  We take account of the need to protect young people aged 16-19 as defined by the Children Act 1989. This may include students or school children on work placement, young employees or young parents. Where abuse is suspected we follow the procedure for reporting any other child protection concerns. The views of the young person will always be taken into account, but the setting may override the young person’s refusal to consent to share information if it feels that it is necessary to prevent a crime from being committed or intervene where one may have been, or to prevent harm to a child or adult. Sharing confidential information without consent is done only where not sharing it could be worse than the outcome of having shared it.
§  All staff are also aware that adults can also be vulnerable and know how to refer adults who are in need of community care services.
§  We have a whistleblowing policy in place.
§  Staff/volunteers know they can contact the organisation Public Concern at Work for advice relating to whistleblowing; if they feel that the organisation has not acted adequately in relation to safeguarding they can contact the NSPCC whistleblowing helpline.
Recording suspicions of abuse and disclosures
§  Where a child makes comments to a member of staff that give cause for concern (disclosure), or a member of staff observes signs or signals that give cause for concern, such as significant changes in behaviour; deterioration in general well-being; unexplained bruising, marks or signs of possible abuse or neglect; that member of staff:
-          listens to the child, offers reassurance and gives assurance that she or he will take action;
-          does not question the child, although it is OK to ask questions for the purposes of clarification;
-          makes a written record that forms an objective record of the observation or disclosure that includes: the date and time of the observation or the disclosure; the exact words spoken by the child as far as possible; the name of the person to whom the concern was reported, with the date and time; and the names of any other person present at the time.
§  These records are signed and dated and kept in the child's personal file, which is kept securely and confidentially.
§  The member of staff acting as the designated person is informed of the issue at the earliest opportunity, and within one working day.
§  Where the Local Safeguarding Children Board stipulates the process for recording and sharing concerns, we include those procedures alongside this procedure and follow the steps set down by the Local Safeguarding Children Board.
Escalation process
§  If we feel that a referral made has not been dealt with properly or that concerns are not being addressed or responded to, we will follow the LSCB escalation process.
§  We will ensure that staff are aware of how to escalate concerns.
Informing parents
§  Parents are normally the first point of contact. Concerns are discussed with parents to gain their view of events, unless it is felt that this may put the child at risk, or interfere with the course of a police investigation. Advice will be sought from social care if necessary.
§  Parents are informed when we make a record of concerns in their child’s file and that we also make a note of any discussion we have with them regarding a concern.
§  If a suspicion of abuse warrants referral to social care, parents are informed at the same time that the referral will be made, except where the guidance of the Local Safeguarding Children Board does not allow this, for example, where it is believed that the child may be placed at risk.
§  This will usually be the case where the parent is the likely abuser.
§  If there is a possibility that advising a parent beforehand may place a child at greater risk (or interfere with a police response) the designated person should seek advice from children’s social care, about whether or not to advise parents beforehand, and should record and follow the advice given.
Liaison with other agencies
§  We work within the Local Safeguarding Children Board guidelines.
§  Joeys must have regard to the Government's statutory guidance ‘Working Together to Safeguard Children 2018’. If we have concerns about children's safety or welfare, we must notify agencies with statutory responsibilities without delay. This means the local children's social care services and, in emergencies, the police.
§  Joey’s operates in accordance with Cumbria Local Safeguarding Children Board guidelines, these can be found on their website www.cumbrialscb.com 
§   Confidential records kept on children about whom Joey’s is anxious will be shared with the Children’s Services if Joey’s feels that adequate explanations for changes in the child’s condition have not been provided. In cases of extreme concern, where immediate action is considered necessary to safeguard the wellbeing of the child, Children’s Services will be notified without prior consultation with the parents.
§  If a report on a child is to be made to the authorities, the child’s parents, or carers, will be informed at the same time as the report is made, unless Joeys feel this may put the child at greater risk.
§  Joeys will maintain ongoing contact with the registration authority, including names, addresses and telephone numbers of individual social workers, to ensure that it would be easy, in any emergency, for Joeys and Children’s Services to work well together.
§   Records will also be kept of other contact(s) as appropriate.
§  The current version of ‘What to do if you’re worried a child is being abused’ is available for parents and staff and all staff are familiar with what they need to do if they have concerns.
§  We have procedures for contacting the local authority regarding child protection issues, including maintaining a list of names, addresses and telephone numbers of social workers, to ensure that it is easy, in any emergency, for the setting and children's social care to work well together.
§  We notify Ofsted of any incident or accident and any changes in our arrangements which may affect the well-being of children or where an allegation of abuse is made against a member of staff (whether the allegations relate to harm or abuse committed on our premises or elsewhere). Notifications to Ofsted are made as soon as is reasonably practicable, but at the latest within 14 days of the allegations being made.
§  Contact details for the local National Society for the Prevention of Cruelty to Children (NSPCC) are also kept.
Whistle blowing:
Any individual who has reasonable suspicion of malpractice or concerns about a child’s welfare should inform the Safeguarding and Child Protection designated person immediately. All reports will be investigated and dealt with in confidence, including only those staff on a ‘need to know’ basis. In relation to complaints, about the Safeguarding and Child Protection designated person/manager, the Lado should be contacted at the Cumbria safeguarding hub 03332401727
Whistle blowing at Ofsted Hotline: To contact the hotline call 0300 123 3155
(Monday to Friday from 08.00 to 18.00), email: whistleblowing@ofsted.gov.uk
Or write to WBHL, Ofsted, Royal Exchange Buildings, Piccadilly Gate, Manchester M1 2WD.
Allegations against staff
If a member of staff or other adult involved with Joeys is suspected of abuse or displays inappropriate behaviour, parents/carers/staff should report this to the Manager. If this is not appropriate they should contact Cumbria Safeguarding Hub, telephone number: 03332401727
§  We ensure that all parents know how to complain about the behaviour or actions of staff or volunteers within the setting which may include an allegation of abuse.
§  We respond to any inappropriate behaviour displayed by members of staff, volunteer which includes:
-          inappropriate sexual comments;
-          Excessive one-to-one attention beyond the requirements of their usual role and responsibilities, or inappropriate sharing of images.
§  Any allegations concerning a member of staff will be dealt with immediately by the manager. The member of staff will be suspended while enquiries are carried out.
§  All staff have a duty to report any suspicious behaviour or witnessed incidents to the Manager immediately if the manager is not on site and not contactable, they should report to the deputy manager if in the unlikely event neither the Manager or Deputy are available a third senior member of staff will be named. If however the member of staff feels it necessary for any reason they should contact Cumbria Safeguarding Hub.
§  We follow the guidance of the Local Safeguarding Children Board when responding to any complaint that a member of staff or volunteer within the setting has abused a child.
§  We ensure that all staff and volunteers know how to raise concerns about a member of staff or volunteer within the setting. We respond to any concerns raised by staff and volunteers who know how to escalate their concerns if they are not satisfied with our response
§  We respond to any disclosure by children or staff that abuse by a member of staff or volunteer within the setting, may have taken, or is taking place, by first recording the details of any such alleged incident.
§  We refer any such complaint immediately to the Local Authority Designated Officer (LADO) to investigate and/or offer advice: they are contacted through Cumbria Local Safeguarding Hub 03332401727
§  We also report any such alleged incident to Ofsted (unless advised by LADO that this is unnecessary due to the incident not meeting the threshold), as well as what measures we have taken. We are aware that it is an offence not to do this.
§  We co-operate entirely with any investigation carried out by children’s social care in conjunction with the police.
§  Where the management team and children’s social care agree it is appropriate in the circumstances, the member of staff or volunteer will be suspended for the duration of the investigation. This is not an indication of admission that the alleged incident has taken place, but is to protect the staff, as well as children and families, throughout the process.
Disciplinary action
Where a member of staff or volunteer has been dismissed due to engaging in activities that caused concern for the safeguarding of children or vulnerable adults, we will notify the Disclosure and Barring Service of relevant information, so that individuals who pose a threat to children and vulnerable groups can be identified and barred from working with these groups.
Promoting awareness of child abuse
We are committed to promoting awareness of child abuse issues throughout our training and learning programmes for adults. We are also committed to empowering children through our early childhood curriculum, promoting their right to be strong, resilient and listened to.
§  All staff and students joining Joeys are given our “Joeys keeping children safe” pack as part of their induction. This includes a copy of our policies, HM Government documents ‘what to do if you’re worried a child is being abused’ advice for practitioners & ‘information sharing’, definitions and signs of abuse from NSPCC, as well as information and guidance on FGM, radicalisation and other such useful publications.
§  We will provide online training through Cumbria LSCB for all staff and volunteers during their first week.  All senior practitioners receive level 3 safeguarding training. All training will be updated regularly to ensure staff knowledge is current and relevant.
§  Training opportunities for all adults involved in the group ensure that they are able to recognise the signs and signals of possible physical abuse, emotional abuse, sexual abuse (including child sexual exploitation) and neglect and that they are aware of the local authority guidelines for making referrals.
§  Joeys will provide opportunities for staff to discuss concerns through supervisions and having an open door policy where staff can talk with the manager wherever concerns may arise. Advice and support will be given in helping the staff member throughout safeguarding procedure.
§  The manager is also supported and offered regular supervisions with director Shirley Bennett, who operates the same open door policy and is always available to support the manager or any staff member.
§  Designated persons receive appropriate training, as recommended by the Local Safeguarding Children Board, every two years and refresh their knowledge and skills at least annually.
§  We ensure that all staff know the procedures for reporting and recording any concerns they may have about the provision.
§  We ensure that all staff receive updates on safeguarding via emails, newsletters, online training and/or discussion at staff meetings at least once a year.
§  The layout of the rooms allows for constant supervision. No child is left alone with staff or volunteers in a one-to-one situation without being within sight and/or hearing of other staff or volunteers.
§  We introduce key elements of keeping children safe into our programme to promote the personal, social and emotional development of all children, so that they may grow to be strong, resilient and listened to and so that they develop an understanding of why and how to keep safe.
§  We create within the setting a culture of value and respect for individuals, having positive regard for children's heritage arising from their colour, ethnicity, languages spoken at home, cultural and social background.
§  We ensure that this is carried out in a way that is developmentally appropriate for the children.
§  All suspicions and investigations are kept confidential and shared only with those who need to know. Any information is shared under the guidance of the Local Safeguarding Children Board.
Support families
§  Joeys will take every step in its power to build up trusting and supportive relationships between families and staff and volunteers in the group.
§  We make clear to parents our role and responsibilities in relation to child protection, such as for the reporting of concerns, information sharing, monitoring of the child, and liaising at all times with the local children’s social care team.
§  We will continue to welcome the child and the family whilst investigations are being made in relation to any alleged abuse.
§  We follow the Child Protection Plan as set by the child’s social worker in relation to the setting's designated role and tasks in supporting that child and their family, subsequent to any investigation.
§  Confidential records kept on a child are shared with the child's parents or those who have parental responsibility for the child in accordance with the Confidentiality and Client Access to Records procedure, and only if appropriate under the guidance of the Local Safeguarding Children Board.
Legal framework
Primary legislation
§  Children Act (1989 s47)
§  Protection of Children Act (1999)
§  The Children Act (2004 s11)
§  Safeguarding Vulnerable Groups Act (2006)
§  Childcare Act (2006)
Secondary legislation
§  Sexual Offences Act (2003)
§  Criminal Justice and Court Services Act (2000)
§  Equality Act (2010)
§  General Data Protection Regulations (GDPR) (2018)
§  Childcare (Disqualification) Regulations (2009)
§  Children and Families Act (2014)
§  Care Act (2014)
§  Serious Crime Act (2015)
§  Counter-Terrorism and Security Act (2015)


Signed on behalf of Milnthorpe Family Centre Directors

Katie Smyth, Manager                          Reviewed August 2018