Safeguarding Policy for Under 18s

Definitions and Scope

1. In accordance with the Children Act 1989 and 2004, a child is any person under the age of 18.
2. The safety and wellbeing of all children who participate in events or activities at the University is essential, and all University staff and students working for us on these activities are responsible for safeguarding.
3. This Policy applies to events and activities that may take place in person, on the University campus or elsewhere, or online. Activities delivered in a school are covered by the school’s own safeguarding procedures, and University staff comply with these as required.
4. Children may be present at the University in the following circumstances:
   1. Participating in a summer school or other activity organised by the University.
   2. Attending open days, offer holder days or campus tours either as potential applicants or as part of a family group.
   3. Participating in or otherwise present because of an event or activity organised by a third-party organisation.
   4. Attending interviews for admission.
   5. In some, but not all, of these situations the children may be accompanied by an adult, such as a parent, guardian or teacher who will be responsible for their safety.
5. This Policy must be read in conjunction with the following University policies:
   1. Health and Safety Policy
   2. Bullying, Harassment and Sexual Misconduct Policy
   3. Code of Behaviour for Summer School
6. The Department for Education has defined Safeguarding as:
   1. Protecting children from maltreatment
   2. Preventing impairment of children’s mental and physical health, or development.
   3. Ensuring that children grow up in circumstances consistent with the provision of safe and effective care.
   4. Taking action to enable all children to have the best outcomes.
7. Parent/guardian refers to the parent/guardian of the participant. The parent/guardian must be an adult over the age of 18 who has responsibility for the participant’s wellbeing and safety. In some cases, this may not necessarily be a legal guardian, but a responsible family member who can be contacted in reference to the participant in an emergency.

General

Policy Statement

8. Northeastern University London (the University) is committed to protecting the safety and wellbeing of all children taking part in events and activities at the University. All University staff and students working on activities are responsible for safeguarding.
9. This Policy demonstrates the University’s values, responsibility and statutory duties within UK legislation.
10. The University believes all children have the right to be treated equally and with respect, regardless of their background or personal circumstances.

University Responsibilities

11. The University recognises and acknowledges its responsibility to protect the welfare of, and to actively manage potential harm to, children taking part in events and activities at the University.
12. The University recognises its responsibility to take appropriate action when a child discloses that they are experiencing abuse or neglect, or if staff have a concern about the welfare of a child, and to ensure staff understand what might indicate this and what action to take.
13. The University has appointed a Designated Safeguarding Lead who is responsible for the implementation of this Policy and who will be the person to whom any safeguarding concerns will be reported and who will then discuss and agree the appropriate action to be taken. The Designated Safeguarding Lead will have a Deputy who will act in their place when they are on annual leave or otherwise unavailable or if a complaint or concern is raised about them.
14. The University’s Designated Safeguarding Lead is:
    1. Head of Student Support and Development
15. The University’s Deputy Designated Safeguarding Lead is:
    1. Director of Business and Partnership Development & Apprenticeships
16. The University will maintain policies and procedures geared towards abuse prevention, including:
    1. Vetting of staff and volunteers using enhanced DBS checks for staff working on events and activities involving children.
    2. Staff disciplinary procedure.
    3. Clear rules for staff and students to follow in the instance of a child entering the University.
    4. Staff induction and training.
    5. Confidential reporting procedure.
17. The University will arrange and ensure completion of necessary safeguarding training for all staff working on events and activities involving children.
18. The University will ensure that full and accurate records are kept of all safeguarding concerns, in line with data protection policies and procedures.

Individual Staff and Student Ambassador Responsibilities

19. University staff and student ambassadors understand that safeguarding is their responsibility, and that they are in a position of trust in relation to children, therefore they should:
    1. Treat all children, regardless of any protected characteristics under the Equality Act 2010, with respect and dignity and provide with the same equality of opportunity.
    2. Read and familiarise themselves with this Policy.
    3. Attend all required safeguarding training and ensure this is kept up to date.
    4. Ensure they are aware of the reporting procedure and follow the procedures set out at all times. This includes reporting any safeguarding concerns to the University immediately, making a full and accurate record of the incident/concern as soon as possible.
    5. Maintain a professional relationship with children and their families. Under the Sexual Offences (Amendment) Act 2000, it is a criminal offence for any person in a position of trust to engage in sexual activity with a child.
20. They should not:
    1. Discuss their personal lives with children.
    2. Meet or arrange to meet children or their families privately away from University events or activities.
    3. Exchange personal contact details with children or their families, or connect with them on social media. Contact should be restricted to work communication channels to ensure a professional relationship is maintained.
    4. Be alone with a child. Another adult or children should be present at all times. If a one-to-one meeting is necessary, it should take place in a room with an open door or with visual access.
    5. Display discriminatory, offensive language or behaviours.
    6. Engage in physical contact with children (unless absolutely necessary, for example giving first aid).
    7. Take gifts or money from children or their families.
    8. Give gifts or money to children or their families.
    9. Promise that a conversation will be kept confidential, since it is impossible to guarantee such confidentiality.

Ensuring Safe Practice at Events and Activities

Event Lead Responsibilities

21. All events and activities involving children should have an Event Lead who will take responsibility for initial decision-making during the event. A secondary member of staff (back-up) should be aware of all the arrangements in case the Event Lead is unavailable. This Event Lead should be a Manager or a member of the team with appropriate experience that they have delegated this too. The Event Lead is responsible for:
    1. Producing an appropriate and adequate written risk assessment.
    2. Ensuring that all staff and student ambassadors who are working on an event or activity are fully briefed and understand their role/responsibilities, including what to do in the event of an emergency.
    3. Gaining appropriate consents from parents/guardians in advance.
    4. Ensuring that the participants involved are adequately supervised for the duration of the event or activity. The University follows NSPCC guidance on the minimum ratio of appropriate adults to children:
       1. Age 9 – 12 years: one adult to eight children.
       2. Age 13 – 18 years: one adult to ten children.
       3. If taking children to an activity off campus the ratio should be: one adult to five children, regardless of age.
    5. Setting expectations of the standards of behaviour required from participants in advance, which may include asking participants and/or their parents/guardians to acknowledge they have read and agree to the participant code of behaviour, with relevant additions made for each event/activity as necessary.
    6. Build in time at the end of events to debrief with staff and provide staff the opportunity to raise any concerns.

Working with External Organisations

22. The University partners with external organisations to deliver some events or activities, at the University or at other locations. For partnership working the University requests a copy of the organisation’s child protection policy and provides them with the University’s. The policy is reviewed by a manager who has oversight of the activity or partnership, to ensure they are compatible. If any issues are identified, these are discussed, and a joint approach agreed in writing in advance.

Online Events

23. Any events or activities being run online must be delivered on appropriate platforms. All online platforms must:
    1. Be appropriate for the participants’ age group.
    2. Enable staff to restrict the audience to just the intended participants and staff members. Including the ability to remove somebody from the session if necessary.
    3. Ensure that participant and staff personal information (e.g., contact information) is not visible to anybody else presenting or viewing the stream.
    4. Enable staff to control whether participants can have their videos/microphones on.
    5. Enable staff to prevent participants from sending private messages or chatting one-two-one with other participants.
24. Event Leads must ensure they have enough staff to support all online events. Participants must be supervised by at least two staff in every live online activity and at least one of those should hold an Enhanced DBS check.
25. Where possible, staff should not have one-to-one video calls with children. If this is unavoidable, the meeting should be recorded and saved in a secure location. Participants should be notified of this Policy at least 24 hours in advance.

What Constitutes Abuse?

26. In drawing up guidance locally, it needs to be recognised that the term ‘abuse’ can be subject to wide interpretation.
27. Abuse may consist of a single act or repeated acts and University staff should recognise that abuse is rarely a standalone event that can be covered by one definition or label. There are four main categories of abuse: neglect, physical abuse, emotional abuse and sexual abuse.
28. It is not always possible to recognise if someone has been abused – signs may not be obvious. University staff or student ambassadors are not responsible for investigating or deciding if abuse is occurring, but it is always our responsibility to report concerns. Possible signs of abuse include:
    1. Direct disclosures of verbal, emotional, physical, sexual, neglect, or bullying, by anyone. Abuse can be current or historical. Children can be abused by other children, as well as adults.
    2. Third party disclosures (abuse happening to someone else).
    3. Saying they want to tell you something but only if you keep it a secret.
    4. Hints about abuse in classwork, homework or conversations.
    5. Self-harm marks, bruises, burns or other injuries.
    6. Signs of disordered eating, anxiety or serious depression.
    7. Sudden change in behaviour, for example very withdrawn when previously confident and happy.
    8. Serious aggression or inappropriate behaviour towards other children or University staff.
    9. Worrying language such as excessive swearing or sexualised comments.
    10. Seeming anxious about going home, or afraid of us calling their parents.
    11. Talking about being pregnant, or having an older girl or boyfriend.

Procedure If a Child Discloses Abuse by Someone Else

29. If a child makes a disclosure that they have suffered harm through abuse or neglect, the initial response should always be limited to listening carefully to what they say to fully understand their situation. Reassurance should be offered, and an explanation given as to what action will be taken.
30. It is vitally important that no promise is given to keep the information confidential.
31. The steps which should be followed are:
    1. Stay calm.
    2. Listen carefully to what the child is saying.
    3. Explain that it is likely that a limited number of other people will need to be informed – do not promise to keep information confidential.
    4. Allow the child to speak at their own pace. Ask questions that will give clarification but do not press them for answers or ask leading questions.
    5. Reassure the child that they have done the right thing by talking to someone.
    6. Make sure the child understands what will happen next, that the person in the University who is responsible for their protection will be notified and that the Local Authority Children’s Services may need to be contacted.
    7. Record the disclosure using the child’s/student’s words where possible and noting time and date.
    8. Notify the Event Lead as soon as possible so they can report this to the Designated Safeguarding Lead.
    9. Do not discuss the disclosure with other staff; discussion should be strictly on a ‘need to know’ basis. Find out when the child/ is next due to see the individual who is the subject of the complaint. (A judgement will need to be made as to the appropriate timing of any follow-up actions to ensure that the child remains safe.)
32. Concerns about the welfare of a child, including the possibility of abuse or neglect, may also be raised by behaviour or other indicators noticed by a member of staff, but not disclosed by the child. In these instances, it is equally important to act, and these concerns should be raised and discussed with the Event Lead who can report to the Designated Safeguarding Lead.

Procedures for Dealing With Safeguarding Allegations or Concerns Regarding a Member of Staff or Student Ambassador

33. When dealing with Safeguarding Allegations or Concerns involving a member of staff or student ambassador, managers and Board Members must remember that the welfare of children at the University is paramount, but that the University also has a responsibility to ensure that University staff and student ambassadors are treated fairly and with respect.
34. A safeguarding allegation is one where information comes to light from any source, which suggests that an adult working for or on behalf of the University has or may have:
    1. Behaved in a way that has harmed a child or may have harmed a child.
    2. Committed a criminal offence against or related to a child.
    3. Behaved in such a way that calls into question their suitability to work with children.
35. Concerns should be reported to the Event Lead immediately so they can be raised with the Designated Safeguarding Lead.
36. If the concern relates to the Event Lead, it should be reported to the Designated Safeguarding Lead directly.

Confidentiality

37. Whatever the nature of the disclosure, suspicion, or complaint, it must be kept confidential, and information should only be shared on a need-to-know basis, with the Event Lead and the Designated Safeguarding Lead.

Dealing with concerns relating to the ‘Prevent Duty’

38. According to the Counter-Terrorism and Security Act 2015, universities are legally obliged, under the ‘Prevent Duty’, to have due regard to the need to prevent people from being drawn into terrorism, known as ‘radicalisation’. The University has no direct legal duty to take action under the Prevent Duty in respect of suspected radicalisation of children involved in our events or activities, as that will fall to another agency (e.g., their school or college). However, we must report any concerns we have to the relevant authority, as set out below, so that they can take action.
39. There is no single way of identifying a person who may be vulnerable to extremist ideology and radicalisation can be difficult to spot. Signs that may indicate radicalisation include:
    1. Isolation from family and friends.
    2. Talking as if from a scripted speech.
    3. Unwillingness or inability to discuss their views.
    4. Expressing views that justify acts of violence or terrorism.
    5. A sudden and disrespectful attitude towards others.
    6. Increased levels of anger or intolerance.
    7. Increased secretiveness, especially around internet use.
    8. Travelling for long periods of time but is vague about where they are going.
    9. Buying or storing large amounts of chemicals for no obvious reason.
40. If University staff or student ambassadors have any concerns related to a child and radicalisation, they should:
    1. Make a full and accurate record of their concerns, noting the date and time.
    2. Notify the Event Lead as soon as possible, so they can report this to the Designated Safeguarding Lead.

Monitoring and Reviewing

41. This Policy will be monitored and reviewed by the Designated Safeguarding Lead.

Version History

Annex 1: Child Protection Procedure for Events and Activities at the University

Events or Activities That Have Individual Participants (e.g., children attend without their parent/guardian or school)

1. For participants up to, and including, Year 11 or for those in Year 12 and 13 that last for more than one day, the University must receive:
   1. A signed Parent/Legal Guardian Agreement to Participate Form, including details of two emergency contacts and permission for their child to participate in the event or activities.
   2. A signed offer letter by the child, agreeing to the terms and conditions of the event or activity.
2. The University must ensure that parents/guardians and participants have received the following information:
   1. Details on registration, including location and start and finish times.
   2. Activity timetable including catering information and details of any off-campus activities.
   3. Contact details for the activity, including an email address and emergency phone number that will be available during the event.
3. For all events and activities accessibility, faith or dietary requirements must be obtained from the participant or their parent/guardian in advance.
4. The University is not responsible for children when they are travelling to and from the University. We are responsible for them from the moment they register at the University until the end of the activity, whether on the University campus or at external sites such as museums. If a participant does not arrive the following action will be taken:
   1. A designated staff member will call the participant to find out if they are attending. If they tell us they are no longer attending, this will be confirmed with the parent/guardian and the reason for absence will be recorded. If there is no response the staff member will contact their parent/guardian.
   2. If a child tells us by phone that they are running late, but do not arrive, the staff member should follow up and alert the parent/guardian if necessary.
   3. If a child doesn’t arrive and the staff member cannot get through to anyone by phone, they should send a follow up email to the child’s parent/guardian to notify them they have not arrived.
   4. A staff member will stay on the registration desk for any late arrivals.
5. If a participant in Year 11 or below needs to leave before the end of a scheduled activity, their parent/guardian should email or call the event staff in advance to explain that they give permission for their child to leave early. If this is not possible, the child should speak to the Event Lead on the day. The staff member will call their parent/guardian and will obtain verbal consent for them to leave the University at a set time.
6. At the end of a scheduled activity, children in Year 10 and above can leave when given permission to do so by University staff. For children in Year 9 or below, their parent/guardian must have given consent for them to leave unaccompanied. If participants need help in finding their way off campus and to the nearest bus stop, for example, staff should direct them.

Supervision During Events or Activities

7. The Event Lead is responsible for briefing and debriefing all staff working the event or activity.
8. Expectations should be set with participants in the first session of an event or activity, and reiterated on subsequent occasions, if it is ongoing. Specific housekeeping arrangements should be announced, and participants should be reminded of the key points of the Code of Behaviour, to include:
   1. Please follow any instructions from University staff or Student Ambassadors and stay with the group at all times.
   2. Engage with the activities. Listen, and contribute your thoughts and questions at the appropriate times.
   3. Show respect and kindness to classmates, staff and students.  
   4. Do not use offensive or discriminatory language or discuss inappropriate subjects not related to the session topic.
   5. Do not ask for the contact details of staff or try to contact University staff and students through their personal emails or social media accounts. University staff and students must not contact you through their personal email or social media accounts.
   6. We hope you enjoy the event but, if you do have any concerns, please do tell an adult you trust and contact University staff.
   7. Anyone who does not abide by our Code of Behaviour may be asked to leave the activity and their parent/guardian will be contacted. 
9. Staff and student ambassadors must always have a register with a list of children in their group and know if they are present or absent that day. Group leaders must run head counts of their group at regular intervals, and before moving between locations.
   1. If they cannot find a child, they must alert the Event Lead immediately, check if the child is with another group, then retrace their steps. If the child is not found, the Event Lead should phone the child. If they cannot be contacted and remain missing, the Event Lead should contact the Designated Safeguarding Lead.
10. If a child needs to go to the toilet, staff or a student ambassador can escort the group and wait outside to escort them back.
11. Some children may need to pray. Appropriate breaks for prayer should be planned into timetables. Children who need to pray should be gathered in one group and escorted by staff or student ambassadors to the prayer room, and then escorted back.
12. If a participant becomes ill during an activity:
    1. Staff should provide first aid, if appropriate.
    2. If they recover, they should be encouraged to rejoin the group if they feel able to do so.
    3. If they are too ill to re-join the activity, a staff member will call their parent/guardian to inform them and can either send them home (with consent from the parent/guardian) or wait for their parent/guardian to collect them.
13. Challenging behaviour or inappropriate comments should be dealt with immediately, which may involve:
    1. Issuing a general reminder to all participants, or an individual, of expectations and asking them to abide by the Code of Behaviour.
    2. Asking a participant to move seats or groups if they are causing disruption to others.
    3. Asking a participant to accompany staff away from the group so that there can be a discussion about their behaviour, what may be causing it, and possible consequences if the behaviour continues.
    4. Reconfiguring groups to minimise confrontation or disruptive behaviour.    
    5. Contacting a parent/guardian to discuss the behaviour.
    6. Where there is a serious or repeated breach of the Code of Behaviour, the situation should be discussed with the Event Lead and the Designated Safeguarding Lead.  
    7. Following discussion, a participant may be removed from the activity permanently and sent home, after staff have notified a parent/guardian and made arrangements for this to happen.

Events or Activities Supervised by Schools or Other External Organisations

14. The University does not need to collect parent/guardian consent forms for events organised as group visits with schools or other organisations.
15. Staff from the school or organisation arranging the visit are responsible for their students throughout their visit, and while travelling to and from the University.
16. For activities such as campus tours where teachers cannot be present with all groups, University staff or student ambassadors are responsible for supervision until participants re-join the main group. The person leading the activity should ensure the group stay together and ensure good health and safety practices.

Events or Activities with Family Groups

17. Where children attend with parents/guardians, the parent/guardian is responsible for their child throughout the visit.
18. If there are any sections of the day when parents/guardians and children separate for different activities, University staff/student ambassadors are responsible for supervision until participants re-join their family members. Our usual supervision levels are maintained and the person leading the activity should ensure the group stay together and ensure good health and safety practices.

Annex 2: Useful Contact Information

• Childline: 0800 1111
• NSPCC: 0808 800 5000
• Police: If you are concerned about the immediate safety of a child, call 999 and ask for the police
• Tower Hamlets Safeguarding Children Partnership: http://www.childrenandfamiliestrust.co.uk/the-lscb/

Internal

• In the event of a first aid emergency, please contact one of the first aiders advertised on signage throughout the premises or on the number below, who will provide assistance and summon an ambulance if required. A list of our first aid trained staff is posted at all kitchens and first aid rooms.
• Emergency contact information for Security and Facilities is as follows:
  • First Aid: 02045 040485
  • Security: 07594 651771
  • Facilities: 02045 040174