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.
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.
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 (2023) 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 email@example.com
Designated Safeguarding Lead: Michelle Kent –07795 486090
Designated Safeguarding Lead – Devolved - Theresa Vincent 07891182976
Additional Designated Safeguarding Officers listed below -
Lois Heighton - Quality Coordinator 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
James Birkett – Hospitality Learning coach 07584 706083
Safeguarding is the protection of children and of 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)
- 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
- 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
- Children missing in education
A child is defined as anyone under the age of 18. An adult at risk 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 risks 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 Care
- 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 background disclosure 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 be knowledgeable about safeguarding and to ensure we have effective policies To receive reports on safeguarding at each board meeting.
- 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 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. They will lead on policy and training, making referrals to external agencies such as Local Authority 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. They will also pass this information where relevant to a learner’s new training provider if they leave a Lifetime programme. When informed, oversee information security for safeguarding and work with the data protection team where required. The lead will also nominate and ensure Deputy Designated Safeguarding Officers are in place and trained to the same level. They will also report to the Board on safeguarding.
- 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 Regional Prevent Coordinators, local multi-agency safeguarding partnerships (which constitute local authorities, chief officers of police, 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 complete allocated 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 complete allocated 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 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. From November 2023 onwards Trust ID and Experian manage these processes on behalf of Lifetime . See resourcing policy for more detail.
7.1. Disclosure and Barring Service Checks
The Disclosure and Barring Service (DBS) and Disclosure Scotland (who manage the Protecting Vulnerable Children Scheme (PVG)) are executive agencies of the UK and Scottish governments 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 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 enquiries 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 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 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’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.
Scotland - Protecting Vulnerable Groups scheme (PVG)
In Scotland all employees engaging in regulated activity are obliged to have a membership of the PVG scheme.
7.2. When and What Type of DBS Check is Appropriate
Lifetime’s People 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:
- 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 settings
- 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
- 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 DBS or PVG scheme. How we meet our responsibility towards this is explained below. Further advice on types of DBS/PVG disclosure and the circumstances in which regulated activity applies can be obtained from the People Team.
Where Lifetime is recruiting for a role that qualifies for a DBS/PVG check, the advert and further information during the interview process will confirm the type of check 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 check, right to work, references and qualification checks. In the instance that the outcome of a DBS/PVG check has not yet 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 is in place
As a DBS/PVG check forms part of our recruitment process, we encourage all candidates to declare anything relevant to the type of check 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
Some contractual requirements dictate an annual declaration from employees in relation to conforming to any changes that may affect the outcome of their DBS/PVC check. Any changes will be risk assessed following the procedure set out in 7.5
Information provided in a disclosure report must be kept confidential and 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.
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/PVG 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/PVC 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/PVG check appropriate for their role. This could mean, for example, that if your role requires satisfactory Enhanced DBS/PVC 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/PVG 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 Relevance 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/PVG 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 People 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 relevant information, no further action will be taken. If the report confirms a conviction or any other relevant information, a member of People 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 People Team and the 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 the person’s circumstances have changed since the offence(s) was(were) 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 People 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/PVG checks
We have a duty to ensure that learners understand what a DBS/PVG 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 DBS/PVG 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/PVG requirements are understood by the learner and employer in the relevant sectors . The leaners curriculum is contextualised to their work setting and reinforces the importance of the DBS/PVG process.
8. Reporting a Concern - see Appendices D for Process Charts
- 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 review if learner agrees and raised with the manager if learner agrees. If the learner gives consent, you must report the issue to a Designated Safeguarding Officer. You should always consider the wishes of the individual, even those aged under 18 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 work with the learner to encourage this.
If no consent agreed you should still consider escalation, this could be by learner details being anonymised. If a learner is at risk of harm; getting them the correct support is likely to be more important than maintaining their confidentiality.. Guidance should be sourced with a Designated Safeguarding Officer if you are unsure. They will then decide the appropriate course of action, and if a referral for early help intervention or to local authority . (D1)
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) above if a learner raises an issue/allegation with the RT (?). (D1)
- 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 a Lifetime Designated Safeguarding Officer. Contact details are available in this policy (see section 4 above), the learner welfare section on huddle, and the essential information section in Aptem. See section 9 for more detail on how concerns over employees are managed including low level concerns ( D2)
- This safeguarding policy is also available on Lifetime’s external website. (D2)
- If a parent contacts you to report a concern about their child: Ensure you listen and record the details in the same way as a learner reporting a concern to you (see (a) above). Ensure you have contact details for the parent. You must report the issue to the Designated Safeguarding Officer. They 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)
- If you observe a safeguarding issue taking place within the working practices of an employer’s setting or during Lifetime group delivery sessions: An 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 a 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)
- 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 firstname.lastname@example.org in the first instance using the Disclosure reporting form ( appendix G) .
- If you require an immediate response, call a 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 Safeguarding Officer will endeavour to make initial contact regarding the concern 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 helpline number is 0300 666 7247
- The Designated Safeguarding 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/PVG.
- 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. 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 (section 4 above). 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 for process of reporting)
9. Managing ALlegations against employees
The Department for Education guidance sets out procedures for managing safeguarding allegations or concerns against teaching staff, other staff, volunteers and contractors. In this 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 policy which detail 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 if employees – including employees on temporary contracts, volunteers or contractors - have:
- Behaved in a way that has harmed a learner or may have harmed them.
- Possibly committed a criminal offence against 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 learners.
Safeguarding allegations or concerns arising from the above 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/concern identifies that a learner has been harmed, is at immediate risk of harm or is an emergency situation, the DSL (or People team as appropriate) will immediately contact social care services and where appropriate, the police. 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. They 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 to determine what further action may need to be taken, including liaising with HR should the disciplinary policy need to be followed.
- If appropriate, liaise with the Local authority Designated Officer to consider the allegation and agree a course of action.
- If appropriate, conduct an internal investigation carried out aligning with misconduct policy.
- Work with the People team to implement any internal disciplinary procedures where required.
- Work with the People team to support the subject of the allegation.
- All relevant information is shared with police/social care if appropriate.
- Any parent/ guardian/ employer is informed and updated where required.
All concerns should be recorded in MILO Case Management system by the DSL (or deputy).
9b. LOW LEVEL CONCERNS THAT DO NOT MEET THE HARM THRESHOLD
A low-level concern is any concern about employees – including employees on temporary contracts, volunteers or contractors - who 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 to mitigate the risk of abuse. Low-level concerns should be reported to the DSL (or a deputy). Where a low-level concern is raised about the DSL, it should be reported to HR. The DSL (or People team as appropriate) 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 to determine what further action may need to be taken, including liaising with HR should the disciplinary policy need to be followed.
All concerns should be recorded in MILO Case Management system by the DSL (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 at least a formal L2 designated officer 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/ EAT L3
The training received is continually reviewed to ensure the most appropriate and up to date training is given. Aligning with the mandatory duty surrounding the 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 internal communication channels. Monthly focus topics are also distributed via these 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 team meetings –, 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 an 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 your and learners’ safety, the following are strictly prohibited:
- Befriending learners on personal social media sites
- Distributing personal telephone numbers
- Visiting 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 apprenticeship contact, and the learners may see you as a confidante and supportive 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 duty of care for Lifetime to ensure that employers are suitable to receive an apprentice.
To this end:
- A service level agreement is undertaken prior to an apprentice commencing employment to clarify expectations in relation to basic health and safety, and other 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 agendas.
- Health and safety vetting is carried out during learner induction. This involves a discussion between the coach, 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 health and safety, and other essential legislative requirements such as a need for some leamers to have a DBS/PVC check . H&S is also covered during enrolment directly with the learner and is part of the Life Skills mandatory learning plan modules
- 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 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. There is an essential information guide containing the same information is made available during the enrolment process
- Learners are issued with a learner welfare flyer detailing both internal and external support services, accessible through Aptem ‘essential information’. 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.
- 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 Thrive which all learners are sent via email and available within their APTEM account. The content aligns with the employee monthly newsletter and aids learner awareness and support discussions
Additional social needs identification and process is support that is provided by Lifetime Training for all learners who are facing Social, Emotional, Behavioural and Mental Health difficulties. This process supports Increasing the ability to learn & making learning more accessible whilst dealing with personal issues, helps with motivation to reach their potential, provides extra support avenue giving them quality time as and when needed
Learners can self-declare at sign up stage that they require support or coach can refer them
Additional welfare support for 16-19 learners - receive a 3 month support package including and workbook and workshop that incudes awareness of; employment expectation, developing resilience, British values and radicalisation, online safety and awareness of sexual harassment . Learners that don’t attend have the workshop presentation added to their APTEM, and both the coach and themselves are informed its available to view. 19 year old have access to the workshop aspect
Care leaver support and bursary access - learners highlight if they are residing in care or a recent care leaver. This is alerted to the ASN team, who work with the learner to check bursary eligibility, provide support and facilitate access to and guidance for use of the bursary funding
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 educate learners around online dangers through a variety of avenues including our Life Skills learning module. Periodically our Safeguarding newsletters cover online safety topics. These are used by trainers as educational content for learners. To ensure we monitor and act upon accessing of inappropriate content and comments, filtering systems are in place on employee and distributed learner devices to restrict access to illegal and unsuitable content and our social media platforms. We adhere to the Children’s Education setting provided by the ‘Zoom Platform’https://explore.zoom.us/en/schools-privacy-statement/
Forcepoint filtering system is subject to monthly sample by DSL to identify and act upon any illegal/ unsuitable content access attempts.
Child on Child abuse/ Sexual Harassment and Violence between children.
As a result of Ofsted’s review into sexual abuse in schools in 2021, a range of interventions have been applied to educate and support learner around identification and accessing support around sexual harassment and abuse. Coaches are provided with training on indicators and support avenues as part of the safeguarding support process. Annual CPD is also provided to refresh knowledge This training includes identification of and action required for incidents of this nature alongside what learner might view as accepted norms, and what constitutes sexual harassment and abuse both face-to-face and online. This includes sexual harassment and violence in the workplace.
All 16-19 learners have access to a workshop that provides a taught session that covers sexual harassment identification, inappropriate behaviours, expected behaviours in the workplace and support available. Those that can’t attend have the resources added to their APTEM account to explore at their own pace. This accompanies the 3 month additional social needs support all 16-18 learners have allocated to them
The increased importance of supporting poor mental health has been seen through the increased prevalence of mental health concerns raised by learners both as a 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 which provides counselling if required and are provided with bespoke support where required. They are encouraged to seek support from their employers, where appropriate, who in the main, have robust support networks in place. All learners will also compete the Life Skills learning plan which has a module focussed on managing mental health and wellbeing. The Thrive newsletters that learners also receive also have section on wellbeing and mental health every month
If an accident occurs in the workplace, the overall responsibility to investigate lies with the employer, but Lifetime will still investigate the incident to ensure the workplace are supporting them appropriately . If an accident occurs out of the workplace whilst under supervision of Lifetime, Lifetime have overall responsibility to investigate The coach is to complete the accident reporting form, located in Learner Welfare/ Huddle and send to the H&S and Welfare Manager
Learner risk assessment
To ensure Lifetime supports the health and safety of all learners, in certain situations Lifetime may risk assess support requirements for learners, e.g. if a medical condition has been declared, has been subject to sexual harassment/violence or is on bail.
Where Lifetime acts a lead provider, providing funding to other companies, Lifetime will provide appropriate training /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, we 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.
- Leadership and Management
A Safeguarding board report is presented monthly as part of the board pack. The monthly Learner Experience Committee gives opportunity to update the Senior team providing a greater focus on safeguarding and safety of learners, and discuss trends, new initiatives and directives in more detail., and agree company actions
The effectiveness and impact of all welfare support is monitored via a survey to those learners experiencing a safeguarding issue alongside a more generalised survey to all learners analysing support avenues and impact of educational material. Monthlylearner welfare audit reviews all processes and material.
The safeguarding officer team are also subject to quality assurance checks carried out by the DSL.
13. Associated Policies
- Equality and Diversity Policy
- Grievance Policy
- Disciplinary Policy
- Social Networking and Media Policy
- Prevent Policy
- Resourcing Policy
- Bribery Policy
- Code of Conduct
- Whistleblowing Policy
- Health and Safety
Read full policy here