Safeguarding Policy

Datalaw Safeguarding Policy

1. Introduction and Ethos

Datalaw Limited acknowledges its statutory duty to safeguard and promote the welfare of children, young people, and vulnerable adults. Safeguarding is the responsibility of everyone within the organisation, including staff, volunteers, learners, and stakeholders.

We prioritise safety, wellbeing, and empowerment, encouraging children, young people, and vulnerable adults to seek guidance to develop resilience, confidence, and independence. All interactions are based on mutual respect, equality, and inclusion.

Staff are expected to maintain an attitude of “it could happen here” and ensure the best interests of children and vulnerable adults guide all decisions. Every individual, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation, has an equal right to protection from harm or abuse.

Datalaw provides a safe, caring, and stimulating environment that promotes the academic, social, emotional, and moral development of children, young people, and vulnerable adults, while ensuring safe professional practice in line with safeguarding policies.

Core Safeguarding Principles:

  • Prevention: Promote a positive, safe culture through supportive learning and working environments, safer recruitment, and protective practices.
  • Protection: Equip all staff with training to identify and respond appropriately to safeguarding concerns.
  • Support: Provide guidance and intervention for learners, staff, and others at risk.
  • Collaboration: Work with parents, carers, and relevant agencies in Liverpool to respond promptly and effectively to concerns.
  • Responsibility: Everyone in contact with children or vulnerable adults has a role to play, in line with KCSIE 2025.

2. Aims of the Safeguarding Policy

Datalaw aims to safeguard children, young people, and vulnerable adults by:

  • Implementing child protection codes of conduct for staff and volunteers.
  • Sharing safeguarding guidance and promoting good practice among learners, staff, and families.
  • Following safer recruitment procedures to ensure ongoing staff suitability.
  • Creating an environment where individuals feel safe to raise concerns.
  • Maintaining effective communication with Designated Safeguarding Leads (DSLs), National/Regional safeguarding authorities, police, and social services.
  • Ensuring all staff understand safeguarding procedures for both children and adults, including reporting mechanisms.
  • Maintaining accurate, confidential safeguarding records in compliance with UK Data Protection Law (DPA 2018, GDPR) and specific data protocols.
  • Cooperating fully with local authorities and law enforcement to protect individuals at risk.
  • Providing regular safeguarding training aligned with KCSIE 2025.
  • Reviewing and updating policies annually or in response to legislative changes or safeguarding incidents.

3. Policy Context

This policy reflects statutory and legal frameworks including:

  • Children Acts 1989 & 2004
  • Children and Social Work Act 2017
  • Education Act 2002
  • Education and Training Act 2021
  • Keeping Children Safe in Education (KCSIE 2025)
  • Working Together to Safeguard Children 2018
  • Care Act 2014
  • Data Protection Act 2018 & GDPR
  • Human Rights Act 1998
  • Modern Slavery Act 2015
  • Channel Duty Guidance 2015
  • Liverpool City Council Safeguarding Children and Adults Guidance

Datalaw acknowledges the ongoing impact of Covid-19 on learner wellbeing and staff must remain vigilant to safeguarding risks arising from social or emotional challenges.

4. Safeguarding Adults

Datalaw is committed to safeguarding adults at risk. This includes:

  • Recognising risk factors and circumstances that may increase vulnerability.
  • Reporting abuse, neglect, or exploitation promptly.
  • Respecting the individual’s rights, dignity, and autonomy while taking proportionate action to safeguard them.
  • Ensuring cooperation with police and local safeguarding authorities in Liverpool and all other specific authorities.
  • Maintaining confidentiality and compliance with data protection legislation.

Adults at risk are actively supported to communicate their views, and their wishes are respected unless there are overriding safeguarding concerns.

5. Data Protection and Information Sharing

Safeguarding records are securely maintained in line with DPA 2018, GDPR, and all data protection policies. Information is shared only on a “need-to-know” basis with external agencies such as social services or the police, balancing statutory safeguarding duties with data privacy requirements.

6. Implementation and Review

This policy applies to all staff, volunteers, learners, and stakeholders at Datalaw. Safeguarding practices are reviewed annually or sooner if:

  • There are changes in legislation or government guidance.
  • New safeguarding risks are identified.
  • Local or national safeguarding authorities issue updated guidance.

All staff are required to complete safeguarding training regularly and maintain a vigilant approach to protect children, young people, and vulnerable adults.

7. Definition of Safeguarding

7.1 Safeguarding refers to a comprehensive set of measures and actions designed to protect individuals, particularly those who are vulnerable, from harm, abuse, neglect, or exploitation. It involves strategies and practices that promote the safety, well-being, and development of people across various settings, including education, healthcare, social care, and the wider community.

Safeguarding applies in different contexts, including child safeguarding, adult safeguarding, and safeguarding within specific professional or organisational environments.

The primary objectives of safeguarding are to prevent harm, detect and respond to signs of abuse or neglect, and to promote safe and nurturing environments where individuals can thrive. Effective safeguarding requires collaboration among professionals, organisations, statutory agencies, and local communities to establish protective systems and support networks.

Safeguarding encompasses a broad range of specific issues, including but not limited to:

  • Child Abuse and Neglect: Physical, emotional, sexual abuse, and neglect affecting children.
  • Adult Abuse and Neglect: Abuse affecting vulnerable adults, including physical, emotional, financial, or sexual abuse.
  • Domestic Violence: Protecting individuals, especially women and children, from abusive relationships.
  • Bullying: Addressing bullying in schools, workplaces, and online environments.
  • Cyber security and Online Safety: Safeguarding individuals from online harassment, cyber bullying, and digital exploitation, particularly children.
  • Human Trafficking: Preventing and addressing the trafficking of individuals for forced labour, sexual exploitation, or other purposes.
  • Mental Health Concerns: Supporting individuals experiencing mental health challenges and ensuring access to appropriate care.
  • Substance Abuse: Protecting individuals from the harmful consequences of drug and alcohol misuse.
  • Radicalisation and Extremism: Identifying and preventing radicalisation towards extremist ideologies.
  • Environmental Protection and Food Safety: Ensuring safe and sustainable environments and protecting against foodborne illnesses.
  • Workplace and Elder Safety: Preventing accidents, abuse, or exploitation in workplaces and among elderly individuals.
  • Sexual Harassment and Child Exploitation: Addressing unwelcome sexual behaviour and protecting children from exploitation, including labor or forced marriage.
  • Disability Rights and Gender-Based Violence: Protecting individuals from discrimination, abuse, and harm related to disability or gender.
  • Hate Crimes and Healthcare Ethics: Protecting individuals from prejudice-based crimes and ensuring ethical standards in healthcare.
  • Privacy and Data Protection: Safeguarding personal data in accordance with UK GDPR and the Data Protection Act 2018, ensuring that personal information is collected, processed, and stored lawfully, securely, and in a manner that respects individuals’ rights.

7.2 Definition of an Adult at Risk

Under current safeguarding adult’s legislation Care Act 2014, local authorities, health services, and law enforcement have specific duties to protect adults at risk from abuse or neglect.

An “Adult at Risk” is any person aged 18 or over who may need community care services due to physical or mental health conditions, learning disabilities, age, sensory impairment, or illness, and may be unable to protect themselves from significant harm or exploitation. This definition also includes individuals encountering domestic violence, substance misuse issues, or who are asylum seekers. Responsibilities for safeguarding may transition from children’s services to adult services as individuals turn 18, though vulnerability may continue into adulthood.

7.3 Definition of a Child at Risk

This policy applies to all children and young people up to the age of 18 years, including unborn children, who live permanently or temporarily in the Liverpool area. In this context, the terms “child” or “children” refer to all individuals under the age of 18. The fact that a child has reached 16 years of age, is living independently, is in further education, the armed forces, hospital, or in a custodial setting, does not change their entitlement to safeguarding services or protection under the Children Act 1989 and associated guidance.

8. Safeguarding in a Training Environment

8.1 Referral to Appropriate Authorities

Training providers have a duty to refer safeguarding concerns to the relevant authorities, typically via a Designated Safeguarding Lead (DSL). The DSL ensures that concerns are reported to local safeguarding partners, contributes to the assessment of a child or vulnerable adult’s needs, and coordinates any follow-up action required to support the individual.

8.2 Training Provider Commitments

To ensure children, young people, and vulnerable adults are adequately protected, training providers will appoint Designated Safeguarding Leads (DSLs) that are appropriately trained in safeguarding and child protection; ensure all staff and tutors are aware of safeguarding procedures, understand indicators of abuse, and know how to respond to disclosures or concerns, including DBS checks for all relevant staff; make the safeguarding policy available to learners, parents, and staff on request; review the safeguarding policy at least annually and provide mandatory safeguarding training for all staff and tutors; maintain robust procedures for referrals, monitoring, and continuous improvement; follow safer recruitment practices, including appropriate pre-employment checks, prior to assigning staff or tutors to work with children or vulnerable adults; and ensure compliance with data protection laws, including the UK GDPR and Data Protection Act 2018, when collecting, storing, or sharing personal information relating to safeguarding concerns.

8.3 Complaints

All learners, parents, carers, and staff have the right to raise safeguarding concerns through the training provider’s complaints process. Allegations against staff will be handled in line with statutory procedures and local safeguarding guidance.

9. Roles & Responsibilities

All senior leaders and staff have a duty to safeguard and promote the welfare of children and adults at risk. Safeguarding is everyone’s responsibility, and a child-centred approach is fundamental.

9.1 Designated Safeguarding Lead’s (DSL)

The DSL’s are responsible for the day-to-day oversight of safeguarding and child protection systems. Responsibilities include acting as the central contact point for staff, tutors, and external agencies regarding safeguarding concerns; maintaining confidential safeguarding records in accordance with UK GDPR and local data protection requirements; ensuring staff and tutors receive regular updates on safeguarding and child protection, including changes in legislation or best practice as outlined in KCSIE 2025; liaising with external agencies, including social services, police, and local safeguarding partnerships, in accordance with statutory guidance; overseeing DSL cover arrangements during out-of-hours activities, closures, or holidays; providing guidance and support to staff and tutors regarding safeguarding concerns, including handling referrals and multi-agency coordination; monitoring and reviewing safeguarding procedures, recording standards, and referral processes; and ensuring all staff has access to appropriate training and updates at least annually, including training on online safety and data protection compliance.

The Deputy DSL supports the DSL and assumes delegated responsibilities in their absence, but ultimate accountability remains with the DSL. All DSLs and deputies must undergo formal safeguarding training every two years, with knowledge refreshed regularly at least annually.

9.2 Members of Staff

All members of staff have a responsibility to provide a safe environment in which children, young people, and vulnerable adults can learn; be alert to those who may benefit from early help and understand their role in the early help process; understand the organisation’s safeguarding policy, staff code of conduct, and reporting systems; undertake regular safeguarding training every two years, gain regular safeguarding updates annually, to ensure awareness of current guidance, including KCSIE 2025; know how to make referrals to children’s social care and understand statutory assessment processes under the Children Act 1989; recognise and respond appropriately if a child, young person, or vulnerable adult discloses abuse or neglect, and understand the potential impact of abuse on their well-being; identify and act on indicators that children or vulnerable adults may be experiencing mental health difficulties; maintain appropriate levels of confidentiality while recognising that safeguarding concerns must always take priority; be aware that indicators of abuse and neglect vary and do not automatically mean abuse is occurring; recognise that safeguarding concerns can arise in diverse contexts and vary in nature and severity; and be alert to parent-child interactions or parental behaviours that could indicate risk, such as substance misuse or sudden changes in mental health.

9.3 Children, Young People, and Vulnerable Adults

Children, young people, and vulnerable adults (learners) have a right to feel safe and be listened to, with their wishes and feelings considered; achieve educational success and reach their full potential; receive support and guidance from a trusted adult; and learn how to protect themselves, including online safety.

9.4 Parents and Carers

Parents and carers have a responsibility to understand and adhere to the organisation’s safeguarding policies and procedures; discuss safeguarding issues with their children or vulnerable adults and support the organisation’s safeguarding approaches; and identify behaviours that could indicate potential harm, including online risks, and seek support from relevant agencies.

10. Confidentiality and Information Sharing

  • Staff has a duty to share relevant safeguarding information with appropriate agencies promptly, following KCSIE 2025 guidance and statutory safeguarding frameworks.
  • Staff cannot promise confidentiality if doing so may compromise a learner’s safety or well-being.
  • Information should be shared on a need-to-know basis while respecting consent where possible, but safeguarding always takes priority.
  • Staff should follow clear reporting routes when concerns arise, escalating where appropriate if a concern is not addressed.
  • The Data Protection Act 2018 and UK GDPR do not prevent the lawful sharing of information to safeguard children, young people, and vulnerable adults. Training providers must ensure that personal data is processed securely and lawfully while enabling effective safeguarding interventions.

11. Supporting Staff

Staff may experience stress or anxiety due to safeguarding concerns. Support mechanisms include a comprehensive induction covering safeguarding responsibilities and procedures; access to a staff code of conduct outlining professional standards and safeguarding expectations; supervision and guidance to ensure staff can competently fulfil their safeguarding responsibilities; and ongoing support from the DSL and safeguarding team to address concerns and build confidence in safeguarding practice.

11.1 Safer Practices

  • Safer practice is essential for all staff and tutors working with children, young people, or vulnerable adults.
  • It is the responsibility of everyone to ensure that all interactions are conducted safely and professionally.
  • Implementing safer practices helps prevent unsuitable individuals from working with vulnerable groups and provides a clear framework to address complaints or allegations appropriately.
  • Safer practice protects both learners and staff by minimising risks and ensuring that all staff act in accordance with professional standards.
  • All staff and tutors must adhere to the Code of Conduct and any other professional guidelines set out in this policy, including behaviour management procedures and any necessary physical interventions.
  • Staff and tutors should be aware of the professional risks associated with social media and electronic communications (e.g., email, mobile devices, texting, and social networking).
  • Staff must follow all relevant organisational policies, including Code of Conduct, Acceptable Use, and Social Media Policies.

12. Staff/Tutor Induction & Training

All new staff and tutors, including agency or temporary staff, receive comprehensive Safeguarding and Child Protection training as part of their induction. This ensures that all personnel are equipped to protect children, young people, and vulnerable adults and understand their legal and organisational responsibilities.

Key elements of induction training include awareness of the organisation’s safeguarding and child protection policies; understanding of Part 1 and relevant annexes of KCSIE 2025, including guidance on recognising signs of abuse and neglect; knowledge of key safeguarding issues, including online safety and the responsibilities associated with filtering and monitoring digital platforms; and guidance on data protection and privacy law, ensuring compliance with UK GDPR and the Data Protection Act 2018 when handling personal data of learners, staff, and other stakeholders.

Training completion is recorded in the organisation’s Single Central Record (SCR), and all staff and tutors undertake refresher training at least annually. Regular updates provide staff with the skills and knowledge to safeguard individuals effectively, including procedures for responding to concerns, disclosures, or allegations.

12.1 Support and Whistleblowing

  • Staff and tutors have access to senior safeguarding leads for guidance and advice regarding concerns or allegations involving colleagues.
  • All staff are made aware of the organisation’s Whistleblowing policy. It is a disciplinary offence not to report concerns about conduct that could place a child, young person, or vulnerable adult at risk.
  • Staff can also access the NSPCC whistleblowing helpline if they do not feel able to raise concerns internally (Tel: 0808 800 5000, Email: help@nspcc.org.uk).

13. DBS Referral

The organisation has a legal duty to refer any individual to the Disclosure and Barring Service (DBS) who has harmed or poses a risk of harm to a child or vulnerable adult, or has been removed from, or would have been removed from, work in regulated activity due to safeguarding concerns. Referrals are made promptly following resignation or dismissal, in line with guidance from the Designated Safeguarding Lead (DSL). Failure to make a referral without good reason is a criminal offence.

13.1 Responding to Disclosures, Suspicions, and Allegations

Disclosures of abuse, suspicions, and allegations must always be taken seriously. Actions should be taken immediately if concerns arise.

13.2 Responding to a Disclosure:

The person receiving the disclosure should allow the individual to speak freely and remain calm; reassure them that they are not to blame and that they were right to disclose; take their account seriously, taking into consideration speech, language, or communication differences; avoid investigative questions and limit questions to clarifying understanding; explain that information may need to be shared with relevant agencies to provide support; and make a full and accurate record of the disclosure as soon as possible.

The person receiving the disclosure should not panic or show shock or distaste; probe for additional information or make assumptions; criticise or approach the alleged perpetrator; or promise confidentiality if information may need to be shared.

13.3 Suspension and Investigation

Suspension of a staff member or tutor should be considered when there is reason to suspect a child or vulnerable adult is at risk of significant harm; the allegation requires police investigation; or the allegation is serious enough to potentially warrant dismissal. Disciplinary investigations are conducted following the completion of safeguarding and criminal investigations, ensuring that all procedures comply with KCSIE 2025 and data protection obligations.

14. Code of Conduct

The Code of Conduct sets out the professional standards expected of all staff, tutors, and anyone undertaking duties for the organisation, whether paid or unpaid. This includes permanent, temporary, and agency staff. The Code is designed to protect children, young people, and vulnerable adults from harm or abuse; reduce the risk of unfounded allegations; and ensure staff and tutors understand the expectations regarding their behaviour and the consequences of misconduct.

All staff and tutors are required to read, understand, and agree to adhere to this Code. Children, young people, and vulnerable adults must be treated with respect, dignity, and care, and interactions must always maintain appropriate professional boundaries.

14.1 Professional Boundaries and Conduct

  • Staff and tutors should exercise caution during physical contact with learners, avoiding situations that may be misinterpreted. Any incident requiring physical intervention for safety must be recorded and reported to the Designated Safeguarding Lead (DSL) and, where appropriate, parents or guardians.
  • Staff should avoid being alone with learners where possible. If private meetings are necessary, the door should remain open or another adult should be present nearby, and a record kept of the circumstances.
  • Social contact outside formal tuition should be approached with caution. Staff should not meet students outside official sessions or transport them in their personal vehicles.

15. Online Safety and Communication

  • Do not communicate with students via personal social media accounts or similar platforms.
  • Staff must follow organisational protocols for the safe use of technology and digital communications.
  • Confidential information, including personal data of students and families, must be handled in accordance with UK GDPR and the Data Protection Act 2018. This includes secure storage, limited access, and lawful sharing only with authorised individuals to support safeguarding.

16. Reporting and Whistleblowing

  • All staff and tutors must be familiar with the organisation’s whistleblowing procedures.
  • Any safeguarding concerns, disclosures, or incidents involving colleagues must be reported immediately to the DSL or Deputy DSL.
  • Staff must never promise confidentiality regarding disclosures of abuse or harm.

17. Professional Standards

Staff and tutors are expected to maintain professional dress and conduct; respect boundaries in all interactions, including social contact outside the training setting; avoid giving or receiving gifts from learners, as this could be construed as improper influence; act as positive role models, demonstrating ethical and professional behaviour at all times; and refrain from inappropriate physical contact, conversations of a sexual or abusive nature, or any behaviour that could be misinterpreted.

18. Student/Tutor Relationships

  • Never ask learners personal questions unrelated to learning.
  • Support learners’ questions or concerns regarding behaviour, attitudes, or experiences.
  • Remember that actions may be misinterpreted regardless of intent.
  • Maintain all professional interactions within formal tuition sessions.
  • Ensure disclosures or safeguarding concerns are reported promptly to the DSL.
  • Comply with the Sexual Offences Act 2003, which prohibits sexual relationships between education staff and learners, regardless of the learner’s age.

19. Allegation Outcomes

Definitions for determining the outcome of an allegation:

  • Substantiated: There is sufficient evidence to prove the allegation.
  • Malicious: Evidence disproves the allegation, and there is proof of deliberate intent to deceive or cause harm.
  • False: Sufficient evidence disproves the allegation.
  • Unsubstantiated: Insufficient evidence exists to either prove or disprove the allegation; this does not imply guilt or innocence.
  • Unfounded: There is no evidence or proper basis for the allegation.

19.1 Following a substantiated allegation:

  • If substantiated, the individual may be dismissed, resign, or cease providing services.
  • The organisation will consider referring the matter to the appropriate regulatory body (e.g., Teaching Regulation Agency) where relevant.

19.2 Allegations Against Staff or Tutors

  • Any staff member, including directors, contractors, agency staff, or visitors, may potentially behave in a way that harms, or may harm, a child or vulnerable adult; constitutes a criminal offence against or related to a child or vulnerable adult; or suggests they may pose a risk of harm or are unsuitable to work with children or vulnerable adults.
  • Allegations can be made by children, young people, or concerned adults.
  • All staff and tutors must feel empowered to raise concerns about unsafe practices or potential failures in safeguarding arrangements.
  • All allegations must be reported immediately to the Designated Safeguarding Lead (DSL), who will inform senior management.
  • Based on the DSL’s advice, the staff member or tutor may be suspended or have working arrangements reviewed pending investigation.
  • If the allegation concerns the DSL or Deputy DSL, it must be reported to senior management.

19.3 Use of Force and Restraint

  • Tutors and staff must only use physical intervention as a last resort, when a child, young person, or vulnerable adult is at risk of causing harm to themselves or others. Any intervention must involve the minimal force necessary to prevent injury.
  • If physical action is required to prevent injury, the Designated Safeguarding Lead (DSL) must be informed immediately. The DSL is responsible for notifying the relevant local authority children’s services and/or the parents or carers of the individual involved.
  • Any concerns or allegations regarding inappropriate use of force by staff or tutors must be reported immediately to the DSL.

20. Anti-Bullying

  • The training provider is committed to maintaining an environment free from all forms of bullying.
  • Bullying should be reported promptly to the appropriate line manager and includes, but is not limited to, cyber bullying, racist, homophobic, or gender-based bullying.
  • Tutors should be aware that children and young people with SEND or other differences may be more vulnerable to bullying or other forms of abuse.

21. Online Safety and Use of Digital Technology

  • In line with the provider’s Online Safety Policy and KCSIE 2025, leadership and relevant staff must ensure appropriate monitoring and filtering systems are in place to safeguard learners using IT systems. These systems should limit exposure to online risks while remaining proportionate to the age, number, and needs of learners.
  • Electronic media, including PCs, laptops, tablets, smartphones, webcams, and social networking platforms, create additional safeguarding risks, including grooming and exploitation via chat rooms, discussion forums, and social networks; access to indecent images, which perpetuates abuse; and cyber bullying through text, instant messaging, or social media.
  • Tutors must educate learners on online safety and risks, including references to CEOP (Child Exploitation and Online Protection Centre) resources where appropriate.
  • Staff should also follow guidance on data protection, ensuring personal information is managed in accordance with UK GDPR and the Data Protection Act 2018, maintaining confidentiality while safeguarding individuals.

22. Tuition Setting and Environment

  • Tutors working in external or remote venues may be required to provide photo identification to the hosting establishment.
  • When working one-to-one, ensure sessions occur in a safe environment: the door should be ajar and the session within earshot of other adults; any concerns about the suitability or safety of the environment must be reported immediately to the DSL.
  • The tuition space should be professional and free from distractions: adequate lighting, table, chair, and equipment, with phones, TV, or radio switched off. Smoking is prohibited.
  • Tutors should dress appropriately and respect cultural and religious considerations in their interactions with learners.

23. Whistleblowing

  • The organisation promotes a culture of openness in line with the “Freedom to Speak Up” principles and ensures staff and tutors feel confident raising concerns about the safeguarding of children or vulnerable adults, or any poor practice that may put individuals at risk.
  • All staff and tutors have a responsibility to report concerns about child protection, including concerns regarding the behaviour or decisions of colleagues. In the first instance, concerns should be raised with the individual’s line manager, or if inappropriate, with the Designated Safeguarding Lead (DSL).
  • The organisation recognises that in some circumstances staff or learners may feel unable to raise concerns internally due to doubts about how they will be addressed.
  • All staff and tutors have a legal duty to raise concerns where they believe individuals are failing to safeguard or promote the welfare of children or adults at risk. If internal reporting is not possible, concerns may be raised through external channels, such as the Ofsted whistleblowing line (0300 123 3155) or the NSPCC whistleblowing helpline (0800 028 0285).
  • Whistleblowing procedures are fully aligned with data protection law, ensuring that any personal information involved in the reporting of concerns is processed in compliance with UK GDPR and the Data Protection Act 2018. Reports will be handled confidentially, securely, and only shared with authorised individuals or agencies as necessary for safeguarding purposes.

24. Safer Recruitment

  • Safer recruitment is an essential element of creating a safe environment for children and vulnerable adults. The organisation ensures that all staff and tutors working directly with learners are appropriately vetted and do not pose any risk.
  • Recruitment processes follow guidance from Keeping Children Safe in Education (KCSIE 2025), including all statutory safer recruitment practices.
  • As part of due diligence, online searches may be conducted for shortlisted candidates to identify publicly available information that may require further discussion during interviews. Candidates will be informed of this process.

25. General Principles

  • Leadership is responsible for ensuring safe recruitment processes are consistently applied.
  • All staff and tutors are recruited in accordance with safer recruitment policies and must adhere to data protection, confidentiality, and information security standards.
  • Statutory checks and enquiries are conducted on all applicants and directors before they commence employment.
  • Disclosure and Barring Service (DBS) checks are conducted at the level appropriate for the role, including barred list checks for regulated activity. No individual may start regulated activity until all relevant checks are complete.
  • A Single Central Record (SCR) is maintained to document all recruitment and vetting activities in line with statutory guidance.
  • Staff are required to disclose any factors affecting suitability to work with children or vulnerable adults, including convictions, cautions, court orders, reprimands, or warnings.
  • All staff and tutors must comply with the organisation’s Code of Conduct and attend safeguarding induction training.

26. Pre-Employment Checks

  • Identity verification through passport or photographic ID, plus proof of address.
  • Right to work in the UK must be evidenced through original documentation.
  • Enhanced DBS checks for regulated activity, including barred list checks, must be completed prior to starting work.
  • Verification of academic and vocational qualifications for teaching staff.
  • Assessment of physical and mental health to ensure capacity to fulfil role responsibilities.
  • Copies of key documents (proof of identity, DBS summary, right-to-work evidence) are securely retained; other sensitive DBS documentation is destroyed in compliance with data protection requirements.

26.1 References

  • Applicants must provide a complete employment history and at least two professional referees, preferably previous or current employers. References from colleagues are not accepted.
  • All references are obtained directly from the referees prior to interview. Information provided by applicants is independently verified. Electronic references are validated to confirm authenticity.

26.2 DBS Checks

To ensure that individuals working with children, young people, and vulnerable adults are suitable and not barred from such work, the organisation will apply to the Disclosure and Barring Service (DBS) for relevant police checks and barred list information as part of the recruitment process.

Enhanced DBS checks with barred list information will be required for staff or tutors engaged in regulated activity, defined as close, unsupervised contact on a regular basis involving teaching, training, supervising, or providing information, guidance, or advice. These activities must be part of the staff member’s regular responsibilities. DBS checks are a critical measure to safeguard children and adults at risk. All staff or tutors who have regular contact with children or vulnerable adults will undergo full DBS checks.

All DBS disclosures must either be registered on the DBS Update Service or renewed every three years. For staff on the Update Service, an annual update check will be completed. Any change revealed by an update check will require a new enhanced DBS disclosure.

27. Policy Compliance, Monitoring, and Evaluation

The organisation will review this safeguarding policy at least annually, or sooner in response to updates to national or local safeguarding policies, local child protection concerns, or changes to internal procedures. All staff, including tutors and temporary staff, will receive a copy of this policy and Part One of KCSIE 2025.

28. Record Keeping and Data Protection

All safeguarding concerns, discussions, decisions, and their rationale must be recorded in writing and shared immediately with the Designated Safeguarding Lead (DSL). Records should be completed promptly, using the child or adult’s words where possible, and signed and dated by the staff member. Urgent concerns must be reported before completing formal records.

Safeguarding records are maintained separately from other records in a secure, dedicated safeguarding folder; accessed only by the DSL/DDSL or staff on a strict “need-to-know” basis; and managed in accordance with UK GDPR and the Data Protection Act 2018, ensuring lawful, secure, and confidential storage. All staff receive training on data protection requirements in safeguarding, including lawful sharing of information with relevant agencies while maintaining confidentiality.

29. Multi-Agency Working

The organisation recognises its statutory duty to work within local multi-agency safeguarding arrangements. The leadership team and DSL will collaborate with local authorities, social services, and other agencies to provide a coordinated response that promotes the welfare and protection of children and adults at risk. Participation may include Child Protection Conferences, Child in Need meetings, and other relevant multi-agency safeguarding forums.

30. Safeguarding Children with Special Educational Needs and Disabilities (SEND)

Children with SEND may face additional safeguarding risks due to difficulties resisting or communicating abuse. Staff and tutors are expected to recognise that changes in behaviour, mood, or physical injuries may indicate abuse, not assume they are solely related to disability; and work closely with other agencies, including SENDCos, to plan appropriate support. Additional guidance can be found from specialist organisations such as SENDIASS – local information and support services for children with SEND, and Mencap – advice for working with people with learning disabilities.

30.1 Safeguarding Vulnerable Groups

Some learners may be more vulnerable due to personal circumstances and may require intervention from Early Help Services, Social Services, or other agencies. This includes children who are Lesbian, Gay, Bisexual, or Transgender (LGBT) – recognising the need for safe spaces and addressing homophobic, biphobic, or transphobic bullying; and children experiencing neglect, abuse, or poor outcomes due to family or social circumstances. Staff should provide support, listen, and record concerns in line with safeguarding and data protection policies.

40. Premises and Information Security

All staff are responsible for maintaining premises security and reporting any concerns that may threaten safety. The organisation ensures cyber security and information management meet statutory requirements, safeguarding systems, staff, and learners from digital threats. All digital records, including safeguarding records, comply with UK GDPR and relevant data protection legislation. Regular reviews of security procedures are undertaken to maintain compliance and protect personal information.

Appendix 1 – Recognising Signs of Abuse and Neglect

All staff are made aware of the definitions and indicators of abuse and neglect as outlined in Working Together to Safeguard Children (2018) and Keeping Children Safe in Education (KCSIE) 2025.

Datalaw recognises four categories of abuse when assessing whether a child may be suffering, or is likely to suffer, significant harm: Physical Abuse, Emotional Abuse (including Domestic Abuse), Sexual Abuse, and Neglect. If staff are unsure about any safeguarding concern, they must always consult the Designated Safeguarding Lead (DSL) or a Deputy DSL.

Appendix 1.1 – Abuse and Neglect

All staff should be aware of the indicators of abuse and neglect to enable them to identify children or young people who may require help or protection. Safeguarding issues are rarely isolated incidents and often involve overlapping concerns. Staff should also be aware that safeguarding risks may arise from factors outside the learning environment, including peer-on-peer incidents occurring in the community or online. The DSL and deputies must consider whether children are at risk of abuse or exploitation in extra-familial contexts, including (but not limited to) Child Sexual Exploitation (CSE), Child Criminal Exploitation (CCE), and serious youth violence.

Appendix 1.2 – Definitions

Abuse

Abuse is a form of maltreatment. A child may be harmed through action (infliction of harm) or inaction (failure to act). Harm can include physical harm, emotional ill-treatment, or witnessing the mistreatment of others. Abuse may occur within families; in institutional or community settings; online or facilitated by technology; and perpetrated by adults or other children.

Neglect

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to cause serious impairment to health or development. Examples include failing to provide adequate food, clothing, or shelter; protection from harm or danger; appropriate supervision or childcare; access to medical care or treatment; and emotional responsiveness.

Appendix 1.3 – General Signs of Abuse in Children

The following non-specific indicators may suggest abuse or neglect: significant or unexplained changes in behaviour; fearfulness around parents or carers; extreme anger, sadness, or withdrawal; aggression or attention-seeking behaviour; unexplained or suspicious bruises; low self-esteem or self-injury; and depression.

Appendix 1.4 – Risk Indicators

These factors are commonly associated with child abuse. Their presence does not confirm abuse but should be treated as indicators requiring assessment and discussion with the DSL: indicators of possible significant harm; behaviour inappropriate to age or development; cultural and developmental variations should be considered.

Appendix 1.5 – Recognising Categories of Abuse

Physical Abuse

Physical abuse may involve hitting, shaking, burning, poisoning, drowning, suffocating, or otherwise causing physical harm. It also includes fabricated or induced illness and behaviour online that facilitates or encourages physical abuse. Possible indicators: bruising or abrasions, especially to the face; injuries around the mouth; bilateral injuries (e.g., two black eyes); finger-tip bruising on torso; bite marks; burns or scalds with unusual patterns; cigarette burns; marks indicating beating (straps, welts); covering arms/legs in hot weather; aggression, severe temper, or fearfulness; delayed or implausible explanations for injuries.

Emotional Abuse

Emotional abuse often presents through behavioural indicators. It includes persistent emotional maltreatment that adversely affects emotional development. Examples include silencing or mocking a child; age-inappropriate expectations; limiting learning or social exploration; witnessing the ill-treatment of others; serious bullying (including cyber bullying); and exploitation or corruption of children. Possible indicators: overreaction to mistakes; low confidence or self-esteem; sudden speech problems; self-harm; eating disorders; extreme passivity or aggression; compulsive stealing; substance misuse; fear of parents being contacted; difficulty playing or interacting socially; excessive need for approval or attention.

Sexual Abuse

Sexual abuse involves forcing or enticing a child to participate in sexual activities, whether contact or non-contact. It may occur online or in person and may be perpetrated by adults or other children. Possible indicators: sudden behavioural or performance changes; sexualised behaviour or affection inappropriate to age; self-harm or suicidal behaviour; references to secrets they cannot share; clinginess or need for reassurance; regression (e.g., thumb sucking); distrust of familiar adults; unexplained money or gifts; withdrawal or depression; reluctance to change for PE; STIs; fire-setting behaviour.

Neglect

Neglect is the ongoing failure to meet essential needs. Possible indicators: constant hunger; poor hygiene; tiredness or lethargy; inadequate or unsuitable clothing; frequent lateness or absence; untreated medical issues; poor peer relationships; stealing or scavenging; developmental delays (e.g., rocking, thumb sucking); running away; underweight or weight loss; low self-esteem.

Appendix 2 – Types of Abuse

Members of staff and tutors must remain vigilant for the following safeguarding concerns. Any concerns must be reported immediately to the Designated Safeguarding Lead (DSL) in accordance with referral procedures.

A2.1 Mental Health

Mental health difficulties can, in some cases, indicate that a child has suffered, or is at risk of suffering, abuse, neglect, or exploitation. Only appropriately trained professionals should diagnose mental health conditions; however, staff are well placed to notice day-to-day behaviours that may signal emerging concerns. Children, young people and vulnerable adults who have experienced abuse, neglect or other adverse childhood experiences often face lasting mental health impacts. Staff must understand how these experiences can affect behaviour, learning and wellbeing. Where mental health concerns indicate a safeguarding risk, staff must report this to the DSL immediately.

Key commitments: all staff are encouraged to complete Mental Health Awareness training within their first six months; in line with KCSIE 2025, all staff receives regular CPD on recognising signs of mental health issues (e.g. depression, anxiety, self-harm); mental health concerns must be referred to the DSL, who will liaise with external agencies as appropriate; the DSL is the organisation’s Mental Health Lead, ensuring coordinated support, oversight of mental-health related referrals, and staff access to updated resources; and student support plans are created when needed, in collaboration with parents/guardians and mental health professionals.

A2.2 Child Criminal Exploitation (CCE)

CCE occurs when an individual or group exploits an imbalance of power to coerce, manipulate or deceive a child into criminal activity. This may involve violence, threats, or exchanges for goods, money or status. It can also occur online. Examples include being forced to work in cannabis factories; moving drugs or money across the country (county lines); and shoplifting, pickpocketing, or threatening others. Indicators may include unexplained gifts or possessions; association with individuals involved in exploitation; emotional changes, drug/alcohol misuse; missing episodes or regular lateness; and non-engagement in education. All suspected CCE cases must be reported to the DSL for referral.

A2.3 Child Sexual Exploitation (CSE)

CSE is sexual abuse in which a child is exploited for money, power or status. Children may be groomed online, given alcohol/drugs, or manipulated into believing they are in a consensual relationship. Indicators include missing episodes or lateness; unexplained gifts; association with older individuals; STIs, emotional changes, substance misuse; and inappropriate sexualised behaviour. Legal context: children under 13 cannot consent to sexual activity; sexual activity with a child under 16 is an offence; a position of trust makes sexual activity with a 16–17-year-old illegal. All potential CSE cases must be escalated to the DSL immediately.

A2.4 Sexting / Youth-Produced Sexual Imagery

Creating, possessing, or sharing sexual images of anyone under 18 is illegal. This includes:

  • A child creating and sharing an image of themselves.
  • Sharing images with peers or adults.
  • Possession of images created by another child.

Any such incident must be reported to the DSL. Further guidance is available via UKCCIS: Sexting in Schools and Colleges.

A2.5 Serious Violence / Gangs

Staff must recognise indicators that a child may be at risk from serious violence or gang involvement. Indicators include increased absence; older or concerning peer groups; decline in performance; self-harm or emotional changes; and unexplained injuries or possessions. Weapons are often carried for perceived self-protection. Concerns must be shared with the DSL.

A2.6 County Lines

County lines involves criminal exploitation in which children are groomed to move drugs or money between locations. Key indicators: missing episodes (potential trafficking); violence or threats; association with older individuals; and power imbalance dynamics (age, gender, cognitive ability, status). All concerns must be referred to the DSL.

A2.7 Peer-on-Peer Abuse (including Upskirting)

Peer-on-peer abuse can include bullying (including cyber bullying); physical, emotional or sexual abuse; initiation/hazing activities; coercion and blackmail; sexual harassment or violence; and upskirting (a criminal offence). This behaviour is never to be normalised as “banter” or “part of growing up”. Learners must feel able to report concerns safely. All incidents are referred to the DSL, with risk assessments and support plans implemented as required.

A2.8 Child-on-Child Sexual Violence and Sexual Harassment

This can occur between any children, online or offline, and may involve groups. Key principles: zero tolerance—such behaviour is never acceptable; staff must adopt the attitude of “it could happen here”; and physical behaviours such as inappropriate touching must be challenged. Victims often experience significant distress affecting their education. Staff must report concerns to the DSL without delay. External agencies (e.g. Police, MASH) may be involved.

A2.9 Domestic Abuse

Domestic abuse involves controlling, coercive, threatening or violent behaviour between individuals aged 16 or over. Children witnessing domestic abuse suffer significant long-term harm. Concerns must be reported to the DSL immediately. The organisation recognises Operation Encompass, which supports children exposed to domestic abuse.

A2.10 Violence Against Women and Girls (VAWG)

VAWG includes a range of gender-based violence such as domestic abuse; forced marriage; FGM; sexual violence and exploitation; and stalking, harassment, trafficking. Any concerns must be reported to the DSL for referral.

A2.11 Honour-Based Abuse (HBA)

HBA includes crimes committed to protect perceived family or community “honour”, such as forced marriage; FGM; and breast ironing. HBA often involves multiple perpetrators and extended family networks. All concerns must be escalated to the DSL.

A2.12 Female Genital Mutilation (FGM)

FGM is illegal in the UK and a form of child abuse and violence against women and girls. Staff must understand that FGM has severe immediate and long-term health consequences; it is prevalent in various regions globally; and teachers have a legal duty to report known cases (where FGM is disclosed or visually confirmed) in girls under 18 directly to the police. Staff must still inform the DSL unless there is a compelling reason not to.

A2.13 Forced Marriage

Since February 2023, any conduct intended to cause a child to marry before age 18 is a criminal offence, regardless of coercion. Forced marriage occurs without free and full consent and may involve emotional, psychological or physical pressure. Concerns must be shared with the DSL immediately.

A2.14 Care Act 2014

Local authorities must assess anyone who appears to need care and support, focusing on wellbeing and desired outcomes. Staff should be aware of these duties when supporting vulnerable adults.

A2.15 Child Trafficking and Modern Slavery

Child trafficking is child abuse. Children may be trafficked into or within the UK for exploitation. Staff should refer to NSPCC guidance and report any concerns to the DSL.

A2.16 Children Absent from Education

Prolonged or repeated absence can indicate neglect; CCE or CSE; or county lines involvement. Persistent absence also increases risks for children with social workers. Strategy objectives include Prevention – reduce repeat missing episodes; Protection – respond quickly and collaboratively; and Provision – ensure support and access to help.

A2.17 Filtering and Monitoring Online Activity

Staff responsibilities include reporting concerns about students’ online activity; reporting if inappropriate material is accessible; not assuming filtering/monitoring will detect everything; notifying DSL/IT team when lessons may trigger unusual monitoring alerts; and reporting system failures or bypass attempts. The DSL holds overall responsibility for filtering and monitoring processes.

A2.18 Preventing Radicalisation – The PREVENT Duty

Under the Counter-Terrorism and Security Act 2015, staff must have due regard to preventing individuals from being drawn into terrorism. Radicalisation indicators may include associating with extremist groups; possession of extremist symbols; changes in behaviour, appearance or associations; and justifying violence or expressing extremist views. The full prevent policy covers all forms of extremism, including far-right, religious, political or ideological extremism. Enhancements in line with KCSIE 2025: (1) regular staff training and updated Prevent procedures; (2) enhanced online safety monitoring; (3) curriculum embedding British Values and critical-thinking skills. Full details are in the Prevent Policy.

A2.19 Channel

Channel is a voluntary, confidential programme offering support to individuals vulnerable to radicalisation. The organisation will refer concerns to the MASH; work with Prevent officers; and support multi-agency information-sharing and decision-making.

Appendix 3 – Safeguarding & Child Protection Procedures

A3.0 Introduction

You may have a concern about a child, young person, or vulnerable adult’s well-being based on something they have told you; something you have noticed about their behaviour, health, or appearance; something another professional or adult (e.g., parent or carer) has said or done; or something written or drawn as part of the student’s work. Even if you think your concern is minor, the Designated Safeguarding Lead (DSL) or local authority may have additional information that, when combined with yours, suggests a more serious risk. It is never your decision alone how to respond to concerns – but it is always your responsibility to share concerns, no matter how small.

A3.1 What You Must Do When You Suspect a Child May Be at Risk

1. Inform the Child, Young Person, or Vulnerable Adult. If they have disclosed abuse or you are discussing concerns: do not promise to keep the information secret; calmly explain what you will do next; and inform the DSL immediately.

2. Make a Written Record as Soon as Possible. Refer to Datalaw reporting procedures and include the name of the child / young person / vulnerable adult; date, time, and place of the incident or disclosure; who else was present; what was said, what happened, or what you noticed (include speech, behaviour, mood, drawings, games, or appearance); if the child spoke, record their exact words, not your interpretation; analysis of what you observed and why it is a cause for concern. Keep the record factual—do not include personal opinion. Send the report immediately to the DSL or DDSL. Contact the DSL or DDSL if you are uncertain about any part of the process. You must not discuss or share the information with anyone else.

A3.2 What Will the DSL Do?

The DSL shares information with relevant professionals, including local authority children’s services and/or the DSO (formerly LADO). All actions and decisions must be recorded. The DSL must create a Protection Log for each case and store it securely, separate from other records; provide authorities with any reports or records submitted by staff; work collaboratively with professionals involved to keep the individual safe; attend conferences when invited and provide updated information; inform staff when their attendance is required at a conference; attend all review conferences; ensure the Managing Director is briefed throughout the investigation; and share information only with Senior Managers who have a clear need to know, respecting confidentiality.

A3.3 Disclosure

All staff and tutors must follow these principles when a disclosure is made by or about a child, young person, or vulnerable adult: never guarantee absolute confidentiality—Child Protection overrides all other issues; listen rather than question directly; offer reassurance without making promises; allow the individual to speak without interruption; accept what is said—do not investigate or ask probing questions; stay calm, regardless of the content of the disclosure; avoid judgement and alleviate feelings of guilt or isolation; explain what you must do next and who you must tell; record the discussion accurately as soon as possible, using their exact words; and contact the DSL for advice and guidance.

A3.4 Key Legislation & Guidance

Practitioners may find the following resources useful: Working Together to Safeguard Children (2018); Keeping Children Safe in Education (2025); Safeguarding Vulnerable Groups Act (2006); Children Act 1989; Children Act 2004; Every Child Matters (2004); The Childcare Act (2006); The Counter-Terrorism and Security Act (2015); The Children and Social Care Act (2017); Education Act (2011).

A3.5 Useful Websites

Appendix 4 – Designated Safeguarding Lead (DSL) & Mental Health Lead

A4.1 Duties of the Designated Safeguarding Lead & Mental Health Lead

Safeguarding Responsibilities: drawing up and enforcing the company’s safeguarding policy; being alert to and recognising welfare issues, and challenging poor practice; sharing appropriate information with relevant people; gathering all relevant information and evidence; consulting Local Safeguarding Children Board (LSCB) procedures for additional information or guidance when necessary; making referrals to social services when appropriate; continuing to work with families, sharing information and contributing to plans if concerns are investigated; ensuring that all staff having contact with children or vulnerable adults have received appropriate safeguarding training; acting as the first point of contact for staff reporting safeguarding concerns; undertaking safeguarding training every 2 years and maintaining ready access to relevant resources; ensuring that an effective Child Protection Policy and Staff Code of Conduct are in place, distributed to staff, and available to the public; acting as a source of support, advice, and expertise for staff; keeping detailed, accurate, and secure written records of all concerns and referrals; working closely with the local authority and other relevant agencies; and deciding whether to make a referral to children’s social care when a concern is reported.

Mental Health Lead Responsibilities:

  • Promote Mental Health Awareness: Raise awareness of mental health issues and encourage a supportive, open culture.
  • Early Identification: Identify students who may be experiencing mental health difficulties through staff feedback, observation, or appropriate tools.
  • Training and Support: Ensure staff receive training to recognise mental health concerns and respond appropriately.
  • Referral Processes: Manage internal and external referral processes for students requiring additional mental health support.
  • Policy Development: Support the development and implementation of mental health policies in line with KCSIE and the wider safeguarding framework.
  • Support Plan Coordination: Oversee or contribute to individual mental health support plans (where applicable).
  • Monitoring and Evaluation: Review and evaluate the effectiveness of mental health interventions, adjusting practice as required.
  • Parental and Community Engagement: Work with parents, carers, and community partners to provide relevant information and support.
  • Record Keeping: Maintain secure, confidential, accurate records of mental health concerns and interventions in line with data protection regulations.

It is essential that the Designated Safeguarding Lead is provided with the time, training, funding, resources, and organisational support necessary to fulfil these responsibilities effectively.

A4.2 DSL Procedure

Initial Response: take any allegation or concern seriously; conduct an initial fact-finding investigation through interviews and/or written statements; and ensure all information is recorded accurately.

Recording Requirements: securely record and file all allegations, including date and time; person the allegation is against; victim; location; information source; and actions taken (with date, time, and responsible individual).

Assessment and Escalation: assess whether escalation to the Local Authority Designated Officer (LADO/DSO) is required. If no escalation is made, record the reason for the decision, recommendations, and close/review date, time, and responsible officer.

If Escalation to DSO is Required: contact the Local Authority to obtain DSO details; email details of the concern to the DSO, including date/time, person against whom the allegation is made, victim, location, and information source; await further instruction from the DSO; follow up on any actions requested; hand over the case to the DSO (record date, time, and DSO details); and close the case and securely file all communications.

Immediate Risk: If the alleged victim is in immediate danger, call 999 immediately.

Designated Safeguarding Leads at Datalaw are: Sharon Parsons; Sarah Parker; Catherine Heys; Gemma Garbutt; Sean Brogan. Email: safeguarding@datalaw.org. Tel: 0151 236 2024.

Reviewed Date

3rd December 2025

Next Review Due Date

3rd December 2026

Reviewed by

Sarah Parker

Signature

 Sarah Parker

Datalaw 2025    Safeguarding Policy    DPP063