Safeguarding Policy – CILEX

Datalaw Safeguarding & Child Protection Policy

(Aligned with CILEX – the Chartered Institute of Legal Executives)

1. Introduction and Ethos

Datalaw recognises its statutory and moral duty to safeguard and promote the welfare of children, young people and adults at risk. This duty extends to all learners and candidates engaging with Datalaw programmes and qualifications, including those delivered in partnership with CILEX.

Safeguarding at Datalaw is everyone’s responsibility. It applies to all employees (permanent, temporary and agency); directors and senior leaders; contractors and freelance tutors/assessors; volunteers and visitors; all learners and candidates; and any individual acting on behalf of Datalaw in relation to CILEX delivery or assessment.

Datalaw is committed to promoting a culture where learner safety, wellbeing and empowerment are central; providing opportunities for children, young people and adults at risk to seek support, express concerns and develop resilience, confidence and independence; and ensuring all relationships are based on mutual respect, equality and inclusion.

Staff are expected to maintain the professional mindset of “it could happen here”, meaning they must never assume that safeguarding concerns will not arise within Datalaw or its CILEX-related provision. All decisions must be guided by the best interests of children and adults at risk.

Datalaw believes that every person, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation, has an equal right to be safe and to be protected from abuse, neglect, exploitation or discrimination.

Datalaw will provide a safe, caring and stimulating learning environment; appropriate physical and online safeguards; professional practice that reflects best practice in safeguarding children and adults at risk; and robust arrangements for identifying, responding to and managing safeguarding concerns. These commitments apply equally across all CILEX-approved and CILEX-related programmes, delivery models and assessment activities.

Core Safeguarding Principles

Datalaw’s safeguarding approach is built on five key principles:

1. Prevention – creating a culture where abusive or unsafe behaviour is not tolerated; designing learning, assessment and workplace practices to minimise risks; and using safer recruitment and vetting procedures.
2. Protection – ensuring staff are trained to recognise signs of abuse, neglect or exploitation; and providing clear procedures to report and act on concerns quickly and correctly.
3. Support – supporting learners, staff and others who may be experiencing or disclosing harm; and signposting to appropriate internal support and external specialist services.
4. Collaboration – working with parents, carers, local safeguarding partners, police, social care and other agencies; and collaborating with CILEX where safeguarding issues relate to CILEX qualifications, candidates, assessments or centre approval.
5. Responsibility – making clear that everyone has a role in safeguarding; and ensuring leadership and the Designated Safeguarding Lead (DSL) are accountable for the effectiveness of safeguarding arrangements, in line with KCSIE 2025.

2. Aims of the Safeguarding Policy

The purpose of this policy is to set out how Datalaw safeguards children, young people and adults at risk; meets its legal duties; and complies with safeguarding expectations set by CILEX and other regulators.

Datalaw aims to protect children and adults at risk from harm by implementing clear staff and volunteer codes of conduct, defining acceptable and unacceptable behaviours, and ensuring all staff know how to respond appropriately to concerns or disclosures; promote safeguarding awareness and good practice by sharing guidance, raising awareness of abuse, neglect, exploitation and mental health issues, and promoting safer use of digital technology; embed safer recruitment through robust pre-employment checks (including DBS), re-checking staff where required, and maintaining a Single Central Record; create a safe reporting culture by ensuring learners and staff know how to raise concerns, providing multiple routes to report including anonymous and whistleblowing routes, and making clear that retaliation is unacceptable; ensure effective communication and liaison with local safeguarding partners, police and social services, and with CILEX where concerns relate to CILEX learners, staff or qualifications; provide consistent safeguarding training at induction and through regular refreshers reflecting KCSIE 2025 and emerging risks; maintain accurate, confidential records stored securely and compliant with UK GDPR and the Data Protection Act 2018; and continuously improve safeguarding practice by reviewing policies at least annually and learning from incidents and external guidance.

3. Policy Context and Legal Framework

This policy sits within a framework of UK legislation, statutory guidance and local arrangements. It also supports Datalaw’s contractual and regulatory obligations as a provider working with CILEX. Key legislation and guidance includes (but is not limited to):

• Children Act 1989 and Children Act 2004
• Education Act 2002
• Children and Social Work Act 2017
• Care Act 2014 (adult safeguarding)
• Safeguarding Vulnerable Groups Act 2006
• Working Together to Safeguard Children (2018)
• Keeping Children Safe in Education (KCSIE 2025)
• Data Protection Act 2018 and UK GDPR
• Human Rights Act 1998
• Modern Slavery Act 2015
• Counter-Terrorism and Security Act 2015 (Prevent Duty)
• Channel Duty Guidance
• Local safeguarding children and adult board arrangements (e.g. Liverpool)

Datalaw understands that CILEX, as an awarding body, has its own standards and expectations for approved centres. This policy is designed to be consistent with those expectations and to provide assurance that Datalaw can keep CILEX learners safe, respond appropriately to safeguarding issues, and inform CILEX where necessary and appropriate.

Datalaw also acknowledges the ongoing impact of Covid-19 on learner and staff wellbeing, and the potential for isolation, financial pressure or bereavement to increase vulnerability. Staff must remain vigilant to any safeguarding risk arising from social, emotional or mental health challenges.

4. Safeguarding Adults at Risk

Datalaw is committed to protecting adults at risk—those aged 18 or over who may be unable to protect themselves because of care and support needs. Key principles include recognising the additional risk factors that can increase vulnerability (e.g. disability, mental ill-health, substance misuse, domestic abuse, immigration/asylum, social isolation); taking all concerns seriously and not dismissing them due to age, status or perceived capacity; balancing empowerment and autonomy with the need to take protective action where there is a risk of serious harm; and working in line with the Care Act 2014, local adult safeguarding procedures and CILEX requirements where a CILEX learner is involved.

Datalaw will encourage adults at risk to express their views and wishes; make referrals to adult safeguarding teams, police or other agencies when needed; seek consent where appropriate but act in the person’s best interests where consent cannot be obtained or where others may be at risk; and maintain confidentiality and handle information lawfully and sensitively.

5. Data Protection and Information Sharing

Safeguarding almost always involves sharing information. Datalaw balances the need to protect individuals with the duty to respect privacy and data protection law. Datalaw will maintain safeguarding records in secure systems with restricted access; ensure that information is shared on a “need-to-know” basis only; use lawful bases for processing data, such as vital interests, legal obligation or public task; share information with external agencies (social services, police, health, Channel, Prevent, CILEX) where it is necessary to protect children or adults at risk; and provide clear guidance to staff that data protection does not prevent lawful information sharing for safeguarding.

Staff must never promise complete confidentiality to a child, young person or adult at risk; follow Datalaw procedures for recording and passing on information; and use secure communication channels when sharing sensitive information.

6. Implementation, Monitoring and Review

This policy applies to all Datalaw activities; all programmes, including those accredited or recognised by CILEX; and all staff, contractors, associates, volunteers and learners. Implementation is achieved through clear leadership from the DSL and senior team, robust staff training and induction, safeguarding embedded into operational procedures (HR, teaching, assessment, complaints), and regular communication and awareness-raising.

The policy will be reviewed at least annually, or sooner if legislation changes, CILEX updates its expectations or centre requirements, new safeguarding risks emerge, or significant safeguarding incidents occur. It is monitored through safeguarding incident logs, audit of training completion and SCR, and internal reviews and external quality assurance.

7. Definitions

7.1 Safeguarding

Safeguarding is the umbrella term for all the work Datalaw does to keep people safe, especially those who are vulnerable. It includes preventing abuse and neglect; protecting individuals from harm and exploitation; promoting wellbeing and resilience; and ensuring safe and nurturing environments in all settings (on-site, remote, online). Safeguarding covers, for example: child abuse and neglect (physical, emotional, sexual, neglect); adult abuse and neglect; domestic abuse; bullying and cyberbullying; online safety and digital exploitation; trafficking and modern slavery; mental health concerns linked to risk of harm; substance misuse; radicalisation and extremism; gender-based violence, sexual harassment and exploitation; and discrimination, hate crime and abuse linked to disability or identity.

7.2 Adult at Risk

An adult at risk is any person aged 18 or over who has needs for care and support (because of physical or mental health, disability, age, sensory impairment, substance misuse or other circumstances), and is unable to protect themselves from, or is at increased risk of, abuse or neglect.

7.3 Child

For the purposes of this policy, a child is anyone under 18. This includes 16–17 year olds who may be living independently, in work, in further education or in custody; and unborn children, where safeguarding concerns are present in pregnancy. Children retain their entitlement to safeguarding regardless of living arrangements, education status or employment.

8. Safeguarding in a Training and CILEX Assessment Environment

8.1 DSL Referrals

All concerns about a learner’s welfare must be reported to the Designated Safeguarding Lead (DSL) or Deputy DSL. The DSL will decide whether to manage the concern internally with support and monitoring; to consult or refer to local safeguarding partners, social care, police, Channel or Prevent; or to notify CILEX where the concern relates to a CILEX qualification, candidate, assessment or any matter that could affect centre approval or assessment integrity.

8.2 Datalaw’s Commitments as a Training Provider

Datalaw will appoint a trained DSL and Deputy DSL with sufficient time and authority to fulfil their role; ensure all staff, tutors, assessors, IQAs and exam personnel are aware of safeguarding procedures and know how to respond to concerns or disclosures; provide safeguarding and child protection training at induction and regular refreshers; operate safer recruitment and ensure appropriate DBS checks are in place; maintain clear and robust referral, monitoring and escalation procedures; ensure that CILEX learners and apprentices know how to seek help or raise concerns; and align all procedures with data protection law and CILEX requirements.

8.3 Complaints and Learner Concerns

All learners, parents, carers and staff have the right to raise safeguarding concerns through Datalaw’s complaints process, direct contact with the DSL or Deputy DSL, or whistleblowing routes where appropriate. Allegations against staff will be handled in line with statutory guidance and local LADO/Designated Officer procedures, with proportionate, timely investigation, and with CILEX notified where the allegation relates to a CILEX programme or candidate.

9. Roles and Responsibilities

9.1 Senior Leadership and Governance

Senior leaders and/or the governing body are responsible for approving this policy and ensuring it is implemented; providing sufficient resources to operate effective safeguarding; ensuring there is always access to a trained DSL; receiving reports on safeguarding trends and CILEX-related safeguarding issues; and ensuring alignment with statutory guidance and CILEX requirements.

9.2 Designated Safeguarding Lead (DSL)

The DSL oversees all safeguarding and child protection arrangements. Responsibilities include being the central point of contact for safeguarding concerns; maintaining secure, confidential safeguarding records; ensuring policies, procedures and practice are up to date; liaising with external agencies (social care, police, local safeguarding partners, Channel, Prevent); ensuring staff receive appropriate and timely safeguarding training; ensuring cover during holidays and out-of-hours activities; monitoring the effectiveness of safeguarding systems and making improvements; acting as Mental Health Lead where designated; and deciding when to notify or consult CILEX, especially where a concern affects a CILEX learner or candidate, an allegation involves a member of staff delivering CILEX programmes, or a safeguarding matter could impact exam integrity or centre approval. The Deputy DSL supports the DSL and acts in their absence. Both must receive formal safeguarding training at least every two years and maintain their knowledge through annual updates.

9.3 Staff, Tutors, Assessors and Invigilators

All staff and associates must provide a safe environment for learning and assessment; understand and follow Datalaw’s safeguarding policy and staff Code of Conduct; be alert to indicators of abuse, neglect, exploitation or mental health concerns; know how to respond professionally to disclosures; report concerns immediately to the DSL/Deputy DSL; maintain appropriate confidentiality while prioritising safety; and understand how safeguarding applies in online, hybrid and remote learning/assessment environments.

9.4 Learners

Learners, including CILEX candidates, have the right to feel safe and be listened to; have their views, wishes and feelings taken seriously; access support from a trusted adult; learn how to protect themselves, including online safety and personal boundaries; and be informed about how to report concerns or complaints.

9.5 Parents and Carers

Parents and carers are expected to familiarise themselves with Datalaw safeguarding information; support their child’s learning and safety, including in online/remote environments; raise concerns promptly if they are worried about a child’s welfare; and work in partnership with Datalaw and external agencies where safeguarding concerns exist.

10. Confidentiality and Information Sharing

Datalaw’s approach is that safeguarding concerns must always be reported, not kept secret; staff must never promise absolute confidentiality to a learner; information is shared strictly on a need-to-know basis, with those who have a legitimate role in protecting the individual; and where possible, consent is sought before sharing information, however the absence of consent does not prevent sharing if a child or adult at risk could be harmed. The Data Protection Act 2018 and UK GDPR allow for lawful sharing of personal information for safeguarding and crime prevention, and require that such sharing is necessary, proportionate and secure. Information may be shared with local authority children’s or adult safeguarding teams; police or other law enforcement; health professionals; Channel/Prevent; and CILEX, where the issue relates to CILEX provision and sharing is necessary to protect learners, uphold assessment integrity or meet regulatory duties.

11. Supporting Staff and Safer Working Practice

Safeguarding work can be emotionally demanding. Datalaw will provide safeguarding induction and role clarity; give staff access to supervision, guidance and support via the DSL and managers; promote a culture where staff can discuss concerns about their own wellbeing; and offer access to further support as required (e.g. occupational health, EAP if available). Safer working practices include adhering to the Code of Conduct and professional boundaries; avoiding situations that could be misinterpreted (e.g. being alone behind a closed door); using only approved communication channels with learners; using social media and digital technologies in line with Acceptable Use and Social Media policies; and documenting and reporting any physical intervention used for safety reasons.

12. Induction, Training and Whistleblowing

12.1 Induction and Ongoing Training

All staff, tutors and associates (including those working on CILEX programmes) receive safeguarding training covering Datalaw’s safeguarding and child protection policy; the role of the DSL and reporting routes; signs and indicators of abuse and neglect (in line with KCSIE 2025); online safety, Prevent and other key risk areas; and data protection and confidentiality in safeguarding. Completion is recorded on the Single Central Record. All staff receive at least annual updates.

12.2 Whistleblowing and Escalation

Datalaw encourages a transparent, open culture. Staff are required to report concerns about colleagues’ conduct, unsafe practice or failures in safeguarding arrangements. Concerns may be raised with a line manager, DSL, senior leader or through a whistleblowing route. Staff may contact external whistleblowing services (e.g. NSPCC, Ofsted) where appropriate. It is a disciplinary matter not to report a safeguarding concern or known risk of harm.

13. DBS Referral and Allegations Management

13.1 DBS Referrals

Datalaw has a legal duty to refer individuals to the Disclosure and Barring Service (DBS) if they have harmed or posed a risk of harm to a child or vulnerable adult, or they have been removed (or would have been removed) from regulated activity due to safeguarding concerns. Failure to refer without good reason is a criminal offence.

13.2 Responding to Disclosures, Suspicion and Allegations

When someone discloses abuse or a member of staff suspects abuse, the person receiving the concern must stay calm and listen carefully; reassure the person that they have done the right thing; avoid leading questions or investigation; explain that information will be shared with people who need to know; make a factual, written record as soon as possible; and report to the DSL immediately. Allegations against staff, tutors, contractors or volunteers will be reported promptly to the DSL and senior leadership; managed in line with statutory guidance and local LADO/Designated Officer procedures; notified to CILEX where relevant to CILEX programmes or candidates; and investigated fairly and proportionately, with decisions made about suspension, restrictions or redeployment while investigations are ongoing.

14. Code of Conduct, Professional Boundaries and Relationships

Datalaw’s Code of Conduct sets out expectations for behaviour, language, contact and professional boundaries. The Code is designed to protect children, young people and adults at risk from harm; protect staff from unfounded allegations; and clarify the consequences of misconduct. Key points: avoid unnecessary physical contact and record/report any physical intervention used for safety; avoid meeting learners alone in isolated settings whenever possible; maintain professional relationships with learners at all times with no social, financial or sexual relationships; comply with the Sexual Offences Act 2003, which prohibits sexual relationships between staff and learners in a position of trust, regardless of the learner’s age; do not use personal social media or personal devices to contact learners; and avoid giving or receiving personal gifts where this may be misinterpreted.

15. Anti-Bullying

Datalaw is committed to an environment free from bullying, including verbal, physical and emotional bullying; cyberbullying; and racist, sexist, homophobic, biphobic or transphobic bullying. Staff must recognise that learners with SEND or other vulnerabilities may be at higher risk; treat bullying as a safeguarding concern where it causes significant harm or risk of harm; follow reporting and recording procedures; and implement support and, where necessary, disciplinary action.

16. Online Safety and Digital Technology

Digital environments are integral to Datalaw’s delivery, especially for online learning and CILEX-related study. Datalaw will implement appropriate filtering and monitoring systems for online platforms it controls; provide guidance to learners on safe online behaviour, privacy and digital footprint; ensure staff use secure, approved systems and follow data protection rules; and respond to online safeguarding incidents such as grooming, exploitation, cyberbullying, sexting, illegal content or extremist material. Staff responsibilities include reporting concerning online behaviour or access to inappropriate content; not assuming that filtering/monitoring will catch everything; alerting the DSL/IT if teaching materials might trigger alerts (e.g. lessons on extremism); and reporting any attempts to bypass security controls.

17. Tuition Setting, Environment and Premises Security

Datalaw will ensure that all learning and assessment environments (physical and online) are safe, accessible and suitable for the age and needs of learners; equipped appropriately (lighting, seating, equipment); and free from avoidable hazards or distractions. Tutors must follow identification and site procedures when working in external venues; ensure one-to-one sessions are conducted in visible/accessible spaces; report any concerns about a venue or environment to the DSL immediately; and dress appropriately and be sensitive to cultural and religious considerations. All staff share responsibility for premises security and must report issues that could compromise safety.

18. Safer Recruitment and Pre-Employment Checks

Datalaw’s safer recruitment approach ensures that people who are unsuitable to work with children and adults at risk are not employed or engaged. This includes clear roles and responsibilities highlighting safeguarding duties; application forms requiring full employment history and gaps explained; identity and right-to-work checks; qualification verification for teaching/assessing roles; health and fitness to work checks where appropriate; obtaining and verifying at least two professional references; conducting enhanced DBS checks with barred list checks where roles involve regulated activity; using the DBS Update Service and requiring regular re-checks as needed; and maintaining a Single Central Record of checks in line with KCSIE 2025. Staff are required to declare anything that might affect their suitability to work with vulnerable groups.

19. Record Keeping and Data Security

All safeguarding concerns, conversations, decisions and actions must be recorded promptly, clearly and factually, using where possible the learner’s own words, and signed and dated by the person making the record. Records are stored separately from general learner records in a secure safeguarding system/folder; accessible only to the DSL, Deputy DSL and authorised staff on a strict need-to-know basis; and retained and disposed of in line with legal and regulatory requirements. All staff receive training on data protection in safeguarding, including lawful information sharing with relevant agencies and, where necessary, CILEX. Digital safeguarding records are protected through technical and organisational security measures, appropriate access controls, and regular review and audit of systems and processes.

20. Multi-Agency Working and Collaboration with CILEX

Datalaw recognises its statutory duty to work within local multi-agency safeguarding arrangements and its responsibilities as a centre working with CILEX. Datalaw will attend and contribute to case conferences, core groups, Child in Need meetings, strategy meetings and other relevant forums; collaborate with health, education, police, social care and voluntary agencies; and share information with CILEX where a safeguarding concern involves a CILEX learner or candidate, a staff member delivering CILEX programmes is implicated, or an incident may impact CILEX assessment integrity or centre compliance. Datalaw will cooperate fully with CILEX audits, investigations and quality assurance that relate to safeguarding and learner welfare.

21. Safeguarding Learners with SEND and Other Vulnerable Groups

Children and adults with Special Educational Needs and Disabilities (SEND) or other vulnerabilities may have greater difficulty recognising or communicating abuse; be more dependent on others for care and support; and experience isolation, exclusion or bullying. Staff must be alert to changes in behaviour, mood or physical presentation; not automatically attribute all concerns to SEND or disability; work with external specialists (e.g. SENDCos, mental health services) to plan support; and recognise additional risks for groups such as LGBT learners or those experiencing difficult family circumstances. Datalaw will seek advice from specialist organisations as appropriate (e.g. SENDIASS, Mencap).

22. Preventing Radicalisation and Extremism (Prevent & Channel)

Under the Counter-Terrorism and Security Act 2015, Datalaw and its staff must have due regard to preventing individuals from being drawn into terrorism. Datalaw will train staff to recognise indicators of radicalisation (e.g. changes in behaviour, expressing extremist views, associating with extremist groups); encourage open, critical discussion and promote British Values; have clear referral routes to the DSL for Prevent concerns; and refer appropriate cases to Channel via local safeguarding partners. The DSL will liaise with Prevent officers and coordinate information sharing and support for individuals at risk.

23. Monitoring, Compliance and Review

Datalaw will monitor this policy and its implementation through regular review of safeguarding incidents, trends and outcomes; sampling of safeguarding records for quality and completeness; monitoring training completion and staff understanding; and internal and external audits (including CILEX-related quality assurance visits). This policy will be formally reviewed at least once per year; updated when necessary to reflect changes in law, guidance or CILEX requirements; and re-issued to staff, with key changes highlighted.

Reviewed Date	03rd December 2025	Next Review Due Date	03rd December 2026
Reviewed by	Sarah Parker	Signature	Sarah Parker

Datalaw 2025    Safeguarding Policy – CILEX    DPP087