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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 to 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.

2. Objectives

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

3. Scope

This policy covers safeguarding of Children and Adults at Risk – our learners, learners during EPA, learners within sub-contracted provision, and those persons in settings in where we practise which fall into the category of child or adult at risk. It is inclusive of specific highlighted safeguarding agenda areas – as defined by law, as specified in Keeping Children Safe in Education (2021) and in the wider context all our students and learners. This policy also aligns our compliance with the Government Prevent Duty.

4. Key contacts

The safeguarding team can be contacted on supportme@lifetimetraining.co.uk
Designated Safeguarding Lead: Michelle Kent – 07795 486090

Additional Designated Officers listed below:
Lois Palmer - Quality Coordinator Deputy Safeguarding Lead 07870 747729
Alex Butcher - Compliance Officer 01173 142816
Debra Winder – Social Support Tutor and Deputy Safeguarding Lead 07469 083838
Lesley Lacey - Social Support Tutor 07557 433513
Georgie Bassett - Learning Support Manager 07971 077199
James Birkett - Hospitality Learning Coach 07584 706083
Hayley Allison – Operations Manager Management and Professional Services 077739 32061
Calvin Challenor - Quality Improvement Coach Business and Commerce 07891 182984

5. Definitions

Safeguarding is the protection of children and adults at risk from abuse and neglect, promoting health and development, ensuring safety and care, and ensuring optimum life chances. The Safeguarding Agenda includes a wide range of potential risks (see appendix F for full definitions and indicators of a Safeguarding concern).

  • Abuse (physical, emotional, financial, institutional, sexual, and organisational)
  • Self-neglect
  • Discrimination
  • Child sexual exploitation
  • Bullying and cyberbullying
  • Domestic abuse
  • 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
  • Relationship abuse, including teenage relationship abuse
  • Trafficking and modern slavery
  • Breast ironing
  • Mental health concerns
  • Sexual violence and sexual harassment
  • Children missing in education

A child is defined as anyone under the age of 18. An adult at risk (previously vulnerable adult) is defined as any person over the age of 18 and at risk of abuse or neglect because of their need for support or personal circumstance. Alongside the Safeguarding Agenda above this could be due to, and not limited to any of the following:

  • Living in sheltered housing
  • Receiving any form of health care
  • Receiving a welfare service in order to support their need to live independently
  • Receiving a service due to their age or disability
  • Living in residential accommodation such as a care home
  • Receiving domiciliary care in their own home
  • Expectant or nursing mother living in residential care
  • Person under supervision of probation service

While the definitions of a child and adult at risk give the rationale for legislative intervention, it is important to note that a person may be deemed at higher risk of a safeguarding issue affecting them due to other factors. This is termed contextual safeguarding. Examples of areas to consider are:

  • Poor numeracy and literacy skill, or specific learning need
  • English not a first language
  • Unsupportive employer
  • Under-represented group
  • Acting as a carer for another family member
  • Background in offending or is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement and association with organised crime groups
  • Has a disability or social need
  • Has special educational needs (whether or not they have a statutory Education, Health and Care Plan)
  • Lives ‘In Care’ or has recently transitioned out of Car
  • Is a young carer
  • Is frequently missing/goes missing from care or from home
  • Is within a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse or generally unsupportive
  • A number of groups of learners have been identified as being more vulnerable, and each have proportionate measures in place in order to ensure the learners are fully supported. These include learner on an EHCP, coach core learners and in care learners

6. Our responsibility

We all have a responsibility to ensure that children, young people and adults at risk are protected from harm, informed about potential risks to their welfare, and understand how to seek help. We ensure all concerns are dealt with timely and appropriately. We also have a responsibility to minimise the risk of allegations against you.

All staff are expected comply with any DBS check request and to have a good understanding of what constitutes a safeguarding or welfare concern, how to provide support, guidance in such instances, and the channels for escalating a concern. To assist you in this, on-going training and awareness, as well as continuous information, advice and guidance will help you to feel confident in proactively promoting safeguarding and understanding your individual responsibilities.

The responsibilities of particular individuals are detailed below:

  • Our Directors - to ensure we have effective policies.
  • Our CEO - to ensure policies are implemented and followed, and sufficient time and resources are allocated to employees to carry out their responsibilities.
  • Designated Safeguarding Lead – to maintain links with local multi-agency safeguarding partners (local authorities, chief officers of police, and clinical commissioning groups), and Prevent Coordinators, inform and advise all parties on legislation changes and current safeguarding themes, plan and implement training for all employees including CPD, quality assurance and standardisation for the designed safeguarding officer team. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as safeguarding board where appropriate. Support and coordinate escalation process. Overall management of safeguarding issues and report to board on any issues that arise. Review procedures and policies on a timely basis. Maintain own CPD to ensure their role can be fulfilled competently. They will also provide advice and support to other staff 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, and to contributing to the assessment of children. The will lead on policy and training, making referrals to external agencies such as Local children’s social care/Chanel/ Police and DBS. Have awareness of those children that are in need and how their education is impacted and progressing, this includes children allocated a social worker where this has been alerted to Lifetime . Oversee information security for Safeguarding and work with the Data protection team where required. The lead will also nominate and ensure Deputy Designated safeguarding leads are in place and trained to the same level
  • Designated Safeguarding Officers – to deal with employee concerns over learners’ welfare, signpost and offer guidance. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as local multi-agency safeguarding partnerships (local authorities, chief officers of police, and clinical commissioning groups) where appropriate. Maintain own CPD to ensure their role can be fulfilled competently and seek guidance where appropriate.
  • Safeguarding Administration support – monitor the supportme inbox twice daily and ensure a designated safeguarding officer is informed about any new concerns within 24 hours.
  • Our Coaches/Tutors and EPAs - to check safety and welfare with all learners at each visit/communication, ensuring learners complete all safety-related learning activities within their programme. You must be aware of indicators and that there may be a safeguarding issue – see Appendix E, and if required to follow the 5 R’s procedure - our flow chart for reporting issues that concern them or are reported to them (see Appendix D). To provide support and referral to external agencies as they see fit, if comfortable to do so, and then inform safeguarding team of their actions. To carry out training as directed by the safeguarding team in a timely manner.
  • Support Teams - You must be mindful of indicators that there may be a safeguarding issue should you come into contact with a learner or potential learner – see Appendix E, and if required to follow the 5 R’s procedure - our flow chart for reporting issues that concern them or are reported to them (see Appendix D). To carry out training as directed by the safeguarding team in a timely manner.

The topic of Safeguarding can be very sensitive due to the content and may be difficult for you to discuss. If you have any concerns over issues raised, please contact a Designated Officer as quickly as possible.

7. Safer recruitment

Lifetime undertake a range of Safer recruitment practises throughout the recruitment process including sharing our commitment to Safeguarding in job adverts, a thorough interview process and collation of references Lifetime carries out a safe recruitment process and ensures that all appropriate checks are carried out on new staff that will work or come into contact with children and adults at risk in line with the Disclosure and Barring Service requirements. All recruiting managers go through ‘Hiring Right First time ‘training which includes an interview workshop around safer recruitment practices which is part of their Manager on boarding programme See resourcing policy for further detail on recruitment procedures.

7.1. Disclosure and barring service checks

The Disclosure and Barring Service (DBS) and Disclosure Scotland are an executive agency of the Home Office and its 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 helps 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 enquiry about the applicant’s criminal record and seek a disclosure through a DBS or PVG check. 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 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 in 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 it 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’ 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.

Scotland - protecting vulnerable groups scheme (PVG)

In Scotland all employees engaging in regulated activity are obliged to have a membership of the PVG scheme, this is facilitated through our Umbrella partner.

7.2 When and what type of DBS check is appropriate

Lifetime’s HR Senior Business Partner and Designated Safeguarding Lead 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 in order to safeguard our learners any unsupervised contact with learners will result in an enhanced DBS check with 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. The criteria for regulated activity differ for adults and children as shown overleaf:

Children

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

Adult

  • Healthcare professionals - giving first aid or receiving 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
  • Providing assistance in someone’s personal affairs or allowing someone else to do so
  • Provide assistance with cash, bills and shopping (allowing someone else to or shopping on someone’s behalf)
  • Person who transports or is transported because of their illness

Scotland - there are 2 types of regulated work – work with children and work with protected adults. Regulated work is usually jobs including:

  • Caring responsibilities
  • Teaching or supervising children and/or protected adults
  • Providing personal services to children and/or protected adults
  • Working directly with children and/or protected adults

Individuals must not engage in regulated activity with either children or adults at risk if they have been barred from doing so by the Disclosure and Barring Service (DBS) or PVG scheme. How we meet our responsibility towards this is explained below. Further advice on types of DBS disclosure and the circumstances in which regulated activity applies can be obtained from the HR Team.

Where Lifetime is recruiting for a role that qualifies for a DBS/PVG disclosure, the advert and further information during the interview process will confirm the type of DBS disclosure required. When the most suitable candidate for the position has been identified, the offer of appointment will be made subject to a satisfactory DBS/PVG, right to work, references and qualification checks. In the instance that the outcome of a DBS/PVG check has not been received from the appropriate authority prior to learner visits being carried out, all visits with learners aged below 18 will be supervised by a person whose DBS outcome has been received and approved. The Area Manager will be responsible for arranging this supervision. Quality assurance of this process will take place on a weekly basis.

As a DBS/PVG check forms part of our recruitment process, we encourage all candidates to declare anything relevant to the type of disclosure required for the role. Once an offer has been made, candidates should tell us of any further details of convictions, including those that normally would be considered as spent, cautions or reprimands.

As part of our safeguarding obligations, we will re-apply for the appropriate types of DBS/PVG checks on a 3-year basis during employment with Lifetime Training. If someone is already part of the update service:

  • DBS – we request an updated check for that number
  • PVG – a short scheme record will be applied for

Where contractual requirements dictate an annual declaration from employees is required in relation to conforming any changes that may affect the outcome of their DBS check. Any changes will be risk assessed following the procedure set out in 7.5

7.3 Confidentiality

Information provided in a DBS disclosure report must be kept confidential and only on a need-to-know basis. Such information will be handled in accordance with Lifetime’s ‘Statement on the Secure Storage, Handling, Use, Retention and Disposal of Disclosures and Disclosure Information’, Appendix B. Any other information regarding offences must be kept securely and in accordance with Lifetime’s Data Protection Policy.

We recognise that job applicants and our employees need to feel confident that information about their convictions will not be disclosed to colleagues unless there is a specific reason for doing so. Those involved in recruitment decisions should ensure that when appointing an individual with a conviction, they are advised as to whom within Lifetime knows of their conviction and the reasons why the information has been disclosed.

First standards have a satisfactory privacy policy to align with our requirements

If you would like further information on our disclosure process, please see Appendix C.

7.4. Failure to disclose information relevant to the type of DBS check appropriate to your role

Having a criminal record does not necessarily preclude an individual from working at Lifetime. The decision as to whether a person with a criminal record should be appointed, or an offer of employment withdrawn, or employment terminated will be taken only after careful and thorough consideration of the outcome of any DBS check as well as the job and offence related factors as explained in 8.6.

Nonetheless we request all employees to tell us about any information relevant to the type of DBS check appropriate for their role. This could mean, for example, that if your role requires satisfactory Enhanced DBS and barring check, you need to tell us about any convictions, cautions or reprimands or being barred from working with children as soon as any of these have been issued. Failure to disclose information relevant to the type of DBS check appropriate to your role would be seen by Lifetime as a breach of trust and confidence. Such acts are considered as gross misconduct and you would be invited to a disciplinary hearing with a potential outcome of instant dismissal.

7.5 Exploring the relevant of information provided in the disclosure report

As we explained in the previous section having a criminal record does not necessarily preclude an individual from working at Lifetime. The decision as to whether a candidate with a criminal record should be appointed, or an offer of employment withdrawn, will be taken only after careful and thorough consideration of the outcome of any DBS check as well as the job and offence related factors as explained in section 8.6.

Similar to the recruitment process, a disclosure of a criminal record will not necessarily lead to termination of your employment with us and the decision will be taken only after careful and thorough consideration of the job and offence related factors. Any decision to terminate employment would follow our Disciplinary Policy (or Probationary Policy if you have not yet passed your probation).

A member of the HR Team, alongside the Designated Safeguarding, Lead will make an initial assessment of the content of the disclosure report. If the report provides no evidence of convictions or any other related information, no further action will be taken. If the report confirms a conviction or any other related information, a member of HR Team, alongside the Designated Safeguarding Lead, will make an initial assessment of whether the information provided has any potential relevance to the post. If there is clearly no potential relevance, no further action will be taken.

If the report confirms a potentially relevant conviction or any other potentially relevant information further exploration will be required following the process outlined below.

7.6. Exploring a conviction and its relevance

All discussions relating to convictions must take place after the selection process has been completed and will involve the line manager and a member of the HR Team and, if appropriate, the company Designated Safeguarding Lead. As part of the decision-making process they will normally meet with the individual to gain more information from the person about the nature and circumstances of any conviction.

The suitability for employment of a person with a criminal record will clearly vary, depending upon the nature of the job and the details and circumstances of any convictions. The decision will be made on the basis of a risk assessment to enable the applicant’s criminal record and circumstances to be assessed in relation to the tasks he or she will be required to perform and the circumstances in which the work is to be carried out. The following job-related factors should be taken into account:

  • Does the post involve direct contact with learners or the public?
  • What level of supervision will the post-holder receive?
  • What level of trust is involved? Will the nature of the job present any opportunities for the post-holder to reoffend in the place of work?
  • Does the post involve any direct responsibility for finance or items of value?
  • Does the post involve any contact with children or other vulnerable groups of learners or employees?

The assessment is also likely to include consideration of the following factors relating to the individual’s offence(s):

  • The seriousness of the offence(s) and relevance to the safety of other employees, students, research subjects, the public etc.
  • The length of time since the offence(s) occurred.
  • Relevant information offered by the person about the circumstances that led to the offence(s) being committed, for example the influence of domestic or financial difficulties.
  • The degree of remorse, or otherwise, expressed by the person and their motivation to change;
  • Whether the offence was a one-off, or part of a history of offending.
  • Whether person’s circumstances have changed since the offence(s) was committed, making re-offending less likely.
  • Whether the offence has since been decriminalised.

Following careful and thorough consideration of all these matters and consultation with the HR Director and Designated Safeguarding Lead, a decision will be made as to whether the individual should be appointed. If appropriate we may seek further information from relevant bodies when reaching this decision. If the decision is not to appoint, a letter will be sent to the individual confirming the reasons for this decision.

The above process will also be followed in the event of a criminal conviction coming to light after the formal offer of employment has been made or during employment. In such cases Lifetime would reserve the right to withdraw the offer of appointment where appropriate or terminate employment in line with the Lifetime’s Disciplinary Policy (or Probationary Policy if in probationary period).

7.7. Learner DBS checks

We have a duty to ensure that learners understand what a DBS check is and if it is required for their role. The employer is ultimately responsible for ensuring anyone they employ has the necessary checks in place. However, we do support employers to engage with the Disclosure and Barring Service to fully understand their role and responsibility.

Work Based Learning - Each employer partner site undergoes a H&S vetting process, this requires the coach to check the mandatory legislative DBS requirements are understood by the learner and employer . The coach will discuss with the learner and manager that understand that they hold suitable DBS checks. The leaners curriculum is contextualised to their work setting and also reinforces the importance of the DBS process.

Adult Learning Loan learners – for those learners who are studying an adult learning loan programme information, advice and guidance regarding the requirement of DBS check learners is provided with during enrolment and learners are made aware of the requirement for of DBS when they enter into employment. During the leaners programme relevant curriculum content educates learners about the importance of the DBS process.

8. Reporting a concern - see appendices D in full report for process charts

a. If a learner raises a concern/allegation with you: If the learner has a concern over their own personal welfare and wellbeing, you are to listen to and record all information given, making no judgement or assumptions. Take any actions required to secure the immediate safety of the child or adult at risk if deemed appropriate, this may involve staying with them until a responsible adult can be located. This will only be recorded on the TAPR, if learner agrees and raised with the manager, if learner agrees. If the learner gives consent you must report the issue to a designated officer. If you feel the learner’s safety and wellbeing are at risk and they do not give consent for the matter to be escalated, you should escalate only when you believe the matter would deteriorate if additional support was not sourced. You should always consider the wishes of the individual, even those aged under 18. Guidance should be sourced with a safeguarding officer if you are unsure. The designated officer will then decide the appropriate course of action, and if a referral outside the organisation is appropriate. (D1)

b. If a Coach /Tutor/EPA has concerns over a learner: This might be through observation, alleged by others of discussion. To follow procedure set out as point (a) if a learner raises an issue/allegation with the RT. (D1)

c. If a learner/parent has a concern/allegation about a member of Lifetime or Innovate staff: All learners are to be informed that if they have a concern over their own personal welfare and wellbeing that they do not feel comfortable talking to their coach /tutor about, they are to contact Lifetime’s Designated Officer. Contact details for the designated person are available in this policy, the information, advice and guidance section on FUSE (Lifetime’s online social learning platform), and on the online learning compliance courses, and the welfare cards with additional details on. See section 9 for more detail on how concerns over employees are managed including Low level concerns ( D2)

d. The safeguarding policy is also available on Lifetime’s external website. (D2)

e. If a parent contacts you to report a concern about their child, ensure you listen and record the details as per a learner reporting a concern to you. Ensure you have contact details for the parent. You must report the issue to the designated officer. The designated officer will then decide the appropriate course of action, and if a referral outside the organisation is appropriate, liaise with the parent as appropriate. Be mindful of confidentiality as all learners aged 16 and above, and of employed status are deemed to be adults, and therefore no information should be passed to parents or carers without prior consent to do so from the learner. (D1/2)

f. If you observe a safeguarding issue taking place within the working practices of an employer’s setting or during Lifetime group delivery sessions - example would be a practitioner hitting a child or observing inappropriate restraint techniques, or learners verbally or physically abusing each other. Take action to stop the activity immediately, and inform the individual of your concerns, ask them to remove themselves from the area and advise them you will inform their senior manager. In those cases where learners are not on work-based learning programme inform the safeguarding team. Take any actions to secure the safety of the child or adult at risk, this may involve staying with them until a responsible adult can be located. Inform your designated safeguarding officer in all cases. Be mindful of differences between poor practice and a safeguarding issue and apply your action appropriately. (D3)

g. If a learner reports unsafe practices or safeguarding issues to you within their working/learning environment - advise the learner to follow in-house reporting or whistle blowing procedures. If it is related to a Lifetime learner activity session, follow Lifetime’s safeguarding reporting procedures. You may support the learner in speaking to the appropriate senior team members if appropriate. Report the incident to your designated safeguarding officer who will offer additional guidance and signposting for the learner and will monitor. (D3)

It is important you do not pass any information to other parties or try to investigate the concern yourself. All concerns should be reported to supportme@lifetimetraining.co.uk in the first instance.

  • If you require an immediate response call your sector designated safeguarding officer immediately, it is noted that the designated officer may not be available out of normal working hours, so in circumstances where the individual is in immediate danger report the incident to the police on 999.
  • The designated officer will endeavour to make initial contact with regards the concerns within 24 hours ( not including weekends). Outside of working hours the learner welfare helpline operates 24 hours a day 7 days per week and can be contacted at any time for support and is signposted through supportme
  • The designated officer will assess if the individual is at risk of significant harm and decide upon the next course of action, this can range from offering signposting to support agencies to referral to the police and local safeguarding authorities. This may also involve passing information to the DBS.
  • Also be mindful of any subcontract arrangements in place for the learner. In some instances, safeguarding officers at other companies might need to be informed. Ensure you pass to the safeguarding officer the name of the subcontractor (e.g. McDonalds, Cambrian training). For employer providers we partner with, their safeguarding officer must be informed, and they take the lead in dealing with the concern. We will support where required.
  • If you feel a designated safeguarding officer has not complied with their duty of care to a reported learner concern, please contact the designated safeguarding lead identified in this policy. If you feel the designated safeguarding lead has not complied with their duty of care to a reported learner concern, please contact the Quality Director. You may also escalate the concern yourself to the relevant external agency (See Appendices D and E in full report for process of reporting)

9. Managing allegations against employees

Part 4 of DFE guidance ‘Keeping Children Safe In Education’ (September 2021) sets out revised procedures for managing safeguarding allegations or concerns against teaching staff, other staff, volunteers and contractors. In this revised guidance training providers are now expected to respond to two levels of concern about staff behaviour:
(1) Behaviour that meets a perceived ‘harms’ threshold and
(2) Behaviour judged as a ’low level’ concern’ that does not meet the ‘harms’ threshold.

It is Lifetime’s intention to create a culture in which all concerns about adults (including allegations that do not meet the harms threshold) are shared responsibly and with the right person, recorded and dealt with appropriately. We aim to create and embed a culture of openness, trust and transparency in which our expected behaviours which are set out in the staff Code of Conduct are constantly lived, monitored and reinforced by all employees.

Alongside our Code of Conduct and Safeguarding polices which detail the expected behaviours Lifetime will also:

  • Ensure that employees are clear about what is appropriate behaviour through awareness and training
  • Create an environment where employees feel confident in sharing low-level concerns, and are comfortable to self-refer, 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.
  • Address unprofessional behaviour and supporting the individual to correct it.
  • Ensure a responsive and proportionate handling of such concerns.
  • Through case analysis identify any business improvements required

Alongside the processes below employees are also able to report concerns through Lifetime’s Whistleblowing line, following the whistleblowing procedure detailed in the Whistleblowing policy

9a Allegations that may meet the harms threshold

Lifetime will consider that behaviour meets the harms threshold to be if; employees – including employees on temporary contracts, volunteers or contractors have:

  • Behaved in a way that has harmed a learner or may have harmed.
  • Possibly committed a criminal offence against or related to a learner.
  • Behaved in a way that may pose a risk of harm to a learner.
  • Behaved in a way that indicates they may not be suitable to work with learner

If a safeguarding allegation or concern is reported about another member of staff (including staff on temporary contracts, volunteers, and contractors) posing a risk of harm to a learner, this should be reported to the Designated Safeguarding Lead (DSL) . Where there are concerns/allegations about the Safeguarding Lead this should be referred to HR.

If the allegation identifies that a learner has been harmed, is at immediate risk of harm or is an emergency situation, the DSL will contact social care services and where appropriate the police immediately. They will also ensure that:

  • The learners affected are safe.
  • Inform and support the person subject to the allegation as soon as possible.
  • Conduct basic enquiries to establish the facts to help them determine whether there is any foundation to the allegation. The designated safeguarding lead will collect as much evidence as possible by speaking directly to the person who raised the concern (unless raised anonymously), to the individual involved and any witnesses. The information collected will be reviewed against the employee code of conduct, then determine what further action may need to be taken.
  • Liaise with the Local authority Designated Officer (LADO) to consider the allegation and agree a course of action.
    o Internal investigation carried out where appropriate aligning with misconduct policy
  • Work with the HR team to implement any internal disciplinary procedures where required
  • Work with HR to support the subject of the allegation
  • All relevant information is shared with police/ social care
  • Any parent/ guardian/ employer is informed and updated where required
  • Where a concern is raised about the designated safeguarding lead, it should be reported to HR. HR will then lead on the processes detailed above.

All reports will be recorded in Lifetime’s case management system (MILO)

9b. Low level concerns that do not meet the harm threshold

A low-level concern is any concern that an adult working in or on behalf of Lifetime Training may have acted in a way that is inconsistent with the staff code of conduct (including inappropriate conduct outside of work) but does not meet the harms allegations threshold. Examples of such behaviour could include, but are not limited to: offering personal favours to learners, being overly friendly, using inappropriate language or sharing personal information

Lifetime will seek to identify and deal with inappropriate behaviour early, in order to mitigate the risk of abuse. Low-level concerns about a member of staff, volunteer or contractor should be reported to the designated safeguarding lead (or deputy). Where a low-level concern is raised about the designated safeguarding lead, it should be reported to HR. The designated safeguarding lead will collect as much evidence as possible by speaking directly to the person who raised the concern (unless raised anonymously), to the individual involved and any witnesses. The information collected will be reviewed against the employee code of conduct, then determine what further action may need to be taken, including liaising with HR should the disciplinary policy need to be followed .

All low-level concerns should be recorded in MILO Case Management system by the designated safeguarding lead (or deputy).

Records will be reviewed periodically so that potential patterns of concerning behaviour can be identified. Where a pattern of such behaviour is identified (including where low level concern move to meeting the harms threshold) Lifetime will decide on a course of action.

10. Training and educating employees

Each member of the safeguarding team holds a formal L2 safeguarding qualification and undertakes regular CPD events and standardisation meetings in order to keep updated with legislation and refresh their knowledge.

All employees undertake a Safeguarding Induction and/or completion of a L2 online course specifically for Safeguarding Young Vulnerable People.

All coaches also complete:

  • IAO Level 1 Award in Principles of Safeguarding in a Learning Environment
  • Qualification Number: 603/5287/5 as part of their L4 Assessor Coach qualification

The training received is continually reviewed to ensure most appropriate and up to date training is given. Aligning with the mandatory duty surrounding the Government’s Counter Terrorism and Security Act 2015 all staff undertake Prevent training aligning with their role within Lifetime.

There is annual CPD training for formal procedures and emerging themes . Periodic updates surrounding key safeguarding concepts are communicated monthly via the internal communication channels. Monthly focus topics are also distributed via these internal communication channels to raise awareness and promote discussion in all areas under the wider safeguarding agenda including areas such as radicalisation, mental health issues, positive relationships, and staying safe on the internet, which will educate employees alongside giving greater knowledge to be passed onto learners.

There is reference to safeguarding in all team meetings – carried out bi-monthly, with managers utilising the information in the monthly safeguarding and equality newsletters (Thrive) as well as a health and safety section, to stem discussions.

Key individuals involved in staff recruitment complete and in-house safer recruitment training course annually, which informs Hiring Right First time training all line manager receive, referred to in Safer recruitment.

11. Keeping yourself safe

To maintain yours and the learner’s safety, the following are strictly prohibited:

  • Befriending learners on personal social media sites
  • Distributing personal telephone numbers
  • Visit learners at home or transporting learners to and from locations (this includes travelling in a car with a learner driving)
  • Directing sarcasm, insults or belittling comments towards learners
  • Personal relationships with learners

It also important to be mindful of the following when conducting yourself:

  • Locations of one-to-one meetings with colleagues. These should take place at a neutral location
  • You will naturally build a rapport with learners through the apprenticeship contact, and the learners may see you as a confidante and support but be sure to maintain professional boundaries whenever carrying out work on Lifetime’s behalf.
  • Be respectful of all young and vulnerable people, and appreciate you are in a position of trust. We have the opportunity to listen to their concerns and support them.
  • Uphold confidentiality within certain remits when required by the situation but be careful not to promise to keep secrets or ask others to do so.
  • Avoid spending time alone with learners in a closed environment. If this is unavoidable for example during a formal assessment/examination, ensure a member of the site staff is aware where you are and monitors this.
  • Be careful when giving learner advice – as this is based on your opinion, focus support around information (facts), and guidance (signposting)..
  • Be mindful of any learners you acquire that by default creates a conflict of interest, i.e. a partner or friend becomes a learner. Discuss appropriateness/alternative trainer arrangements with your line manager.
  • If a learner offers you gifts of any sort as a result of the support through their programme, please refer to the bribery policy for the process to follow.
  • If at any point you feel unsafe in a learner’s company inform the site manager, your line manager, the designated safeguarding officer and leave the premises.

12. Keeping learners safe

Lifetime offer an apprenticeship recruitment service which places potential apprenticeship learners into employment. It is recognised that this creates a greater duty of care, and in order for Lifetime to ensure that employers are suitable to receive an apprentice, a service level agreement is undertaken prior to apprentice commencing employment, in order to clarify expectation in relation to basic health and safety, and employment requirements for the learner.

There is an employer guide to welfare that is available to employers to help them understand Lifetime and their own responsibilities under Safeguarding, health and safety and Prevent Agenda.

Health and safety vetting is carried out during learner induction, this involves a discussion between the Regional Trainer, employer and learner, and allows for the trainer to be confident in the employer’s ability to keep the learner safe during their employment, and also to help educate the learner in looking after their own welfare, and that of others, while at work. Its supports H&S, and other essential legislative requirements such as a need for some leamers to have a DBS check and a COVID 19 vaccination

Learners are made aware of all of Lifetime’s relevant policies, who the designated persons are and how to report a concern during their induction to the programme. There is also a dedicated support site on the learner information portal/learning community to signpost to information, advice, and guidance for a wide range of support needs, and a direct email address to allow the learners to access support from the designated safeguarding officer confidentially. For APTEM registered learners - an essential information guide containing the same information is made available during the enrolment process

Learners are issued with a learner welfare card/ flyer detailing both internal and external support services. This contains contact details for police, Lifetime head office and direct link to the safeguarding team. It also provides details of an external learner welfare assistance programme, which is a 24-hour confidential helpline which will provide learners with a counselling service, or signposting to relevant support experts should they require it. During the COVID 19 pandemic the learner helpline flyer is distributed to compliment remote working and avoid close contact

APTEM registered learners complete a mandatory Life Skills Learning plan which covers a range of welfare and wellbeing issues, and allows for review and further discussion with coaches where appropriate. Monthly topics in relation to equality and diversity and safeguarding are highlighted by an externally written newsletter which appears alongside internal Information advice on guidance on a range welfare issues in the CSR newsletter Thrive . Learning translated to learners surrounding these activities is discussed and documented at each visit, along with pastoral checks.

Online Safety is being aware of the nature of the possible threats that you could encounter whilst engaging in activity through the Internet, these could be security threats, protecting and managing your personal data, online reputation management, and avoiding harmful or illegal content. These might manifest as online abuse, bullying, threats, impersonation, grooming, harassment or exposure to offensive and/or violent content. We currently educate learners around online dangers through a variety of avenues including our My Life Code of conduct which all learners need to read and sign prior to registration. They all have access to the Digital Literacy and Online Safety sections of My Life and signposted to when relevant. Periodically our Safeguarding newsletters cover online safety topics. These are used by trainers as educational sessions for learners. This will be complimented with the launch of APTEM later in 2021 with a mandatory section on online safety .To ensure we monitor and act upon accessing of inappropriate content and comments, filtering systems are in place on distributed learner devices and our social media platforms .

Peer-on-Peer abuse/ Sexual Harassment and Violence between children . As a result of Ofsted’s review into sexual abuse in schools, additional training for learner facing employees has taken place related to identification and action required for incidents of this nature including presence of accepted norms and the need to change this, and making learners aware of what constitutes sexual harassment and abuse both face-to-face and online. Thisincludes sexual harassment and violence in the workplace This is through a variety of means including CPD and awareness newsletters

Mental Health

The increased importance of supporting poor mental health has been seen through the increased prevalence of mental health concerns raised by learners both as the sole issue and also as an associated issue as a result of experiencing another safeguarding issue. All learners have access to the Learner Welfare Helpline wich provides counselling if required and are provided with bespke support where required They are encouraged to seek support from their employers where appropriate who in the main have robust support networks in place.

Learner Accidents

If the learner is employed or in the workplace at the time, the overall responsibility to investigate lies with the employer, but Lifetime will still investigate the incident. If out of the workplace whilst under supervision of Lifetime – Lifetime have overall responsibility to investigate.

1. Learner or employer to report the accident or fatality to RT/Tutor
2. RT/Tutor to complete the accident reporting form, located:
a. Fuse/ Learner Welfare/
3. Send the form to Welfare Manager within 5 days of being notified by the learner
4. Welfare Manager to apply any follow up if required

Learner risk assessment

To ensure Lifetime support the health and safety of all learns in certain situations Lifetime may risk assess support requirements for learners , e.g. a medical condition has been declared, learner has been subject to sexual harassment/ violence or is on bail

Subcontracts

Where Lifetime acts a lead provider, providing funding to other companies, Lifetime will endeavour to provide appropriate training and guidance to subcontracts to ensure Lifetime policies and procedures are followed, alongside the due diligence checks carried out. This will be monitored (see Subcontracting Quality Assurance Manual).

Where Lifetime acts as a subcontract to other companies - Lifetime Training will commit to upholding the policies and procedures of the training provider/college which holds the funding. Lifetime will also attend any relevant training/updates, adhere to monitoring requirements, be aware of and adhere to funding regulations as set out by the different funding authorities.

12. Leadership and Management

A dedicated safeguarding board, including all of the Senior Management team, meet quarterly as part of a Quality Board providing a greater focus on safeguarding and safety of learners.

The effectiveness of all welfare support and educational material is analysed periodically by Learner Voice and an annual learner welfare working group. Learner welfare audit reviews all processes and material.

The safeguarding officer team are also subject to Quality Assurance checks carried out by the Safeguarding Lead.

13. Associated policies

  • Equality and Diversity Policy
  • Grievance Policy
  • Disciplinary Policy
  • Social Networking and Media Policy
  • Prevent Policy
  • Resourcing Policy
  • Bribery Policy

View full policy