Safeguarding Policy

1. Our commitment

All our employees who work with learners have a crucial role to play in shaping their lives. You have a unique opportunity to interact in ways that are both affirming and inspiring. This policy has been produced (and is supported by Information, Advice and Guidance) to help you establish safe and responsive environments which safeguard all and reduce the risk of you being unjustly accused of improper or unprofessional conduct. We all have a duty of care to safeguard and promote welfare, and to enhance awareness of the broader welfare spectrum, specifically the issues facing young people in society and create a culture where young people can speak out or share their concerns

2. Objectives

The policy aims to ensure you are aware of and understand your responsibilities, those of others, signs that there might be a safeguarding concern, along with the reporting procedures for all safeguarding issues.

3. Scope

This policy covers the safeguarding of Children and Adults at Risk as defined below for Lifetime Group (Lifetime is the trading name for both Lifetime Training Group Limited and The IT Skills Management Company Limited.). This scope also extends to the safeguarding of children and adults at risk in settings where our learners are employed

Our learners across all nations include those in EPA, those within sub-contracted provision, and individuals in settings where we deliver services, falling into the category of children or adults at risk. This encompasses specific highlighted safeguarding agenda areas as defined by law, as specified in Keeping Children Safe in Education (2024), and, in the wider context, all our students and learners. This policy is also influenced by and aligns with the requirements set out in ‘The Education Act (2002) Section 175’ and ‘Working Together to Safeguard Children (2023) updated Dec 2023’. Additionally, this policy aligns with the government’s Counter-terrorism and Security Act 2015, which places a duty upon all education providers to consider the need to prevent people from being drawn into terrorism. This Prevent Duty forms part of the wider government’s CONTEST counter-terrorism strategy:

  • Prevent terrorism – stop people from becoming terrorists
  • Pursue terrorism – disrupt and stop terror attacks
  • Protect against terrorism – strengthen UK protection
  • Prepare to deal with terrorism – mitigate the impact of attacks that can’t be stopped.

The Prevent strategy seeks to mitigate the threat of terrorism in the UK by preventing individuals from becoming terrorists or supporting terrorist activities. It has three specific strategic objectives:

  1. Address the ideological challenge of terrorism and the threat posed by those who promote it.
  2. Prevent individuals from being drawn into terrorism while ensuring they receive appropriate advice and support.
  3. Collaborate with sectors and institutions at risk of radicalisation that require our attention.

For more details about how Lifetime meets the Prevent Duty, see our Prevent Policy

4. Key Contacts

The safeguarding team can be contacted via supportme@lifetimetraining.co.uk

Head of Safeguarding and Health and Safety: Michelle Kent – 07795 486090

Safeguarding Board representative – Chief Learning Officer Paul Swindale - 07557431211

External Safeguarding Consultant - Learner Experience Committee Chair, Barbara Van Der Ecken - quality@bvde.co.uk

Additional Designated Safeguarding Officers listed below:

Lois Heighton - Quality Partner & Deputy Safeguarding Lead - 07870 747729

Debra Winder – Social Support Tutor and Deputy Safeguarding Lead - 07469 083838

Alex Butcher – Compliance Officer - 01173142816

Lesley Lacey - Social Support Tutor - 07557 433513

Claire Scott - Management Development Coach - 07970 036234

Sarah Gardner English and Maths Coach 07971397080

5. Definitions

Safeguarding refers to the protection of children and vulnerable adults from abuse and neglect, while promoting health and development, ensuring safety and care, and ensuring optimum life chances.

  • A child is defined as anyone under the age of 18, as cited in the Education Act (2002). Recent attention has been drawn to the fact that some children are treated as adults, particularly regarding the responsibilities placed on teenagers who are being exploited, as well as the adulting of black children and young people. This issue should be given due consideration.
  • An adult at risk, as defined by the Care Act (2014), is anyone over the age of 18 who is at risk of abuse or neglect due to their need for support or personal circumstances.
  • In Scotland, the general definition of a "child" is anyone under the age of 18. This definition is used in the Children and Young People (Scotland) Act 2014. However, specific legal contexts may have different age definitions. For example, the Children's Hearings (Scotland) Act 2011 defines a child as anyone under 16.
  • In Scotland - protected adult The Act, defines 'adults at risk' as individuals, aged 16 years or over, who:
  • are unable to safeguard themselves, their property, rights or other interests;
    • are at risk of harm; and
    • because they are affected by disability, mental disorder, illness or physical or mental infirmity, are more vulnerable to being harmed than others who are not so affected
    • The presence of a particular condition does not automatically mean an adult is an "adult at risk". Someone could have a disability but be able to safeguard their well-being etc. It is important to stress that all three elements of this definition must be met. It is the whole of an adult's particular circumstances which can combine to make then more susceptible to harm than others.

The Safeguarding Agenda encompasses a broad spectrum of potential risks both within and outside apprenticeship settings, at home, and online. (see Appendix F for full definitions and indicators of a Safeguarding concern).

  • Abuse encompasses physical, emotional, financial, institutional, sexual, organisational, and exploitation forms.
  • Self-neglect
  • Discrimination
  • Child sexual exploitation
  • Bullying and cyberbullying
  • Cybercrime
  • Domestic abuse, including what children see, hear or experience.
  • Substance misuse
  • Fabricated or induced Illness
  • Faith abuse
  • Forced marriage
  • Gang and youth violence
  • Private fostering
  • Female genital mutilation (FGM)
  • Gender based violence
  • Radicalisation
  • Sexting
  • Peer-on-Peer abuse, including sexual harassment
  • Relationship abuse, including teenage relationship abuse
  • Trafficking and modern slavery
  • Breast ironing
  • Mental health concerns
  • Sexual violence and sexual harassment, including child-on-child abuse
  • Unexplained and/or persistent absences from education

Alongside the Safeguarding Agenda mentioned above, this may be attributable to, but not limited to, any of the following:

  • Residing in sheltered accommodation
  • Receiving any form of health care
  • Is or has been supported by a social worker
  • Receiving welfare services to support their need for independent living
  • Receiving a service based on their age or disability
  • Residing in residential accommodation like a care home
  • Receiving domiciliary care in their own home
  • An expectant or nursing mother residing in a care home.
  • Individual under the supervision of the probation service

The definitions of a child and an adult at risk provide the rationale for legislative intervention. It is important to note that learners can be temporarily vulnerable due to changes in circumstances or poor mental health. Additionally, a person may be deemed to be at a higher risk of a safeguarding issue affecting them due to various other factors. This is known as Contextual Safeguarding. These areas should be examined thoroughly when planning and agreeing on early help interventions. Areas to explore include:

  • Low-level numeracy and literacy skills, or complex learning needs
  • English is not a first language
  • Unsupportive employers, line managers or colleagues
  • Underrepresentation and/or belonging to one of the ‘nine protected groups’
  • Children and young people exploring their gender identity and/or experiencing gender dysphoria
  • Carrying out the role of caregiver for a family member, which includes young carers
  • A background in offending or displaying signs of being drawn into anti-social or criminal behaviour, including gang involvement and associations with organised crime groups.
  • A visible or hidden disability or social need
  • Having special educational needs (regardless of whether they possess a statutory Education, Health and Care Plan)
  • Lives ‘In Care’, recently transitioned ‘Out of Care’ or is frequently missing/goes missing from care or home
  • Is a privately fostered child
  • Family circumstances presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse, or is generally unsupportive
  • Coming from a Pupil Referral Unit or having been subject to multiple suspensions/exclusions
  • Risk of modern slavery, trafficking, sexual and/or criminal exploitation
  • Risk of being radicalised or exploited
  • Having a parent or carer in custody, or is affected by parental offending, and is misusing alcohol and other drugs themselves
  • Risk of so-called ‘honour’-based abuse, such as Female Genital Mutilation or Forced Marriage

Some groups of learners have been identified as possibility of being more vulnerable, and each has proportionate measures in place to ensure the learners are fully supported should they require additional support . These include learners on an EHCP, Coach Core learners and In Care learners

6. Our responsibility

Safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who comes into contact with children, young people and adults at risk, and their families has a role to play. To fulfil this responsibility effectively, all practitioners should make sure their approach is person-centred and should consider, at all times, what is in their best interests and that it complies with relevant governmental guidance and legislation.

Lifetime has a duty of care to ensure children, young people and adults at risk are protected from harm, are informed about potential risks, and understand and feel confident to seek help. We ensure all concerns are dealt with discreetly, timely and appropriate manner, providing help and support to meet individual needs as soon as concerns are raised. We also have a responsibility to minimise the risk of harm and allegations against Lifetime’s team members.

All staff must comply with and pass the relevant background disclosure checks required by each UK nation. They must have a good understanding of what constitutes a safeguarding or welfare concern and the relevant legislation and government guidance in their country, sector and place of work.

All must have read and understand the requirements of the country in which they work, Keeping Children Safe in Education, 2023 (KCSIE) Part 1 for England and The Children & Young People (Scotland) Act for Scotland and know how to provide support, guidance, and the correct channels for escalating a concern.

Ongoing training and awareness raising will be provided to support confidence and ensure a clear understanding of individual roles and responsibilities as detailed below:

  • Lifetime Directors/Board - to be knowledgeable about safeguarding and to ensure effective policies are in place to protect and safeguard all learners, employer partners and Lifetime team members. They will receive detailed safeguarding reporting to analyse and action plan at each board meeting. Lifetime will comply with relevant data protection legislation and safe and secure archiving policies for each nation, including the Data Protection Act 2018, and the UK General Data Protection Regulation (UK GDPR). They will lead by example and ensure and promote a culture where everyone feels safe, protected and free from harm and has the confidence to speak out or share concerns where needed.
  • CEO - to ensure policies are implemented and observed across Lifetime Group, and sufficient time and resources are allocated to employees to carry out their roles and responsibilities effectively.
  • Head of Safeguarding and Health and Safety – to manage all aspects of welfare, safeguarding and health and safety across the Lifetime Group. To act as the main conduit between national and local multi-agency safeguarding partners, including local authorities, the police, clinical commissioning groups, Prevent Coordinators, and all contractual organisations, employer partners, and other key stakeholders. They will manage legislation and policy changes and inform strategic direction in consultation with the board, including for training, CPD, quality assurance and standardisation. They will manage and support the Designated Safeguarding Team. They will nominate a deputy as and when required.
  • Designated Safeguarding Leads - review procedures and policies on a timely basis and carry out standardisation across case outcomes. They review trends and plan appropriate interventions and resources. They routinely attend internal and external welfare and safeguarding training events to develop and maintain their knowledge and skills to support learners across all nations.
  • Designated Safeguarding Officers – signpost information, advice and guidance, and carry out case investigations and support staff with reported potential and actual welfare and safeguarding concerns, liaising with external bodies where appropriate. All cases are managed and reported discretely with full records kept on a locked SharePoint site for monitoring and trend purposes only, and for reporting at the board and sector level. All cases are anonymised and shared only on a need-to-know basis. CPD is regularly updated to ensure they are competent to carry out the role.
  • Social and Additional Support Tutors – provide specialist support for learners between the ages of 16 and 18 inclusive and those identified as vulnerable or at risk. They advise on child welfare, safeguarding and child protection matters, taking part in strategy discussions and inter-agency meetings, and/or supporting other staff to do so. They contribute to the assessment of children and young people and liaise with schools, social workers, financial institutions, housing associations, and medical representatives, etc, to arrange appropriate interventions and support.
  • Safeguarding Administration support – monitor the supportme inbox twice daily and ensure a Designated Safeguarding Officer is informed about any new concerns within 24 hours. All cases are logged on a confidential spreadsheet and discreetly marked against the relevant learner on Aptem.
  • Mental Health Champions - while their role is supporting employees with their own any wellbeing concerns. They may as part of this role support an employee who is supporting a learner through a welfare or wellbeing concern if it has an effect on their own wellbeing
  • Our Delivery Team (Coaches/Tutors/Pathway Planners and EPAs) - create a culture where learners and employer partners can speak out or share their concerns about potential welfare and safeguarding concerns. They routinely check in on learners and ensure all complete relevant welfare and safety-related activities and life-skills learning within their programme. All are aware of the indicators that there may be a safeguarding issue (Appendix E). If required, they follow the 5 R’s Procedure (Recognise, Respond, Record, Report, Refer) (Appendix D). All have access to support and referral agencies, including the confidential free helpline available for learners, and can report any concerns via the Supportme@lifetimetraining.co.uk e-mail address. Allocated training and CPD are completed as directed by Lifetime.

The topic of safeguarding can be very sensitive due to the content, and may be difficult for people to discuss. If anyone has concerns over issues raised, a member of the Designated Safeguarding team is available to support. The Employee Helpline and Mental Health Champions are also available.

7. Safer Recruitment

Lifetime fully endorses the principles of Safer Recruitment. For a comprehensive list of actions applied when recruiting and employing individuals please refer to The Resourcing Policy Lifetime ensures that all appropriate checks are carried out on new staff who will work or come into contact with children and adults at risk in line with the Disclosure and Barring Service and Teacher Regulation Agency (TRA) requirements, KCSIE and The Children & Young People (Scotland) Act

Lifetime reserves the right to do online checks as part of Safer Recruitment. All recruiting managers complete ‘Safeguarding through Recruitment’ training as part of their Manager onboarding programme. Since November 2023, Trust ID and Experian have managed these processes on behalf of Lifetime. See the Resourcing Policy for further details on Lifetime’s recruitment procedures.

7.1. Disclosure and Barring Service Checks

The Disclosure and Barring Service (DBS) and Disclosure Scotland, which manage the Protecting Vulnerable Children (PVG) Scheme, are government agencies whose primary purpose is to help employers make safer recruitment decisions and appointments.

By conducting checks and providing details of criminal records and other relevant information, DBS/PVG checks help to identify applicants who may be unsuitable for certain work and positions, especially those involving contact with children (those less than 18 years old) or adults at risk.

Depending on the type and regularity of contact with children or adults at risk involved in a particular role, employers are entitled to make appropriate types of enquiries about the applicant’s criminal record and seek a disclosure through either DBS or Disclosure Scotland.

In England, Lifetime can undertake six types of criminal records checks depending on the role applied for:

Standard DBS check

This will be for positions that are included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975.

This type of check contains details of an individual’s convictions, cautions, reprimands or warnings recorded on police central records and includes both ‘spent’ and ‘unspent’ convictions that will be shown on a criminal records check.

Enhanced DBS check

This will be for positions included in both the ROA 1974 Exceptions Order and the Police Act 1997 regulations. This type of check contains the same details as the standard check, plus any information held locally by police forces that is reasonably considered to be relevant to the post applied for.

Enhanced DBS & barred list check (child)

An enhanced check with information from the DBS’s children’s barred list is only available for those individuals engaged in regulated activity with children and a small number of posts as listed in the Police Act 1997 regulations.

Enhanced DBS & barred list check (adult)

An enhanced check with information from the DBS’s adults barred list is only available for those individuals engaged in regulated activity with adults and a small number of posts as listed in the Police Act 1997 regulations.

Enhanced DBS & barred list check (child and adult)

An enhanced check with information from the DBS’s children and adults barred list is only available for those individuals engaged in regulated activity with both vulnerable groups, including children and a small number of posts as listed in the Police Act regulations.

7.2. When and What Type of DBS Check is Appropriate

The Board, in consultation with the Head of Safeguarding and Health and Safety, are responsible for deciding which level of check is appropriate for a particular role and whether barred list checks are necessary. Even where a post has some contact with children or adults at risk, the definition of regulated activity may not be fully satisfied, but to safeguard our learners, any unsupervised contact with learners will result in an enhanced DBS check with the child barred list. The Safeguarding Vulnerable Groups Act 2006 (amended by the Protection of Freedoms Act 2012) defines what types of activities involving children and adults at risk are regulated and therefore require barring list checks. Appendix A specifies current posts at Lifetime that require DBS and/or barring list checks.

Regulated Activity – is a term that defines activities that an individual engages in, defined by the Disclosure and Barring Service. The criteria for regulated activity differ for adults and children:

Children

  • Regular activity (once per week or 4 times over 1 month)
  • Unsupervised activity
  • Teaching, training, assessing, mentoring based activities in relation to non-work-related activities - working intensively and closely with a child
  • Within specified settings

Adult

  • Healthcare professionals – those whose role includes providing first aid
  • Receiving or giving personal assistance to those due to age, illness or disability (going to the toilet/washing/nutritional advice)
  • Providing social care - being subject to or assessing the need for health/social care
  • Assisting in someone’s personal affairs or allowing someone else to do so
  • Assisting with cash, bills and shopping (allowing someone else to or shopping on someone’s behalf)

Read our full safeguarding policy