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Sutton Coldfield Training (SCT) Ltd Safeguarding Policy (S2)


Designated Safeguarding Officer


1.       Pauline Hill

2.       Helen Devey


Policies are consistent with the following guidance:


       Working together to safeguard individuals 2013

       Working together to Safeguard Children 2018

       What to do if you think an individual is being abused 2006

       Birmingham Safeguarding Children’s Partnership (BSCP) procedures.

       Childcare Act 2006, Section Five which states:

“We have a duty to implement the Early Years Foundation Stage, meeting the learning and development requirements, and must comply with the welfare requirements”.

·         Keeping Children Safe in Education – Statutory Guidance for schools and colleges – September 2021




Sutton Coldfield Training recognises its statutory and moral duty towards safeguarding the welfare of children, young people, and adults at risk from any form of abuse whilst receiving education and training, including apprentices. We expect all staff, volunteers, and partners to endorse and practice this duty at all times. As a result, we have a zero-tolerance approach to abuse and other harmful behaviour and fully commit to protecting all learners, including apprentices, from abuse at all times.


At Sutton Coldfield Training, safeguarding and promoting the welfare of children, young people and adults at risk is everyone’s responsibility, everyone who comes into contact with children, their families and carers has a role to play in safeguarding. Moreover, we are committed to safeguarding and promoting the welfare of all learners, staff, volunteers, visitors, contractors and partners.


Any reference in the policy to a child, young person or learner applies to all those aged under 18. Our legal duty includes the education and training of adults at risk. Any reference in the policy to an adult at risk applies to anyone aged over 18 yrs. who may for a variety of reasons be in need of community services and/or unable to protect him or herself from significant harm or exploitation.


Children and vulnerable adults have the right to protection, regardless of age, gender, race, culture or disability. They have the right to be safe in our centre.


The centre recognises that every individual is unique. The health, safety and well-being of individuals in our care are of paramount importance. We strive to create an environment which is welcoming and safe. We recognise that individuals learn best when they are healthy, safe and secure, when their individual needs are met, and when they have positive relationships.

This policy applies to all staff (including tutors), learners (including apprentices), stakeholders (including employers) and visitors (including contractors).


Leaders and Managers are responsible for gaining engagement of this policy and safeguarding from staff, learners, stakeholders, and visitors All staff are responsible for promoting a safeguarding culture throughout the organisation, including to learners, stakeholders, and visitors. All marketing and promotion materials and learning resources will include reference to safeguarding principles where appropriate.


This policy will be reviewed annually.


Child & vulnerable adult Protection:


Pauline Hill & Helen Devey are the Safeguarding Officers who are responsible for Safeguarding children & vulnerable adults at Sutton Coldfield Training;


The role of the safeguarding officer


·         The Safeguarding Officer is responsible for liaison with local statutory services/agencies, and with the Local Safeguarding board.

·         The Safeguarding Officer will provide support, advice and guidance to any other staff on an ongoing basis, and on any specific safeguarding issue as required.

·         The Safeguarding Officer will attend relevant protection training courses delivered by the local authority to support their role which enables them to identify, understand and respond appropriately to signs of possible abuse and neglect.

·         Promoting safeguarding throughout the organisation including gaining commitment from all staff, learners, stakeholders and visitors

·         Submission of monthly safeguarding reports to funding partners.

·         Making learners aware of specialist support and guidance, including ensuring resources are available throughout delivery premises, and supporting learners to access external support and guidance

·         Monitor IT usage to ensure compliance with our E-Safety Policy and Procedure and IT Acceptable Use Policy


Definitions of Abuse and neglect - **  Policy updated 05.04.2017 to reflect and cover the Widened areas of Abuse – **** reviewed and updated to reflect and cover topics identified in Keeping Children Safe in Education – Statutory Guidance September 2019 - ***** - reviewed and updated to cover topics in Keeping Children Safe in Education – Statutory Guidance September 2021.


       Child Sexual Exploitation (CSA)

       Bullying including cyberbullying

       Domestic Violence


       Fabricated or induced illness

       Faith Abuse

       Female Genital Mutilation (FGM)

       Gangs and Youth Violence

       Gender-based violence/violence against  women and girls (VAWG)

       Mental Health

       Private Fostering

       Preventing Radicalisation


       Teenage relationship abuse (including Emotional, Physical ,Sexual and Financial Abuse)

       Forced Marriage

       Trafficking **

       Mental Health**

       Breast Ironing**

       Honour Based Violence**

       Criminal Exploitation – County Lines****

       Homelessness ****

       Peer on Peer Abuse ****

       Up skirting ****

       Serious violence *****

       Initiation/hazing type violence and rituals *****




A form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children


Physical Abuse


Physical abuse may involve hitting, shaking, throwing poisoning or burning or scalding, drowning, suffocating or otherwise causing physical harm.

Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces an illness.


Emotional Abuse


Emotional abuse is the persistent emotional maltreatment such as to cause severe and persistent adverse effects on emotional development.

It may involve conveying they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed. These may include interactions that are beyond the developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the participation in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing the individual frequently to feel frightened or in danger, or the exploitation or corruption of individuals Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.


Sexual Abuse


Sexual abuse involves forcing or enticing an individual to take part in sexual activities, not necessarily involving a high level of violence, whether or not the individual is aware of what is happening. 

The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as looking at, or in the production of, sexual images, watching sexual activities, encouraging behaviour in sexually inappropriate ways, or grooming in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children/vulnerable adults. The sexual abuse of children by other children is a specific safeguarding issue (also known as peer on peer abuse) in education and all staff should be aware of it and of their school or college’s policy and procedures for dealing with it,




Neglect is the persistent failure to meet an individual’s basic physical and/ or psychological needs, likely to result in the serious impairment of the individual’s health or development.

Neglect may occur during pregnancy, for example, as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.


Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)


Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in sexual or criminal activity, in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator and/or through violence or the threat of violence. CSE and CCE can affect children, both male and female and can include children who have been moved (commonly referred to as trafficking) for the purpose of exploitation.


Child Criminal Exploitation (CCE).


Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting or pickpocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Children can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence, or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the activity appears to be something they have agreed or consented to.


It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however professionals should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.


Child Sexual Exploitation (CSE)

Sexual abuse may involve physical contact, including assault by penetration (for example, rape or oral sex) or nonpenetrative acts such as masturbation, kissing, rubbing, and touching outside clothing. It may include non-contact activities, such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse including via the internet. CSE can occur over time or be a one-off occurrence, and may happen without the child’s immediate knowledge e.g. through others sharing videos or images of them on social media.

CSE can affect any child, who has been coerced into engaging in sexual activities. This includes 16 and 17 year olds who can legally consent to have sex. Some children may not realise they are being exploited e.g. they believe they are in a genuine romantic relationship.


Supporting Children and vulnerable adults


We encourage children and vulnerable adults to keep safe, recognise different situations and how to behave in response to them.

All staff in areas conducts formal risk assessments and constantly reappraise both the environments and activities to which the individuals are being exposed. Staff must make necessary adjustments to ensure their safety at all times.


Staff Training


All staff receives training to understand the safeguarding policy and procedures. Staff receives updates regarding safeguarding issues and attend training provided by the local authority to enable staff to identify signs of possible abuse and neglect at the earliest opportunity and respond in a timely and appropriate way. These may include:

• Significant changes in behaviour;

• Deterioration in general well-being;

• Unexplained bruising, marks or signs of possible abuse or neglect;

• Comments which give cause for concern;

• Any reasons to suspect neglect or abuse outside the usual setting e.g. home.

• Inappropriate behaviour displayed by other staff members of staff, e.g. inappropriate sexual comments; excessive one-to-one attention beyond the requirements of their usual role and responsibilities; or inappropriate sharing of images (see Mobile Phone and Camera Policy).


To ensure Safeguarding is embedded all staff (including freelance assessors) are required to complete training on Prevent / Channel General Awareness – certificates of which are retained on file.




All staff including students on placements and volunteers working within the setting has the opportunity/ duty to listen carefully to what individuals say and observe any changes in their appearance or behaviour which may result from abuse or neglect and to act quickly and responsibly in any instance that comes to their attention, including reporting suspicions around abuse or neglect.


Staffs are aware of their responsibilities; supervisors and management are clear about maintaining and supervising staff performance. Supervisors are responsible and accountable for their areas and decisions that affect other areas.

·         Staff must alert Pauline Hill or Helen Kelcey to any issues for concern in an individual’s life at home or elsewhere.

·         Any action taken must be in line with the guidance and procedures of Birmingham’s Safeguarding Board.

·         All staff is aware that it is not their responsibility to investigate whether or not an individual has been abused; this responsibility lies with Social Care and the Police. All protection and safeguarding concerns must be passed directly to Social Care and the Integrated Access Teams.

·         Staff must communicate effectively when dealing with protection and safeguarding concerns/issues. All information must be treated as sensitive and confidential.

·         There may be times when inappropriate behaviour needs to be challenged and sometimes this can lead to members of staff having to intervene. However this will only happen if the individual is at harm or hurting others.

·         All Visitors must sign in/out of the visitor’s book. Any persons visiting the in a professional capacity is required to provide proof of identity.

·         If any member of staff suspects that an individual in the setting may be a victim of abuse, they must observe, record and report but remain impartial. These concerns must be passed to the Designated Safeguarding Officer, to be kept on file and passed to the relevant services if necessarily.

·         If the Designated Safeguarding Officer does not feel that there is any cause for concern but a staff member or volunteer disagrees with her decision, the concerns must then be passed on directly to Social Care Services.

·         Where there are protection and safeguarding concerns, the Designated Safeguarding Officer  will contact the Integrated Advice Team within Birmingham City Council  on 0121 303 1888.  ( office hours) or  0121 675 4806 ( out of hours)

The email address for the IAT is

·         If an individual makes a disclosure of abuse to a member of staff, they will write a report and then pass it onto the named person. The centre may make a referral to the relevant services.

·         To ensure any observations, reports etc… are documented at the earliest availability and within 24 hours. Advice will be taken from external agencies regarding time scales for any information they wish to have.



Domestic Abuse


Should we become concerned that a parent/career or person in a position of trust at the centre is subject to domestic abuse, we will pass our concerns onto the Social Care and Health Services for them to investigate. This action is to protect any individual who may be subject to domestic abuse in any environment.

If we suspect that a person in a position of trust is a victim of domestic abuse we will in the first instance sign post them to an outside agency for support. If any children are present in the home we will past our concerns onto Health and Social Care Services. This person may become subject of a Position of Trust meeting.



When a child has a serious accident or dies


In all cases parents/carers will be notified in the first instance

In the event of all child deaths at a setting or any other place that you become aware of, you must report to the Birmingham Safeguarding Children Partnership (BSCP) and Ofsted.

The following must be followed:


Report to the BSCP, the designated safeguarding person or staff member must complete the appropriate notification of child death form and send it to:


• Cheryl Harnett - Child death overview Co- Coordinator

Birmingham safeguarding Children Partnership

TEL: 0121 464 2612 begin_of_the_skype_highlighting              0121 464 2612      end_of_the_skype_highlighting



Children’s Advice and Support Service (CASS) – 0121 303 1888 – Out of hours number 0121 675 4806


Staff must report to Ofsted any serious accident, injury or death that occurs to a child while in the care of the centre. This includes times where you are off the premises such as on an outing. Ofsted must be informed within 14 days; otherwise the centre will commit an offence. More information can be found in Ofsted publication:

Serious accidents, injuries and deaths that registered providers must notify to Ofsted and local child protection agencies. Ofsted can be contacted on: 0300 123 1231 begin_of_the_skype_highlighting      end_of_the_skype_highlighting.




All online safeguarding concerns will be dealt with in line with this policy, particularly in terms of referral and recording procedures


All members of staff will be advised of the company’s IT Acceptable User Policy (AUP) policy and will agree to adhere to it and understand that IT usage by staff and learners is monitored


The prevalence of issues arising through children’s access to the online world is significant and all staff should be aware of associated risks and signs/symptoms. These are categorised within KCSIE 2020 as:


·         Content

·         Contact

·         Conduct


This includes non-age-appropriate content, self-harm and suicide, sexting, cyberbullying, grooming, radicalisation and gaming (now identified by the World Health Organisation as a disorder)


Staff may become concerned about children, young people and adults at risk if they are:

·         Accessing illegal websites or inappropriate "lifestyle" or for their age and ability.

·         Receiving unwanted or upsetting text or e-mail messages or images.

·         Being “groomed” by a responsible adult with a view to meeting the child, young person or adult at risk for their own illegal purposes including sex, drugs, radicalisation, or criminal activity.

·         Viewing or receiving socially unacceptable material such as inciting hatred or violence.

·         Sending or receiving bullying messages or posting malicious details about others.

·         Scamming for financial gain.

·         Ignoring copyright law by downloading music videos.

·         Becoming secretive about where they are going or who they are meeting.

·         Secretive about what they are accessing online.          

Using a phone, iPad or tablet in a closed area, away from other people.

·         Accessing the web or using a handheld device for long periods and at all hours.

·         Constantly clearing their browsing history.

·         Receiving unexpected money or gifts from people they meet online.

·         Sending sexually inappropriate images of themselves to others (i.e. “sexting”) which, for under 18 year-olds, is an offence under the Sexual Offences Act 2003.


Staff may become concerned about a member of staff who:

Befriends or communicates with learners who they work with; especially by their personal phone, online, by messaging and social media etc.

·         Is secretive about what they are doing and who they are meeting.

·         Takes images of company activities with their own phone, iPad, or tablet without permission of their line manager.

·         Does not seek parental permission for taking images of children and young people under 18 years of age.

·         Constantly clearing their browser history.

·         Is viewing pornography at work.

·         Is viewing child sexual abuse images at any time.

·         Is promoting discrimination, illegal acts, or racial or religious hatred of any kind.

·         Sharing confidential or sensitive information.

·         Circulating or messaging any information which may be offensive


Suitable Staff


The centre follows regulations set by the government as outlined in the Protection of Freedoms Act 2012. The centre adheres to DBS (Disclosure and Barring Service) Vetting and barring and referral procedures, and will not knowingly engage a barred person in regulated activity.

Pauline Hill and Helen Kelcey are responsible for ensuring that people looking after children and vulnerable adults are suitable to fulfil the requirements of the role.


Any adults who are likely to have regular contact with children or vulnerable adults are required to complete an enhanced disclosure (DBS), through a regulated government agency for any person aged 16 and over whom:

• Works directly with children

• Works on the premises of which the childcare is provided


Note: Enhanced DBS checks for work within regulated activity will tell us (where requested) if the person is on one of the DBS’s barred lists.


 All staff are expected to disclose any convictions, cautions, court orders, reprimands and warnings which may affect their suitability to work with children (whether received before or during their employment at the setting)


Staffs are required to supply two references; one of which must be able to comment on their suitability of working with children and vulnerable adults.


 Anyone who has not had their suitability checked or awaiting their DBS clearance and references will not be allowed to have unsupervised contact with vulnerable individuals. 

Prior to a position being confirmed applicants must produce original qualification certificates (copies will be taken and confirmed). Identity checks will be completed as part of the DBS process.

 A DBS register is kept on the premises at all times in the office this details the following:

• Criminal records disclosure/reference number

• Date the disclosure was issued

• Who obtained it?


Procedures if a concern/allegation is raised concerning a person in a position of trust


How staff can protect themselves from allegations being made


Staff members need to avoid putting themselves in situations that may lead to allegations being made against them and observe closely the Code of Staff Conduct and adhere to the policies and procedures of the centre.  By following the principles of Good Practice the centre will not only protect the children but also the adults.


Allegations made against a person in a position of Trust. 

This procedure will be adhered to if the concern is related to their work in the centre or anywhere else.


• If a concern rises against any person in a position of trust that raises a query as to their suitability to work with vulnerable individuals (this may include a cook, student, staff or volunteer). We will immediately take the person to one side and inform them an allegation has been made against them.


• We will not at this point tell the person the nature of the allegations.


• We will remove the person from any direct contact with vulnerable individual and it may be necessary to suspend the person on full pay until the investigation is completed.

This action is intended to safeguard the welfare of the vulnerable individual and does not assume that the person is guilty.


• We will appoint a staff member in the centre to offer support to the member of staff.


• If the parent/carer/guardian of the vulnerable individual is not already aware of the concern we will immediately inform them, and where possible will ensure confidentiality of all parties concerned.


• We will then contact the Protection Officer Duty Line on 0121 464 2612 (Birmingham Safeguarding Children’s Board) or 0121 675 1669 and request a LADO referral form.


• Ofsted will be informed of the concerns/allegation if it happened on the premises or elsewhere. We will confirm our actions to date; this will be confirmed in writing and at the latest with 14 days of the allegation being made.


• We will fully co-operate at all times with any External investigation, which may include a Multi-agency “Position of Trust Co-ordination Meeting”. We will take on board any advice given in relation to the allegation.


• If the allegation is found to be true, we will take the person through a disciplinary process and dismiss them. 

We will also refer their name to DBS (the appropriate body) in accordance to legislation and policy, for inclusion on the list of persons barred from working with children (List 99)


Contact Details for Disclosure and Barring Service


DBS Helpline: 03000 200190


• It may be proved to the centre’s satisfaction that the person has abused one or more vulnerable individuals. The above will apply.

• It may be proved to the centre’s satisfaction that the person is not guilty of abuse be inconclusive, leaving suspicion but no proof about the persons behaviour.

• If not proven we will follow the advice given by the Principle Officer for Social Care and the Protection Officer and conduct an internal investigation looking at the practice of the setting and individual/s involved.

• Ofsted will be informed of the outcome and the action/processes taken.


Poor Conduct resulting in dismissal

Ofsted deem staff members,  under the welfare requirements, as ‘suitable persons’ and therefore require settings to ensure effective procedures are in place and implemented to ensure appropriate action is taken should a member of staff be unsuitable

Any staff member or volunteer dismissed from their role at the centre for ‘poor conduct’; and considered by management not to be working to the required standard and organisational requirements will be referred to the Disclosure and Barring Service (DBS) and may have their name listed for persons barred from working with children and vulnerable adults. The DBS will make the overall decision on whether further action needs to be taken following the referral made by centre management.


It is the responsibility of management to ensure they have evidenced how they have considered whether to refer a staff dismissal to the DBS, and reasons for not doing so must be recorded, detailing an accurate account of all investigations, discussions and action taken.

This procedure must also be followed when referring anyone in a position of trust to the DBS.

Any persons at the setting under the age of 19 years are afforded the protection of this policy.