Safeguarding Policy

Definitions and Scope

1. In accordance with the Children Act 1989 and 2004, a child is any person under the age of 18.
2. As defined by the Protection of Freedoms Act 2012, a vulnerable adult is any person aged 18 or over who is in receipt of a ’regulated activity’: who is or may need community care services by reason of mental or other disability, age, or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.
3. In this Policy, ‘child’ means any child (defined as under-18) or vulnerable adult.
4. This Policy applies to children and vulnerable adults who are either: students enrolled at the University, those undertaking apprenticeships or Work Related Learning Programmes, work experience/shadowing placements or visitors to it.
5. A student is anyone registered with the University on a programme of study leading to an award, this includes apprentices and mobility students.
6. The University has a responsibility to safeguard and promote the welfare of any child and vulnerable adult who is identified as at risk, and who participates in organised or regulated activities or services at the University.
7. The University has a general duty of care to all its students. There may be occasions where an adult student, due to illness, mental health, or personal circumstances, may become vulnerable and at risk of harm. In these circumstances this Policy may also be applicable.
8. The University has a duty of care to apprentices in their workplace (Annex A).
9. This Policy extends to University employees working off campus e.g., professional placements, visits to an apprentice’s place of work, widening participation and recruitment activities in local schools, etc.
10. This Policy must be read in conjunction with the following University policies:
    1. Support to Study Policy
    2. Student Welfare Policy
    3. Student Disability Policy
    4. Prevent Policy
    5. Health and Safety Policy
    6. Bullying, Harassment and Sexual Misconduct Policy
    7. Student Confidentiality Statement
    8. Disciplinary Procedure for Students
    9. Disciplinary Procedure for Staff
11. 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.
12. Why is Safeguarding necessary in Higher Education?
    1. Primary and secondary schools and further education colleges have a statutory duty to safeguard and protect young people in their care. The main legislation is the Children Act 1989, and the Safeguarding Vulnerable Groups Act 2006 as amended by the Protection of Freedoms Act 2012. This duty also applies to apprenticeship programmes such as those delivered by the University.
    2. There is no legislation in this area that is directed specifically at Higher Education Providers delivering degree programmes. However, the University aims to provide a safe environment for visiting children, enrolled students under the age of 18 and vulnerable adults and to ensure that reasonably foreseeable harm does not occur as a result of careless acts or omissions. 
    3. There may be occasions where adult students become vulnerable to abuse or exploitation due to deterioration of their mental or physical health or because of personal circumstances and it may be appropriate for the University to act under this Policy to meet its general duty of care to these students.

General

Policy Statement

13. Northeastern University London (the University) is committed to protecting the welfare of all its students, staff and visitors who access its services and activities. The University recognises that the best protection for children and students participating in its programmes is the vigilance and forethought of staff in preventing circumstances where abuse of trust could occur.
14. The University’s commitment is not just about protecting young people and vulnerable people/adults at risk from deliberate harm, neglect, and a failure to act. It relates to broader aspects of duty of care and education, including:
    1. Students’ health, safety, and wellbeing, including their mental health.
    2. The needs of students with disability-related requirements, including those with long-term medical conditions.
    3. Educational visits or visits by young people for work experience.
    4. Attending campus in regard to outreach, volunteering, or recruitment activities.
    5. Degree apprenticeship programmes, work related  learning programmes, undertaking/participating in research and placements.
    6. Online safety and associated issues.
    7. Appropriate arrangements to ensure students’ security, considering the local context, including students on placement or year abroad and apprentices in employment.
    8. Attendance at specific talks and lectures delivered by external speakers on campus.

University Responsibilities

15. The University is not able to take on the usual rights, responsibilities, and authority that parents have in relation to a child, and it will not act in loco parentis in relation to students who are under the age of 18 years.
16. The University also recognises its responsibility to take appropriate action when a child or student discloses that they are experiencing abuse or neglect, or if staff have a concern about the welfare of a child or student, and to ensure staff understand what might indicate this and what action to take.
17. 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.
18. The University’s Designated Safeguarding Lead is:
    1. Head of Student Support and Development
19. The University’s Deputy Designated Safeguarding Lead is:
    1. Head of Business Development
20. The University will maintain policies and procedures geared towards abuse prevention, including:
    1. Selective vetting of staff and volunteers using DBS checks.
    2. Staff disciplinary procedure.
    3. Clear rules for staff and students/apprentices to follow in the instance of a child entering the University.
    4. Staff induction and training.
    5. Confidential reporting procedure. 
21. All staff will receive induction training, which will give an overview of the organisation and ensure they know its purpose, values, services, and structure.
22. Training on specific areas such as safeguarding children, identifying and reporting abuse, and confidentiality of personal information and compliance with GDPR will be given as a priority to staff who will be in frequent contact with a child, new staff and volunteers, and will be regularly reviewed.
23. In relation to work based learning, including apprenticeships, the University will:
    1. Ensure pre-placement health and safety checks, including insurance checks, are completed, prior to the commencement of work related  activity.
    2. Ensure employers are aware of their safeguarding obligations through training and guidance.
    3. Ensure employers understand and commit to their responsibilities.

Individual Staff Responsibilities

24. Staff should maintain a register of children and students working with them at all times.
25. All children and students, regardless of any protected characteristics under the Equality Act 2010, must be treated with respect and dignity and provided with the same equality of opportunity.
26. Maintain a professional relationship with children and all students.
27. Ensure that if any form of manual/physical touching is required as an element of a seminar, workshop or similar, it is provided openly and with the person’s explicit consent.
28. Never give a child or vulnerable adult, personal details such as personal mobile number, personal email, or home address. Do not engage with children through social networking sites e.g., Facebook. Contact should be restricted to work and public professional communication channels to ensure a professional relationship is maintained.  
29. Under the Sexual Offences (Amendment) Act 2000, it is a criminal offence for any person in a position of trust (which may include members of University staff) to engage in sexual activity with a child.
30. Any personal tutor meetings/tutorials with a child should take place in sight of others or with the doors kept open at all times. Any meeting with apprentices that take place at their place of work, should be done so in sight of others or with the doors kept open at all times and, where possible, with Line Managers also present.
31. All communication between staff and children must take place over their University email addresses. Apprentices may have a work email that is used for correspondence.

Student Responsibilities

32. Students must treat faculty, staff and fellow students with courtesy and respect, both on and off University premises, in person and on-line.
33. Students are expected to attend induction sessions which will include information on Prevent and Safeguarding, and the University’s Bullying, Harassment and Sexual Misconduct Policy, Disciplinary Procedure for Students, and the Health and Safety Policy.
34. Any concerns about the wellbeing or safety of themselves or another student should be brought to the attention of a member of staff as soon as possible, which will then be referred to the Designated Safeguarding Lead for consideration.

What Constitutes Abuse? 

35. In drawing up guidance locally, it needs to be recognised that the term ‘abuse’ can be subject to wide interpretation.
36. Abuse may consist of a single act or repeated acts. It may be physical, verbal, or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which they have not consented or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it.
37. A consensus has emerged identifying the following main different forms of abuse:
    1. Physical abuse, including hitting, slapping, pushing, kicking, misuse of medication, restraint, or inappropriate sanctions.
    2. Psychological abuse, including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks.
    3. Discriminatory abuse, including racist, sexist, that based on a person’s disability, and other forms of harassment, slurs, or similar treatment.
    4. Sexual abuse, including rape and sexual assault or sexual acts to which the child or vulnerable adult has not consented, or could not consent or was pressured into consenting.
    5. Financial or material abuse, including theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions, or benefits.
    6. Neglect and acts of omission, including ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate nutrition, and heating.
38. Any or all these types of abuse may be perpetrated as the result of deliberate intent, negligence, or ignorance.

Procedure if a Child or Student Discloses Abuse by Someone Else

39. If a child or student 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.
40. It is vitally important that no promise is given to keep the information confidential.
41. If a child can understand the implications of making a referral to the Local Authority’s Children’s Services, then they should be asked for their view, but it must be made clear that University staff have a responsibility to take what action is necessary to ensure the child’s safety.
42. If the student is over 18 and a vulnerable adult and can understand the implications of making a referral to the Local Authority’s Adult Services then they should be asked for their view, but it must be made clear that University staff have a responsibility to take what action is necessary to ensure their safety.
43. If the student is over 18 and not a vulnerable adult, then they should normally decide what, if any, information is shared. However, it must be made clear that University staff have a responsibility to act if there is an imminent risk to their safety or to others.
44. The steps which should be followed are:
    1. Stay calm.
    2. Listen carefully to what the child/student 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/student 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/student that they have done the right thing by talking to someone.
    6. Make sure the child/student 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 or Adult 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. Contact the Designated Safeguarding Lead as soon as possible.
    9. Do not discuss the disclosure with other staff; discussion should be strictly on a ‘need to know’ basis. Find out when the child/student is next due to see the individual who is the subject of the complaint. (A judgment will need to be made as to the appropriate timing of any follow-up actions to ensure that the child/student remains safe.)
45. Students who are not children or vulnerable adults may disclose abuse. While in these cases it would not normally be appropriate to contact Local Authority Children’s Services, advice should be sought from the Designated Safeguarding Lead with regards to what action might be required. Actions may include seeking support from the Police, specialist charity services or NHS services depending on the nature of the abuse reported and the needs and wishes of the student.
46. Where an allegation is made against another student at the University the Designated Safeguarding Lead may refer the matter to the Registrar as set out under the Disciplinary Procedure for Students.
47. Concerns about the welfare of a child or student, 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 or student. In these instances, it is equally important to act, and these concerns should be raised and discussed with the Designated Safeguarding Lead.

Procedures for Dealing With Suspected Abuse by Members of Staff

48. When dealing with reported or suspected abuse involving allegations against a member of staff, managers and Board Members must remember that the welfare of children and vulnerable adults at the University is paramount, but that the University also has a responsibility to ensure that University staff are treated fairly and with respect.
49. The accused member of staff should be informed of the allegation as soon as possible.
50. The Designated Safeguarding Lead will immediately inform Human Resources on receipt of a report that any member of staff 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 a way that indicates they may not be suitable to work with children.
51. The Designated Safeguarding Lead will ensure that records are kept of all reports and that they are held securely in accordance with GDPR and the University’s Student Confidentiality Statement.

Investigation of Allegations

52. Where an allegation of inappropriate behaviour, abuse or neglect is made against a member of staff, occurring in the course of their work, the University will carry out a full investigation into the circumstances before any action is taken. It may be necessary to suspend the individual until the investigation is concluded.
53. The investigation will be conducted by Human Resources (HR).
54. HR will seek to fully understand the allegation being made and establish the basic facts of the case. This will normally be done by HR speaking to the child/student making the allegation, any relevant witnesses, and the staff member against whom the allegation has been made. Any children interviewed should be accompanied by a parent or carer and a student over the age of 18 should be permitted to be accompanied by a friend or family member, if they choose. The staff member against whom the allegation is made is also entitled to be accompanied by a Trade Union representative or colleague.
55. The investigation should normally be completed within 10 working days. Where it is not possible for good reason to complete the investigation within the time frame, the child/student making the allegation and the staff member against whom the allegation has been made should be informed of the reason for the delay and when the investigation is expected to be completed.
56. Support will be offered, both to the child/student and to any member of staff against whom allegations have been made. For the child this might be provided by their parents or carers, who may themselves need support to do this. For as student over the age of 18 this may be a friend, family member or member of Student Support and Development.

Guidance for Staff in the Event of an Allegation

57. Staff should remain calm and not attempt to engage with the party making the complaint. Staff should inform their line manager, and the Designated Safeguarding Lead immediately.
58. Make a written record of the facts as they recall them.
59. Ensure that no-one is placed in a position which could cause further compromise. Do not contact another agency involved with the child, vulnerable adult or student concerned.

Confidentiality

60. Whatever the nature of the disclosure, suspicion, or complaint, it must be kept confidential.

Staying Safe Online

61. Use of the internet and digital technology is part of most people’s everyday lives. The University uses the internet to support its provision of undergraduate, postgraduate and apprenticeship programmes. It is essential that all students (including apprentices and mobility students) have the knowledge and skills to use the internet safely and appropriately.
62. Staying safe online includes ensuring the security of personal and employers’ data and being aware of the dangers of:
    1. Bullying
    2. Harassment
    3. Grooming
    4. Revenge porn
    5. Identity theft
    6. Viruses

Recognising Signs of Radicalisation

63. Extremists may seek to exploit vulnerable individuals and draw them into terrorist activities. This therefore represents a safeguarding concern.
64. As part of the Counterterrorism and Security Studies Act 2015, the University is required to pay ‘due regard’ to the need to prevent individuals from being radicalised and drawn into terrorism.
65. 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.
66. Employers and University staff should follow the University’s Prevent Policy if they become concerned about a child, student or apprentice being radicalised.

Monitoring and Reviewing

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

Version History

Annex A1: Apprenticeships

General Principles

1. The University is committed to ensuring the highest levels of safety and wellbeing for all apprentices, and this is achieved by working in partnership with employers.
2. To ensure the safety and wellbeing of apprentices it is critical that employers understand their responsibilities to apprentices and that they work closely and cooperatively with the University in the event that a safeguarding concern is raised about an apprentice.
3. The Work Related Learning Management Board will ensure that the learning and wellbeing of apprentices is regularly reviewed and monitored and will ensure that employers meet the requirements set out in this Annex.

The Employer’s Responsibilities

4. Employers have a duty to comply with all current and future UK legislation and statutory responsibilities and should familiarise themselves with relevant government legislation such as the requirements of the Equality Act 2010. Employers we work with have the primary responsibility for health and safety in the workplace and managing any significant risk for apprentices or students on Work Related Learning Programmes. Employers will:
   1. Take appropriate steps to understand what safeguarding means in practice at their organisation, in the context of the responsibilities that they have for the people they employ.
   2. Ensure that staff working with apprentices or work related learners in a position of trust, are appropriate for the role and do not present any danger or threat.
   3. Ensure apprentices are aware of organisational policies relating to internet use at work.
   4. Ensure that any people working with children or vulnerable adults have had an enhanced Disclosure and Barring Service check.
   5. Ensure, if possible, to have a single point of contact within the organisation to coordinate safeguarding across the organisation.
   6. Demonstrate a commitment to the principles that underpin the Prevent Duty.
   7. Demonstrate a commitment to British values.
   8. Ensure apprentices are made aware of the organisation’s policies on using the Internet and technology in the workplace.
   9. Take responsibility for an apprentice’s welfare in the workplace and to seek appropriate advice when they feel an apprentice may be at risk in their personal lives.
   10. Sign an Employer’s Declaration to say they have read and understood their duty to safeguard the University’s apprentices.
   11. Complete and sign a health and safety declaration and provide copies of insurance certificates to evidence their suitability, legal cover, responsibility, and commitment to safeguard their apprentices and provide a safe working environment.
   12. Contribute to Safeguarding, British Values, and Prevent conversations with their apprentice at 6-8 weekly tripartite reviews and maintain open channels of communication regarding apprentices.
5. Employers and staff should not:
   1. Buy alcohol for someone under the age of 18 for the consumption on licensed premises. A 16 or 17-year-old may drink beer, wine, and cider with a table meal if they are accompanied by an adult.
   2. Spend excessive time alone with children or vulnerable adults away from others.
   3. Take children or vulnerable adults alone in a car journey, however short.
   4. Take children or vulnerable adults to their home.
   5. Engage in physical or sexually provocative games including horseplay.
   6. Allow or engage in inappropriate touching of any form.
   7. Make over-familiar or sexually suggestive comments or approaches to a child or vulnerable adult even as a ‘joke’.
   8. Let allegations, over familiar or sexually suggestive comments or approaches made by a child or vulnerable adult go unchallenged or unrecorded.
   9. Do things of a personal nature that children or vulnerable adults can do for themselves.
   10. Take photographs, videos or other images of children or vulnerable adults without the express permission of their parents or legal guardians.
   11. Allow inappropriate computer activity whether internet or network related. This includes mobile phone or related technologies.

Safeguarding Warning Signs

6. An apprentice may not always choose to seek help over an issue that would be considered under safeguarding, but there are common characteristics which may help identify a concern:
   1. Absence from work or reluctance to study/go online.
   2. Changes in physical appearance
   3. Changes in behaviour/character (quiet, loud, aggressive, withdrawn)
   4. Changes in emotional health (crying, low mood, anxiety)
   5. Excessive alcohol consumption
   6. Use of controlled/illegal psychoactive substances
   7. Physical injuries (cuts, bruises) and self-harm
7. It is important to stress that this list of examples is not exhaustive, and existence of these signs is not a definitive indicator of a safeguarding concern. However, if an employer suspects an issue, we recommend they speak to the apprentice as soon as possible and report any safeguarding issues to the University’s Designated Safeguarding Lead as set out in the main policy.

What an Apprentice Should Do to Report a Safeguarding Concern at Work

8. An apprentice who has concerns about abuse, bullying, harassment, exploitation, or neglect at work should speak to their line manager or Human Resources Department as soon as possible and follow their employer’s policies and procedures. 
9. An apprentice may also speak to the University’s Business Relations Manager who supports them on their apprenticeship about any safeguarding issues or concerns in their workplace.

Annex A2: Apprentice Employer Declaration

Employer’s Declaration

I have read and understood my obligations as an employer and will ensure that:

• Staff who have regular contact with apprentices understand their individual and collective responsibility to the health, safety, and well-being of the apprentice at all times.
• The apprentice will work in a safe and productive work environment.
• The apprentice will be provided with equality of opportunity.
• The organization will work with the University to promote professional business behaviours and report any concerns.
• The organisation will work in partnership with the University to identify risks in the workplace including health and safety, safeguarding and radicalisation, and will promote equality and diversity and British values.

Name of Organisation:

Employer signature:

Employer name:

Date:

Annex B: Virtual Learning

The University continues to be committed to protecting the welfare of all its students, apprentices, work related learners, and staff through virtual learning platforms.

It is important that all staff who interact with children and vulnerable adults, including online, continue to look out for signs a child or vulnerable adult may be at risk. Any such concerns should be dealt with as per the above policy and, where appropriate, referrals should continue to be made to the Designated Safeguarding Lead.

Code of Behaviour and Good Practice When Interacting Virtually

• Identify a suitable environment for the call. Discourage, where possible, students and learners from making video calls from their bedroom.
• Appropriate clothing for all participants.
• Distractions and disturbances minimised.
• Use a headset or headphones.
• Cameras optional but preferred.
• Adherence of all to relevant behaviour and conduct policies.
• Maintain a central register of all video calls and contacts – include the link to the call.
• Adherence to the pre-agreed policy for the recording of sessions.
• Involve parents and carers to ensure that they are well-informed.
• Be conscious of confidentiality when working online.