RISE E-Safety Policy

The e-safety policy aims to create an environment where young people, staff, parents, governors and the wider school community work together to keep each other safe and inform each other of ways to use the Internet responsibly, safely and positively. Teaching Digital Employability, PSHE and Life and Life skills we equip young people to participate in a rapidly changing digital world where work and leisure activities, social interactions, self-care, independent living are increasingly dependent on technology. By enable young people to find, explore, analyse, exchange and present information in a functional way and safe manner they become more independent and capable digital citizens. The e-safety policy encourages appropriate and safe conduct and behaviour when achieving this.  Pupils, staff, and all other users of ALTR technologies will agree standards and expectations relating to usage to promote and ensure safe, positive behaviour and prepare them for experiences and expectations in the workplace. The policy is intended to explore areas to discuss, teach and inform, to develop positive ICT use and knowledge. RISE expects that the positive effects of the policy will be seen online and offline; in school and at home; and ultimately beyond school and into the workplace.  
This Policy will be monitored by Provision Lead and Board Members and reviewed biannually due to vast changes with technological advances.Any serious incidents that are reported will refer to the Safeguarding and Child Protection Policies.RISE will monitor the impact of this policy and safety of ICT by:Surveys and questionnaires of young people, parents, carers, staff.Logging incidents of misuse.Monitoring internet activity
The Link School E-safety Policy Scope The school e-safety Policy and agreements apply to all young people, staff, support staff, supply staff, external contractors, agencies and members of the wider provision community who use, have access to or maintain school and school related Internet, computer systems and mobile technologies internally and externally. RISE make reasonable use of relevant legislation and guidelines to affect positive behaviour and understanding regarding ICT and Internet usage at school and at home. ‘In Loco Parentis’ provision under the Children Act 1989 also allows RISE to report and act on:instances of cyber bullying, abuse, harassment (including sexual harassment), malicious communication and grossly offensive material reporting to the police, social media websites, and hosting providers on behalf of pupils.  The Education and Inspections Act 2006 empowers Head teachers when reasonable, to regulate the behaviour of students when they are off the Academy site and empowers members of staff to impose disciplinary penalties for inappropriate behaviour. This is applicable to incidents of cyber-bullying or other E-safety incidents covered by this policy, which may take place away from the RISE provision, but is linked by membership of RISE the ALTR Group.  The 2011 Education Act increased these powers with regard to the searching for and of electronic devices and the deletion of data. In the case of both acts, action can only be taken over issues covered by the published Behaviour Policy. The e-safety policy covers the use of: Provision based ICT systems and equipmentProvision based intranet and networking Provision related external Internet, including but not exclusively, extranet, e-learning platforms, blogs, social media websites. External access to internal school networking, such as webmail, network access, file-serving (document folders) and printing. School ICT equipment off-site, for example staff laptops, digital cameras, mobile phones, tablets Pupil and staff personal ICT equipment when used in school and which makes use of school networking, file-serving, or Internet facilities.  Tablets, mobile phones, devices, and laptops when used on the school site.  
Managing Information Systems It is important to review the security of the whole system from user to Internet. This significant responsibility includes not only the delivery of essential learning services but also the personal safety of staff and learners.Local Area Network (LAN) security issues include: Users must act reasonably — e.g. Downloading large files outside of the working day so not to affect the service that others receive. Users must take responsibility for their network use. For Link School staff, flouting electronic use policy is regarded as a reason for dismissal.Workstations should be secured against user mistakes and deliberate actions. Servers must be located securely and physical access restricted. The server operating system must be secured and kept up to date; through regular monthly patching Virus protection for the whole network must be installed and current. Access by wireless devices must be proactively managed and secured with WPA2 PSK (pre-shared key).  Guest Wi-Fi will use Meraki radius. Wide Area Network (WAN) security issues include: Link School broadband firewalls are configured to prevent unauthorised access. Decisions on WAN security are made on a partnership between partner organisations. The Link provision broadband network is protected by a cluster of high-performance firewalls at the Internet connecting nodes. The security of the provision information systems and users will be reviewed regularly.Virus protection will be updated regularly. Personal data sent over the Internet or taken off site will be password protected.Portable media may not be used unless it has been encrypted and virus checked.Unapproved software will not be allowed in work areas or attached to email. Files held on the network will be regularly checked. System capacity in relation to storage will be checked regularly. The use of user logins and passwords to access the network will be enforced.   
Filter Management. The school’s broadband access provides filtering appropriate to the age and maturity of learners. There is flexibility in the filtering system to allow for changes in provision depending on the learning required. A description of the filtering service should be shared with the school (Infrastructure).  Smooth wall works via Standard Browsing Categories and has a default policy set by Smooth wall.  Any breaches in filtering should be reported to the Provision Lead/or emailed to the Board Member. If staff or learners discover unsuitable sites, the URL will be reported to the Data and assessment manager who will then record the incident and escalate the concern as appropriate. The School filtering system will block all sites on the Internet Watch Foundation (IWF) list. Changes to the school filtering policy will be risk assessed by staff with educational and technical experience prior to any changes and where appropriate with consent from the Leadership team.The Leadership Team will ensure that regular checks are made to ensure that the filtering methods selected are effective. Any material that the school believes is illegal will be reported to appropriate agencies. The academy’s access strategy will be designed by educators to suit the age and curriculum requirements of the learners, with advice from network managers.  
Monitoring the e-safety policy:  The e-safety policy will be actively monitored and evaluated by the Board Members and Provision Lead. E-safety Coordinator/Officer (Keighly Murphy), Safeguarding Lead (Keighly Murphy), Board Members to be confirmed.
E-safety policy review and evaluation schedule: The e-safety policy and Acceptable Use Policy are reviewed at or prior to the start of each academic year. Additionally, the policy will be reviewed promptly upon: Serious and/or frequent breaches of the acceptable Internet use policy or other in the light of e-safety incidents. New guidance by government / LA / safeguarding authorities.  Significant changes in technology as used by the provision or pupils in the wider community. E-safety incidents in the community or local schools which might impact on the provision    community.  Advice from the Police and/or the Bedfordshire Safeguarding Partnership.  The e-safety policy review will be documented in the provision development plan and school    self-evaluation and improvement profiling.  The Board Members will receive a report on the progress, evaluation, impact, and this report will include suitably redacted accounts and statistics of e-safety incidents and how these   have been resolved, and counter measures implemented.  In line with OFSTED recommendations, it is also useful to consult with pupils over the policy    and to ask for their opinion on keeping themselves self when using the Internet. 
School Management and e-safety School senior leadership team is responsible for determining, evaluating, and reviewing e-safety policies to encompass teaching and learning, use of school IT equipment and facilities by pupils, staff, and visitors. In addition, the agreed criteria for acceptable use by pupils, school staff and governors of Internet capable equipment for school related purposes or in situations which will impact on the reputation of the school, and/or on school premises. The e-safety policy is a continuous cycle of evaluation and review based on new initiatives, and partnership discussion with stakeholders and outside organisations; technological and Internet developments, current government guidance and provision related e-safety incidents. The policy development cycle develops good practice within the teaching curriculum and wider pastoral curriculum. Regular assessment of strengths and weaknesses help determine training provision for staff and governors and guidance provided to parents, pupils, and local partnerships.  e-safety provision is always designed to encourage positive behaviours and practical real-world strategies for all members of the provision and wider community. The leadership team is encouraged to be aspirational and innovative in developing strategies    for e-safety provision.  
The school e-safety Coordinator: 
The school has a designated e-safety Coordinator [Keighly Murphy] who reports to the Director (Lianne Murphy) and Governors and coordinates e-safety provision across the school and wider provision community. The committee liaises with SLT, the schools designated safeguarding officer and other senior managers as required.   The school’s e-safety coordinator chairs the school e-safety committee which includes representatives of the Leadership team, teaching and support staff and governors. The e-safety committee meets regularly.  The e-safety coordinator is responsible for e-safety issues on a day to day basis and liaises with LA contacts, filtering and website providers and school ICT support.  The school e-safety coordinator maintains a log of submitted e-safety reports and incidents on MyConcern.  The e-safety coordinator audits and assesses inset requirements for staff, support staff and Governor e-safety training, and ensures that all staff are aware of their responsibilities and the provision’s e-safety procedures. The coordinator is also the first port of call for staff requiring advice on e-safety matters.  Although all staff are responsible for upholding the school e-safety policy and safer Internet practice, the e-safety Coordinator, the Director, Board members and ICT support are responsible for monitoring Internet usage by pupils and staff, and on school machines, such as laptops, used off-site.  The e-safety Coordinator is responsible for promoting best practice in e-safety within the wider community, including providing and being a source of information for parents and partner stakeholders.  The provision e-safety coordinator (along with IT support) should be involved in any risk assessment of new technologies, services, or software to analyse any potential risks   
Governors’ responsibility for e-safety:  One Governor has responsible for e-safety, and the school e-safety Coordinator will liaise directly with the Governor and report on e-safety effectiveness, incidents, monitoring, evaluation and developing and maintaining links with local stakeholders and the wider provision community. The e-safety coordinator will be responsible for auditing Governor e-safety training and inset requirements.   
ICT support staff and external contractors:  External ICT support staff and technicians are responsible for maintaining the provisions networking, IT infrastructure and hardware. They are aware of current thinking and trends in IT security and ensure that the RISE system, particularly file-sharing and access to the Internet is secure. They further ensure that all reasonable steps have been taken to ensure that systems are not open to abuse or unauthorised external access, with regard to external logins and wireless networking.  Support staff maintain and enforce the provision’s password policy. External contractors, such as VLE providers, website designers/hosts/maintenance contractors are made fully aware of and agree to the ’s e-safety Policy. Where contractors have access to sensitive school information and material covered by the Data Protection Act, for example on a VLE, school website or email provision, the contractor should also be Enhanced DBS checked. 

Teaching and teaching support staff: Teaching and teaching support staff need to ensure that they are aware of the current e-safety policy, practices, and associated procedures for reporting e-safety incidents.  Teaching and teaching support staff will be provided with e-safety induction as part of the overall staff induction procedures.  All staff need to ensure that they have read, understood, and signed (thereby indicating an agreement) the Acceptable Use Agreement relevant to Internet and computer use in school.  All staff need to follow the provision’s social media policy, in regard to external off site use, personal use (mindful of not bringing ALTR/ RISE into disrepute), possible contractual obligations, and conduct on Internet messaging or communication platforms, for example email, VLE messages and forums and the website.  All teaching staff need to rigorously monitor pupil Internet and computer usage in line with the policy. This also includes the use of personal technology such as cameras, phones, and other gadgets on site.  Teaching staff should promote best practice regarding avoiding copyright infringement and plagiarism.  Be aware of online propaganda and help pupils with critical evaluation of online materials. Internet usage and suggested websites should be pre-vetted and documented in lesson planning.  In lessons where internet use is pre-planned students should be guided to sites checked as suitable for their use and that processes are in place for dealing with any unsuitable material that is found in internet searchesS
taff Use of Personal Devices 
Staff are not permitted to use their own personal phones or devices for contacting children, young people, and their families within or outside of the setting in a professional capacity. Staff will be issued with a provision phone where contact with learners or parents/carers is required. Mobile Phone and devices will be switched off or switched to ‘silent’ mode, Bluetooth communication should be “hidden” or switched off and mobile phones or devices will not be used during teaching periods unless permission has been given by a member of Senior Leadership Team in emergency circumstances. If members of staff have an educational reason to allow children to use mobile phones or personal device as part of an educational activity, they must ensure that they are used appropriately. Staff should not use personal devices such as mobile phones or cameras to take photos or videos of learners and will only use work-provided equipment for this purpose. If a member of staff breaches the academy policy, then disciplinary action may be taken. 
Designated Safeguarding Officer: The Designated Safeguarding Officer is trained in specific e-safety issues. Accredited training with reference to child protection issues has been accessed.  The Designated Safeguarding Officer can differentiate which e-safety incidents are required to be:reported to CEOP, local Police, LADO, Local Safeguarding Children’s Board, social services, and parents/guardians; and determine whether the information from such an incident should be restricted to nominated members of the leadership team.  Possible scenarios might include:Allegations against members of staff. Computer crime – for example hacking of RISE systems. SextingAllegations or evidence of ‘grooming’. Allegations or evidence of cyber bullying in the form of threats of violence, harassment, or a malicious communication.  Producing and sharing of Youth Produced Sexual Imagery (YPSI) Acting ‘in loco parentis’ and liaising with websites and social media platforms such as Twitter, Instagram, Snapchat, and Facebook to remove instances of illegal material or cyber bullying.  sharing of personal data  access to illegal / inappropriate materials inappropriate on-line contact with adults / strangers
Learners: Are required to use RISE Internet and computer systems in agreement with the terms specified in the provision’s Acceptable Use Policies. Pupils are expected to sign the policy to indicate agreement, and/or have their parents/guardians sign on their behalf.  Pupils need to be aware of how to report e-safety incidents at RISE, and how to use external reporting facilities, such as the Click CEOP button or Childline number. Reporting concerns on my concern.Pupils need to be aware that Acceptable Use Policies cover all computer, Internet, and mobile technology usage in school, including the use of personal items such as phones. Pupils need to be aware that their Internet use out of provision on social networking sites such as Instagram is covered under the Acceptable Use Policy if it impacts on the school and/or its staff and pupils in terms of cyber bullying, reputation, or illegal activities.   
Learners Use of Personal Devices Mobile phones will be handed in at registration, they will be placed in an individual names wallet and stored securely until they are returned at breaks/lunch times. Mobile phones will not be taken on outdoor activities. Phones and devices must not be taken into examinations. Learners found in possession of a mobile phone during an exam will be reported to the appropriate examining body. This may result in the student’s withdrawal from either that examination or all examinations. If a learner needs to contact his/her parents/carers they will be allowed to use a RISE phone. Parents/Carers are advised not to contact their child via their mobile phone during the learning day, but to contact the office. Children and young people should protect their phone numbers by only giving them to trusted friends and family members. Learners will be instructed in safe and appropriate use of mobile phones and personal devices and will be made aware of boundaries and consequences. 
 Parents and Guardians: It is hoped that parents and guardians will support the school’s stance on promoting good Internet behaviour and responsible use of IT equipment and mobile technologies both at RISE and at home.  RISE expects parents and guardians to sign the Acceptable Use Agreement, indicating agreement regarding their child’s use and also their own use with regard to parental access to RISE systems such as extranets, websites, forums, social media, online reporting arrangement, questionnaires and the VLE.  RISE will provide opportunities to educate parents about e-safety through the school website and APP. 
Other users:Other users such visitors, or wider school community stakeholders or external contractors should be expected to agree to a visitor’s AUA document specific to their level of access and usage. External users with significant access to school systems including sensitive information or information held securely under the Data Protection Act should be Enhanced DBS checked. This includes external contractors who might maintain the RISE domain name and web hosting – which would facilitate access to cloud file storage, website documents, and email. 
How will the school provide e-safety education?  Pupils – curriculum teaching:   'Teaching online safety in school (DfE, June 2019) outlines to schools the importance of helping children and young people not only use the internet safely, but also give them opportunities to learn how to behave online. Throughout the new compulsory Relationships (Sex Education) and Health Education pupils will be taught what positive, healthy and respectful online relationships look like. The PSHE curriculum will following the underpinning knowledge and behaviours: How to evaluate what they see online How to recognise techniques used for persuasion Online behaviour How to identify online risks How and when to seek support  Throughout the curriculum teaching about potential harms will include: Age restrictions Content: How it can be used and shared Disinformation, misinformation, and hoaxes Fake websites and scam emails Fraud (online) Password phishing Personal data Persuasive design which keeps 'users online for longer than they might have planned or desired' Privacy settings Targeting of online content  Abuse (online) Challenges [to do something and post about it]  Content which incites...hate, violence Fake profiles Grooming Live streaming Pornography Unsafe communication  Impact on confidence (including body confidence) Impact on quality of life, physical and mental health, and relationships Online vs. offline behaviours Reputational damage Suicide, self-harm and eating disorders  E-safety is accessed as part of pastoral care – form time activities, presentations, tutorial opportunities, E-safety events – such as Safer Internet Day and Anti Bullying Week, the Live and Living skills course and digital employability course.
Parents/Carers – information and events:  E-safety information is directly available to parents via the website which is updated with the latest E safety news and issues.  
Staff – inset and training: E-safety information is directly delivered to staff annually and in between should new training, patterns or concerns emerge. A planned programme of e-safety training opportunities is available for staff, including on site inset, whole staff training, online training opportunities (for example E-safety Support courses), external CPD courses, accredited CPD courses, (for example CEOP) and Coordinator training.  The e-safety Coordinator should be the first port of call for staff requiring e-safety advice.   
Governors – training:  E-safety information will be directly delivered to governors via the e-safety Coordinator.  
ICT support staff – contractors, filtering, and monitoring: IT support staff and contractors will ensure that bought in hardware and software solutions feature built in training provision Support staff and contractors will be DBS checked and agree and sign the school’s e-safety AUA.  IT technical support staff and network managers have relevant industry experience and   Microsoft/Cisco certified qualifications.   Policy guidance for handling personal data, dealing with freedom of information requests, and complying with privacy regulations pertaining to website data:  All of these areas are regulated by the Information Commissioner (ICO), and every UK organisation has to comply with the responsibilities and obligations as defined by the ICO. Schools are no different to any other organisation in this regard. The ICO guidance on how to comply with these obligations is updated regularly. The Link School refer directly to this guidance in these areas.  When disposing of computer equipment, schools needs to ensure all data, including personal data is wiped, not deleted from storage.  Use of IT facilities for curriculum teaching and learning:  Use of the Internet and IT facilities should be clearly planned prior to the activity. Websites and software Apps should be suggested, Students should be trusted to be responsible when researching the Internet, and teaching staff will consider the age and maturity of the students.  
General Data Protection and e-safety: The GDPR sets out the key principles that all personal data must be processed in line with.  Data must be: processed lawfully, fairly and transparently; collected for specific, explicit and legitimate purposes; limited to what is necessary for the purposes for which it is processed; accurate and kept up to date; held securely; only retained for as long as is necessary for the reasons it was collected There are also stronger rights for individuals regarding their own data. The individual’s rights include: to be informed about how their data is used, to have access to their data, to rectify incorrect information, to have their data erased, to restrict how their data is used, to move their data from one organisation to another, and to object to their data being used at all. The General Data Protection Act is relevant to e-safety since it impacts on the way in which personal information should be secured on school networks, computers and storage devices; and the security required for accessing, in order to prevent unauthorised access and dissemination of personal material.  Staff need to ensure that care is taken to ensure the safety and security of personal data regarding all the school population and external stakeholders, particularly, but not exclusively: pupils, parents, staff, and external agencies. Personal and sensitive information should only be sent by e mail when on a secure network. Personal data should only be stored on secure devices. In other words, only computers, servers, file- servers, cloud space, or devices which require a username and password to access the information.   Secure accounts need to be logged off after use to prevent unauthorised access.   Personal e mails should not be used for school business. 
Personal information on the school website: No material defined as ‘personal information’ under the General Data Protection Act will be used on the RISE website. RISE considers staff privacy issues carefully about publishing staff email addresses, staff lists, photos of staff, staff qualifications and any other personally identifying information.     
Communications and acceptable use RISE hopes to make full use of ever developing communication technologies and appreciates that these technologies can enhance learning. 
E-safety and the Law: This e safety policy takes cognizance of the following legislation: The Education and Inspections Act 2006 (Head teachers have the power “to such an extent as is reasonable” to regulate the conduct of pupils off site. Also, staff can confiscate mobile phones if they cause disturbance in class breach the school behaviour policy.) Computer Misuse Act 1990, sections 1-3 Data Protection Act 1998 General Data Protection Regulations Freedom of Information Act 2000 Communications Act 2003 section 1,2 Protection from Harassment Act 1997 Regulation of Investigatory Powers Act 2000 Copyright, Designs and Patents Act 1988 Racial and Religious Hatred Act 2006
Protection of Children Act 1978 Sexual Offences Act 2003 Schools have a ‘duty of care’ to pupils, and as such act “in loco parentis.” Under the Children Act 1989, this enables schools to remove personal information, cyber bullying and comments relating to school pupils as if they were the child’s parent. Facebook has provision for using ‘in loco parentis’ when reporting cyber bullying. This is relevant to all schools. 
Useful links to external organisations: CEOP (Child Exploitation and Online Protection Centre): www.ceop.police.uk  Childline: www.childline.org.uk  Childnet: www.childnet.com  Click Clever Click Safe Campaign: http://clickcleverclicksafe.direct.gov.uk  Cybermentors: www.cybermentors.org.uk  Digizen: www.digizen.org.uk  EiS - ICT Support for Schools and ICT Security Advice: www.eiskent.co.uk  Internet Watch Foundation (IWF): www.iwf.org.uk  Police: In an emergency (a life is in danger or a crime in progress) dial 999. For other non-urgent enquiries contact local Police. Sunderland Safeguarding Partnership:  www.sunderland.gov.uk/safersunderland Kidsmart: www.kidsmart.org.uk Teach Today: http://en.teachtoday.eu  Think U Know website: www.thinkuknow.co.uk Virtual Global Taskforce — Report Abuse: www.virtualglobaltaskforce.com



ALTR Whistle Blowing Policy

Purpose1.1.
To set out the ALTR’s policy and procedure for dealing with concerns raised by employees which relate to suspected wrongdoing or dangers at work (see paragraph 3). Allegations of child abuse against teachers and other staff and volunteers is be dealt with in accordance with Keeping Children Safe in Education statutory guidance for provisions and colleges. 2.

Background 2.1. It is important that any employee who notes a concern in the Provision, feels able to express their concerns without fear of harassment or victimisation.  The Public Interest Disclosure Act 1998 recognises that if employees are not reassured, they may be inclined to ignore the concern rather than report it.This Policy is designed to protect employees, who make certain disclosures of information in ‘the public interest’, from detriment and/or dismissal.  This policy builds on the provisions of the Act. 2.2. ALTR and the Governing Board is committed to the highest possible standard of operation, probity and accountability.  In line with that commitment, employees, officers, consultants, contractors, volunteers, casual workers and agency workers with serious concerns are encouraged to come forward and voice concerns.  This policy documents how employees/ contactors can do so without fear of reprisals; it is intended to encourage and enable employees to raise serious concerns within the provision rather than overlooking a problem or alerting anyone external to the provision. 2.3. This policy does not form part of any employee’s contract of employment and it may be amended at any time. 

3. Aims of the Policy 3.1. This policy aims to: provide avenues for employees to raise concerns internally as a matter of course, and receive feedback on any action takenprovide for matters to be dealt with quickly and appropriately; and ensure that concerns are taken seriously and treated consistently and fairlyreassure employees that they will be protected from reprisals or victimisation for whistleblowing where they have a genuine concernallow employees to take the matter further if they are dissatisfied with the Governing Board's response. 3.2. A whistle-blower is a person who raises a genuine concern relating to the matters below.  If employees have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) s/he should report it under this policy.  Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work.  This may include: (a) criminal activity(b) miscarriages of justice(c) danger to health and safety(d) damage to the environment(e) failure to comply with any legal or professional obligation or regulatory requirements(f) bribery(g)  financial fraud or mismanagement(h)  negligence(i) breach of our internal policies and procedures(j)  conduct likely to damage our reputation(k)  unauthorised disclosure of confidential information(l)  public examination fraud. (m) the deliberate concealment of any of the above matters. 3.3. Before initiating the procedure, employees should consider the following: the responsibility for expressing concerns about unacceptable practice or behaviour rests with all employeesemployees should use line manager or team meetings and other opportunities to raise questions and seek clarification on issues which are of day-to-day concern prior to whistleblowingwhilst it can be difficult to raise concerns about the practice or behaviour of a colleague, employees must act to prevent an escalation of the problem and to prevent themselves being potentially implicated. 
3.4. This policy should not be used for complaints about an employee’s personal circumstances, such as the way s/he has been treated at work.  In these cases, an employee should use the provision’s Grievance Procedure (or anti-harassment and bullying policy as appropriate); if the matter relates to salary, the salary review procedures documented in the provision’s pay policy. 
4. Safeguards 4.1. Harassment or Victimisation 4.1.1. The Governing Board recognises that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal from those responsible for the malpractice.  The Governing Board will not tolerate harassment or victimisation and will take action to protect employees when they have a genuine concern. 4.1.2. This does not mean that if an employee is already the subject of internal procedures such as disciplinary or redundancy, that those procedures will be halted as a result of that employee raising a concern under the whistleblowing policy. 
4.2. Confidentiality 4.2.1. We hope that staff will feel able to voice whistleblowing concerns openly under this policy.  The Governing Board will make every effort to protect an employee's identity if confidentiality is requested where it is possible to do so. 4.2.2. As indicated above, identity will be protected as far as possible, but should the investigation into the concern require the employee to be named as the source of the information, that this will be discussed with the employee before their name is disclosed.
 4.3. Anonymous Allegations 4.3.1. Employees are encouraged to put their name to an allegation.  Proper investigation may be more difficult or impossible if we cannot obtain further information and it is also more difficult to establish whether allegations are credible.  Anonymous allegations will be considered at the discretion of the Governing Board.  In exercising the discretion, the factors to be considered would include: the seriousness of the issues raisedthe credibility of the concernthe likelihood of confirming the allegation from attributable sources. 
4.4. Untrue Allegations 4.4.1. If an employee makes an allegation where s/he has a genuine concern, but it is not confirmed by the investigation, no action will be taken against that employee.  If, however, we conclude that an employee has made malicious or vexatious allegations, or with a view to personal gain, disciplinary action may be taken against that employee. 4.5. Unfounded Allegations 4.5.1. Following investigation, allegations may be confirmed as unfounded.  This outcome will be notified to the employee who raised the concern, who will be informed that the Governing Board deems the matter to be concluded and that it should not be raised again unless new evidence becomes available. 4.6. Support to Employees 4.6.1. It is recognised that raising concerns can be difficult and stressful.  Advice and support will be made available, as appropriate, to both the employee(s) raising the concerns and any employee(s) subject to investigation. 5. How to raise a Concern 5.1. STEP 1: An employee should normally raise concerns with their immediate manager or their manager's superior.  This depends, however, on the seriousness and sensitivity of the issues and who is involved.  For example, if an employee believes that their immediate manager or their manager's superior is involved, s/he should approach the Provision Lead and or Chair of Governors.  An employee (including the Headteacher and members of the leadership team) can by-pass the direct management line and the Governing Board if s/he feels the overall management and Governing Board of a provision is engaged in an improper course of action.  In this case please refer to section 7 below. STEP 2: Concerns must be raised in writing.  The employee should set out the background and history of the concerns, giving names, dates and places where possible, and the reasons why s/he is particularly concerned about the situation.  If an employee does not feel able to put the concern in writing, s/he should telephone or meet the appropriate person.  It is important that, however the concern is raised, the employee makes it clear that s/he is raising the issue via the whistle-blowing procedure. The earlier an employee expresses the concern, the easier it is to act. STEP 3: Although an employee is not expected to prove the truth of an allegation, s/he will need to demonstrate to the person contacted that there are sufficient grounds for the concern. In some instances, it may be appropriate for an employee to ask the trade union to raise a matter on the employee’s behalf. At each meeting under this policy the employee may bring a colleague or trade union representative.  The companion must respect the confidentiality of the disclosure and any subsequent investigation. 


6. The Role of Senior Managers 6.1. A Senior Manager may be informed by an employee about concern(s) and that s/he is "blowing the whistle" within the procedure in person, or in writing or over the phone. 6.2. The Senior Manager should respond immediately by arranging to meet with the employee to discuss the concern(s) as soon as possible. 6.3. Stage One: 6.3.1. At the initial meeting, the Senior Manager should establish that: there is genuine cause and sufficient grounds for the concern; and the concern has been appropriately raised via the Whistle-blowing Policy. 6.3.2. The Senior Manager should ask the employee, to put their concern(s) in writing, if s/he has not already done so.  If the employee is unable to do this the senior manager will take down a written summary of his/her concern/s and provide him/her with a copy after the meeting.  The Senior Manager should make notes of the discussions with the employee.  The employee's letter and/or senior manager's notes should make it clear that the employee is raising the issue via the whistle-blowing procedure and provide: the background and history of the concernsnames, dates and places (where possible)the reasons why the employee is particularly concerned about the situation. 6.3.3. The employee should be asked to date and sign their letter and/or the notes of any discussion.  The Senior Manager should positively encourage the employee to do this, as a concern expressed anonymously is much less powerful and much more difficult to address, especially if the letter/notes become evidence in other proceedings, e.g. an internal disciplinary hearing. 6.3.4. The Senior Manager should follow the policy as set out above and explain to the employee: who he/she will need to speak to determine the next steps (e.g. Headteacher)what steps s/he intends to take to address the concernhow s/he will communicate with the employee during and at the end of the process.  It should be noted that the need for confidentiality may prevent the provision giving the employee specific details of any necessary investigation or any necessary disciplinary action taken as a resultthat the employee will receive a written response within ten working daysthat their identity will be protected as far as possible, but should the investigation into the concern require the employee to be named as the source of the information, that this will be discussed with the employee before their name is disclosedthat the Governing Board will do all that it can to protect the employee from discrimination and/or victimisationthat the matter will be taken seriously and investigated immediatelythat if the employee's concern, though raised as a genuine concern, is not confirmed by the investigation, no punitive action will be taken against themif clear evidence is uncovered during the investigation that s/he has made a malicious or vexatious allegation, disciplinary action may be taken against themthe investigation may confirm their allegations to be unfounded in which case the Governing Board will deem the matter to be concluded unless new evidence becomes available. 
6.4. Stage Two: 6.4.1. Following the initial meeting with the employee, the Senior Manager should consult with the Headteacher or Chair of Governors to determine whether an investigation is appropriate and, if so, what form it should take.  A record should be made of the decisions and/or agreed actions. 6.4.2. It may be necessary, with anonymous allegations, to consider whether it is possible to take any further action.  When making this decision, Senior Managers should take the following factors into account:the seriousness of the issue(s) raisedthe credibility of the concern(s)the likelihood of confirming the allegation(s) from attributable sources. 
6.4.3. In some cases, it may be possible to resolve the concern(s) simply, by agreed action or an explanation regarding the concern(s), without the need for further investigation.  However, depending on the nature of the concern(s) it may be necessary for the concern(s) to: be investigated internallybe referred to the policebe referred to the external auditorform the subject of an independent inquiry. 6.4.4. Senior Managers should have a working knowledge and understanding of other provision policies and procedures, e.g. grievance, disciplinary, harassment, child protection procedures, to ensure that concerns raised by employees are addressed via the appropriate procedure/process.  6.5. Stage Three: 6.5.1. Within ten working days of a concern being received, the manager receiving the concern (at paragraph 5.1 above) must write to the employee: acknowledging that the concern has been receivedindicating how they propose to deal with the mattergiving an estimate of how long it will take to provide a final response and or telling the employee whether any initial enquiries have been madetelling the employee whether further investigations will take place, and if not why not; and/or letting the employee know when s/he will receive further details if the situation is not yet resolved 7. Raising Concerns Outside the Provision 7.1. The aim of this policy is to provide an internal mechanism for reporting, investigation and remedying any wrongdoing in the workplace.  In most cases the employee should not find it necessary to alert anyone externally.  The law recognises that in some circumstances it may be appropriate for the employee to report his/her concerns to an external body such as a regulator.  It will never be appropriate to alert the media.  Employees are strongly encouraged to seek advice before reporting a concern to anyone external.  If an employee is not satisfied with the Governing Board's response, the manager should ensure that s/he is made aware with whom s/he may raise the matter externally:‘Public Concern at Work’ Tel no:  0207 404 6609*Recognised Trade UnionSenior LA OfficerExternal AuditorRelevant professional bodies or regulatory organisationsSolicitor  7.2. The manager should stress to the employee that if s/he chooses to take a concern outside the Provision, it is the employee's responsibility to ensure that confidential information is not disclosed, i.e. confidential information, in whatever format, is not handed over to a third party. *Public Concern at Work is a registered charity that employees can contact for advice to assist them in raising concerns about poor practice at work. The charity also provides advice to employers as to the possible ways to address these concerns. 7.3. Concerns about safeguarding practices must be raised internally where appropriate but externally using the NSPCC whistleblowing helpline. Employees can call 0800 028 0285 or email help@nspcc.org.uk 8. Monitoring and Review 8.1. The Provision Lead will be responsible for monitoring the implementation and effectiveness of this policy/procedure.  The policy/procedure will be reviewed by the Governing Board as necessary.


ISE LONE WORKERS POLICY AND PROCEDURE

Introduction ALTR is committed to protecting the health, safety and welfare of its employees and recognises that lone working is a Health and Safety (H & S) issue and acknowledges the importance of identifying and managing lone workers.  Employers have a duty under the Health and Safety at Work etc Act 1974 (HASAW), to ensure, so far as is reasonably practicable, the health, safety, and welfare of its employees.  Under the Management of Health and Safety at Work Regulations 1999 (as amended), employers must assess the nature and scale of risks to safety in any workplace environment and base any control measures upon this assessment.  Lone working is one of the hazards assessed in the school’s overall risk assessment and management plan.   PURPOSE  ALTR aims to recognise lone workers and manage associated risks by early identification of lone working environments and practices. The purpose of this policy is to provide assistance to managers and employees and to ensure lone workers are identified, risk assessed, and appropriate control measures are implemented and monitored. A Working Alone Health and Safety Guidance booklet (INDG73 revision 2 – appendix 1) has been developed by Health and Safety Executive (HSE) to provide guidance for the management of lone working.  Staff are required to read this and follow its recommendations.   DEFINITIONS:Lone Workers are those that work by themselves without close or direct supervision.  They may be found in a wide range of situations and a non-comprehensive list is as follows:  Home or community visits  Working outside normal hours A risk assessment is the process used to identify the likelihood and consequence of a hazard to any person who may be affected, to evaluate the risks, and decide on any necessary control measures required to mitigate those risks to an acceptable level.   Lone workers to be line managed by a member of the Provision Lead  Each new situation must have a risk analysis which must be discussed with the Provision Lead before commencing the task. If the risk is considered medium – high a written Risk Assessment to be produced by the manager to reduce risk (see school proforma held in the school office). This Risk Assessment will be regularly monitored by the Provision Lead.   The lone worker, if concerned, should contact by phone or in person their line manager at any point to consult or seek advice.  On completion of the task/visit, the lone worker should contact the line manager on leaving the site.   RESPONSIBILITIES OF EMPLOYEES  Cooperate with the implementation of this policy to ensure minimisation of risks associated with lone working. Inform their line managers or Health & Safety representative to escalate any concerns they have in relation to lone working.  Staff will meet regularly with their line manger to discuss concerns and these will be addressed and acted upon by the line manager.  Staff will not be expected to continue the lone working if issues have not been resolved immediately.  Be responsible for personal safety and wellbeing and adhere to any specified control measures.    
PERSONAL RISK ASSESSMENT  Individual risk assessments must consider the unique characteristics of the member of staff and ensure that control measures are adapted as is appropriate for that person. All staff will be trained in manual handling and Safeguarding. ALTR has the responsibility to assess risks to lone workers and take steps to avoid or control risks where necessary.  (see Appendix 1)  POTENTIAL MITIGATION MEASURES FOR CONSIDERATION  Lone workers will hold individual timetables detailing the times of the day and places they are visiting and what work is carried out.  It is the responsibility of the lone worker to complete these and ensure the school hold their diary – work diaries, including electronic devises, ensures a central location for managers to know where staff are expected to be at certain times of the day.  These will be held by the ALTR office and the relevant line manager. This information is critical if Line Managers, Directors or Police are involved:  Name, address and telephone number of staff  Car registration number  Make and model of car  Mobile telephone number and/or pager of staff  Time of each visit including start and finish  Name, address and telephone number of each pupil/parent/carers  ‘Buddy’ contact details (if appropriate)  Details of any risk assessments undertaken  Photograph of staff  Consider a code word to be used when in danger  This information should be held by relevant managers and nominated individuals, otherwise it is to be kept confidential and not to be placed in a position where pupils/parents/carers or the general public have access to it.  This will be held centrally in the secure ALTR Office in line with GDPR.   THINK BEFORE YOU GO  Think first: Have you been supplied with all the information about the person you are visiting and about the environment?  Are there any records or reports available to you before you go?  Do people know where you are going, is your calendar updated?  Consider whether you are wearing appropriate footwear or clothing in case you need to leave promptly and or with urgency.Avoid wearing expensive jewelleryAvoid wearing anything that can be grabbed to prevent you running away e.g. scarf.Have you got someone to check in with (a buddy)?  Do you have a mobile phone/pager/telephone numbers or anything else to help to keep in touch?  Is the mobile/pager accessible and working?  Is it charged?  Does it have enough credit?  How are you getting there and back?  

WHEN YOU ARRRIVE  Park taking into consideration the possible need to leave quickly  On approach to the home there may be certain indications of the situation within the home, for instance, violent arguing  Remember you are the visitor  Stand back from the door and slightly to one side as it opens as this affords you a split second to react if necessary  Say who you are, why you are there and show your ID if you have one  Check who you are talking to   Only enter the house if the person you have arranged the meeting with is there.   Wait to be invited in or ask if you can go in  If it is possible try and assess the person’s attitude and mental state before entering the premises   acknowledge that it is their territory; let them lead the way  Check as you go in how the front door locks  Take only what you need into the house  If the person answering the door makes you feel uneasy about entering the premises, then make an excuse and do not enter.  DURING YOUR VISIT  Study your surroundings.  Look for an exit  Ensure you can get out quickly if necessary, try to sit nearest the door  Try not to react to bad, dirty or smelly surroundings  Politely request for any pets, if you think they may get aggressive, to be secured away from the main room where treatment may be given  Remain alert.  Watch for changes in mood, movements or expressions If there is a TV or radio on in the house, with the volume raised, politely ask if they could turn it down – this will make sure you and the person you are talking to can hear what is being said Do not spread your belongings around as you may need to leave in a hurry  If the person is making you slightly concerned, try not to stand in the kitchen as this can be the most dangerous room in the house  If you feel at risk – have an excuse ready so you can leave as soon as possible e.g. that you need to get something from your car  If you are prevented from leaving or threatened, stay calm and try and control the situation  HOME VISITS - CAR   Ensure your car is, always, in a road worthy state with sufficient fuel, and have business insurance when necessary.   Do not leave for a visit without being sure of your route.  Have directions and a map in the car    Park in well lit, public areas where possible, and away from waste ground and subways  Lock possessions in the boot of your car  If confronted in the car do not get out When driving through built up areas ensure your car doors are locked and the windows closed when possible  WHEN VISITS ARE COMPLETEDAdvise your base that you have finished your visit  Inform them of your next destination  Ensure all incidents are reported immediately as per the ALTR Incident procedures.  ADDITIONAL ADVICE  Care must be taken of staff’s work diaries whilst on home visits; they must not be left unattended at any time  Never give out your home telephone number or address.  Advise them of the school telephone number  Shout ‘fire’ rather than ‘help’ – it can get more response  Whilst driving, if you feel your safety is being compromised, drive to a place which is well lit and busy e.g. shops, petrol stations Staff are representatives of ALTR and should therefore follow all procedures in line with St Nicholas Policies and all staff are always expected to follow Staff Code of conduct.  MONITORING AND REVIEW  This policy will be monitored on a yearly basis by the Provision Lead and Board members to keep up to date with any adjustments to statutory legislation or changes to working arrangements.    
EQUALITY, SAFEGUARDING AND EQUAL OPPORTUNITIES STATEMENT  ALTR, in all policies and procedures, will promote equality of opportunity for students and staff from all social, cultural and economic backgrounds and ensure freedom from discrimination on the basis of membership of any group, including gender, sexual orientation, family circumstances, ethnic or national origin, disability (physical or mental), religious or political beliefs.   ALTR aims to: Provide equal opportunity for all To foster good relations, and create effective partnership with all sections of the community To take no action which discriminates unlawfully in-service delivery, commissioning, and employment to provide an environment free from fear and discrimination, where diversity, respect and dignity are valued. All aspects of Safeguarding will be embedded into the life of the school and be adhered to and be the responsibility of all staff.  LINKS TO OTHER POLICIES  Safeguarding Health and Safety Staff Code of Conduct Confidentiality Policy/Data Protection Policy 


Data Protection Policy 

ALTR Data Protection Policy 
 The Data Protection Act 1998 is the law that protects personal privacy and upholds individual’s rights.  It applies to anyone who handles or has access to people’s personal data.  
This policy is intended to ensure that personal information is dealt with properly and securely and in accordance with the Data Protection Act. It will apply to information regardless of the way it is used, recorded and stored and whether it is held in paper files or electronically. 
Scope of the Policy
Personal information is any information that relates to a living individual who can be identified from the information.  This includes any expression of opinion about an individual and intentions towards an individual. It also applies to personal data held visually in photographs or video clips (including CCTV) or as sound recordings.
ALTR RISE and ALTR RISEX collects a large amount of personal data every year including: staff records, names and addresses of those requesting prospectuses, examination marks, references, fee collection as well as the many different types of research data used by the Provision.  In addition, it may be required by law to collect and use certain types of information to comply with statutory obligations of Local Authorities (LAs), government agencies and other bodies. 
This policy is applied to students, staff, visitors, parents/ carers, governing body, volunteers
ALTR is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller, the handling of such data in line with the data protection principles (see below) and the Data Protection Act (DPA). Changes to data protection legislation (General Data Protection Regulations May 2018) shall be monitored and implemented to remain compliant with all requirements.  
The legal bases for processing data are as follows –  
Consent: the member of staff/student/parent/visitor/volunteer/ board member has given clear consent for the provision to process their personal data for a specific purpose.  Contract: the processing is necessary for the member of staff’s employment contract or student placement contract.  
Legal obligation: the processing is necessary for the provision to comply with the law (not including contractual obligations)  The requirements of this policy are mandatory for all staff employed by the provision and any third party contracted to provide services within the provision.
2.  The Eight Principles
Under GDPR, there are eight data protection principles, or rules for ‘good information handling’ all of which will be implemented by ALTR.   
1. Data will be processed fairly and lawfully with transparency. 
2. Personal data shall be obtained only for one or more specific and lawful purposes; collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes
3. Personal data shall be adequate, relevant and not excessive in relation to the purpose(s) for which they are processed. 
4. Personal data shall be accurate and where necessary kept up to date. every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
5. Personal data processed for any purpose(s) shall not be kept for longer than is necessary for that purpose. personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; 
6. Personal data shall be processed in accordance with the rights of data subjects under the 1998 Data Protection Act, with appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.” 
Article 5(2) requires that: “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”
 Notifications shall be in accordance with ICO guidance and, where relevant, be written in a form understandable by those defined as ‘Children’ under the legislation 
7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data. 
8. Personal data shall not be transferred to a country outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. 
3.  Roles and responsibilities
3.1 The provision will:
Manage and process personal data properly Protect the individual’s right to privacyProvide an individual with access to all personal data held on them upon request.
3.2  
Keighly Murphy is the Data Controller; this role holds responsibility to hold and use personal information.  They decide how and why the information is used and have a responsibility to establish workplace practices and policies that are in line with the Act.
All staff will treat all student information in a confidential manner and follow the guidelines as set out in this document. 
All staff will undertake GDPR Training and internal monitoring will take place.  Any Data Processors, processing data on behalf of the provision (i.e. external organisations) will confirm that they are achieving their obligations under the GDPR Regulations and are registered with the ICO.   Roles under GDPR can be found on the ICO Website https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/.
3.3 The provision is required to ‘notify’ the Information Commissioner of the processing of personal data.  This information will be included in a public register which is available on the Information Commissioner’s website at the following link: 
http://www.ico.gov.uk/what_we_cover/promoting_data_privacy/keeping_the_register.aspx
3.4 Every member of staff that holds personal information must comply with the Act when managing that information.  
3.5 The provision is always committed to maintaining the eight principles. This means that the provision will: 
• inform Data Subjects why they need their personal information, how they will use it and with whom it may be shared.  This is known as a Privacy Notice.
• check the quality and accuracy of the information held 
• apply the records management policies and procedures to ensure that information is not held longer than is necessary 
• ensure that when information is authorised for disposal it is done appropriately 
• ensure appropriate security measures are in place to safeguard personal information whether that is held in paper files or on a computer system 
• only share personal information with others when it is necessary and legally appropriate to do so 
• set out clear procedures for responding to requests for access to personal information known as subject access in the Data Protection Act (see appendix) 
• train all staff so that they are aware of their responsibilities and of the provisions relevant policies and procedures 
4. Personal and Sensitive Data:  
4.1 All data within the provision’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.  
The definitions of personal and sensitive data shall be those published by the ICO for guidance.
This policy will be updated as necessary to reflect best practice or amendments made to the Data Protection Act 1998.
Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc.  You may find it helpful to read the Guide to Data Protection which is available from the website.
For help or advice on any data protection or freedom of information issues, please do not hesitate to contact 
The need for consent: 
4.2 The provision will ask for consent to hold and process personal information if there is no lawful basis for doing so: 1) Contract 2) Legal Obligation 3) Vital Interests 4) Public task 5) Legitimate 
If personal information meets the above criteria, then individuals who have personal information held by the provision will be made aware of the personal information and the criteria for holding the information in the ‘Information Audit’ document, located on the provision website
Data Breaches: 
4.3 All data breaches must be immediately reported to the Data Controller Keighly Murphy. The Data Protection Controller will assess whether the breach needs to be reported to the ICO and/or individuals concerned. The Data Controller undertake a review to explore how the breach has occurred, and to implement changes to processes to ensure the same does not reoccur.

The Data Protection Officer will provide a monitoring role and be a contact point for the supervisory authority, as necessary. 
Protection Impact Statements: 
The provision will evidence the thought and decision-making process about data protection when designing any processes in provision which involve personal data. 
A Data Protection Impact Statement (DPIA) is needed when: New Technology is being deployed A profiling operation is likely to significantly affect individuals There is processing on a large scale of the special categories of data (‘special categories’ as specified in GDPR guidance) 
Individuals Rights: 
Individuals have the right to: Be informed about what data is being held (Information Audit Document published on the provision website).Be informed about how and why the data is being processed (Information Audit Document published on the provision website). The right to access any data that is being held (see Subject Access Requests below). The right to request that any data is erased (see Subject Access Requests below). The right to restrict processing. The right to data portability (that the individual can transport the data held about them to another service) if the data is held by automatic means. The right to object to the way data is being held or processed. The right not to be subject to automated decision-making. 
The individual can write to the Data Manager regarding requests for data to be erased, to restrict processing, to data portability, to not be subject to automated decision-making, or the right to object to the way data is being held or processed. 

Sharing of Information with Third Parties: 
There may be circumstances where ALTR is required either by law or in the best interests of students or staff to pass information onto external authorities. ALTR will ensure that they comply with data protection law and have their own policies relating to the protection of any data that they receive or collect. 
Personal data about children, will not be disclosed to third parties without the consent of the child (at an age who can act for themselves, specified under GDPR guidance) the child’s parent or carer, unless it is obliged by law or in the best interest of the child.  
Examples of data that may be disclosed to third parties without the need for consent: 
• Transfer data to other provision will be necessary to ensure, continuity of academic support, safeguarding and health and wellbeing care.   • Examination Bodies for registration purposes. 
• Department for Education and Ofsted to enable monitoring and audit of provision performance and enforce laws relating to education.  • Social workers and support agencies to protect or maintain the welfare of pupils, and in cases of child abuse/ neglect. • Health authorities (under health legislation), the provision may pass on information regarding the health of children in the provision to monitor and avoid the spread of contagious diseases in the interest of public health.  • Police and courts for criminal investigation. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information, or where it is for the purpose of pupil provision, such as provision meals and on-line curriculum work. Individuals will be notified if there is any proposed change to the processing of individual’s data. Any data sent to external sources will be password protected.

Provision will not disclose information or data:  
that would cause serious harm to the child or anyone else’s physical or mental health.indicating that the child is or has been subject to child abuse or may be at risk of it, where the disclosure would not be in the best interests of the child.that would allow another person to be identified or identifies another person as the source, unless the person is an employee of the provision or a local authority or has given consent, or it is reasonable in the circumstances to disclose the information without consent. The exemption from disclosure does not apply if the information can be edited so that the person’s name or identifying details are removed. 
Data Access Requests (Subject Access Requests): 
All individuals whose data is held by the provision, has a legal right to request access to such data or information. A child may make a subject access request for themselves, specified under GDPR guidance. The provision shall respond to such requests within one month.  
Requests are to be made in writing to the Data Manager, who may delegate the request (as specified in their role above).  No charge will be applied to process the request. There is a right to appeal to the ICO upon dispute of a decision. 
Right to be Forgotten:  
Where any personal data is no longer required for its original purpose, an individual can demand that the processing is stopped, and all their personal data is erased by the provision including any data held by contracted processors.  
Photographs and Video: 
Images of staff and pupils may be taken as part of educational activities for provision use. The provision shall not utilise such images for publication or communication to external sources unless prior consent from parents/pupils/staff has been given.
External parties (including parents) may not capture images of staff or pupils during such activities without prior consent. 
Location of Information and Data:  
ALTR aims to reduce all paperwork where possible and will endeavour to upload all information electronically.
Hard copy data, records, and personal information are stored in a locked cupboard in a room with keycode. 
Medical information, attendance registers and signing in books (which must be immediately accessible and used in the case of an emergency) will be available to those that require it but will be maintained and kept securely within the staff members possessions and will not be left unattended. 
Sensitive or personal information and data will not be removed from the provision site; however, staff may need to access data through the internal IT systems from home. 
Where staff have offsite meetings or are on provision visits with pupil’s information may be required to be transported. Where possible and or appropriate this should be electronically stored and accessed via a laptop in an external setting. 
Risks of identified breaches from existing processes have been considered and have been recorded on an Impact Assessment Form. 
The following guidelines are in place for staff to reduce the risk of personal data being compromised:  
• Paper copies of data or personal information should not be taken off the provision site, unless the Data Controller has provided permission to do so (such as the need for emergency information during educational visits). If there is no other way to avoid taking a paper copy of data off the provision site, the information should not be on view in public places or left unattended under any circumstances. • Unwanted paper copies of data, sensitive information or pupil files should be shredded. This also applies to handwritten notes if the notes reference any other staff member or pupil by name. • Care must be taken to ensure that printouts of any personal or sensitive information are not left in printer trays or photocopiers. • If information is being viewed on a PC, staff must ensure that the window and documents are properly shut down before leaving the computer unattended. Sensitive information should not be viewed on public computers.  • If it is necessary to transport data away from the provision, it should be downloaded onto a password protected USB stick or computer. Computers will also be encrypted if it viable to do so. The data should not be transferred from computers or USB onto any public computers. Work should be edited from the USB and saved onto the USB or authorised computers only. 
These guidelines are clearly communicated to all provision staff, and any person who is found to be intentionally breaching this conduct will be disciplined in line with the seriousness of their misconduct. 
Data Security: 
ALTR shall undertake an assessment of the associated risks of proposed processing and the impact on an individual’s privacy, in holding data related to them.
Risk and impact assessments shall be conducted in accordance with guidance given by the ICO and in compliance with the Data Protection Regulations (GDPR). 
Security of data shall be achieved through the implementation of proportionate physical and technical measures. Nominated staff shall be responsible for the effectiveness of the controls implemented and reporting of their performance.
The security arrangements of any organisation with which data is shared shall also be considered and where required these organisations shall provide evidence of the competence in the security of shared data. 
Data Disposal: 
ALTR recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk. All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner with demonstrable competence in providing secure disposal services. 
All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process. 
Disposal of IT assets holding data shall be in compliance with ICO guidance. 
Any IT resources no longer required will be profession ally cleaned prior to disposal.




Abbreviations:  GDPR – General Data Protection Regulations ICO - Information Commissioners Office DPO – Data Protection Officer



No Smoking & e-cigarette Policy

1.Purpose This policy has been produced in response to regulations regarding ‘the provision of a smoke free environment’ and to implement the Health Act 2006. ALTR recognises its duty to protect all employees, young people, visitors and partners from exposure to second-hand smoke and is committed to fully complying with the legislation in place from 1 July 2007.  This policy is also informed by advice from Public Health England regarding the use of e-cigarettes in public places and workplaces, July 2016.  The Academy Council notes that failure to display ‘No Smoking’ signs and/or failing to take adequate steps to prevent smoking in a smoke free place are both criminal offences which could lead to substantial fines.  2. Application Smoking will be prohibited at all times. This prohibition will apply to anyone entering the site including all employees, students, contractors and visitors.Smoking will be prohibited at all locations within the Provision boundaries, Colmworth site, car parks and entrance roads for any persons associated with ALTR and RISE.Smoking will be prohibited in any vehicle owned by, or contracted to, ALTR and or RISE also by anyone visiting the site.Appropriate signage will be available at appropriate locations around the site and no provision for smokers will be made.Responsibility for the implementation of this policy and its enforcement will be delegated to the Provision Lead, who has the authority to further delegate responsibility for elements of this policy as appropriate. All staff and young people are obliged to adhere to the implementation of this policy and training will be provided for all to ensure they understand their role and responsibilities.All staff and students are to be made aware of this policy and that non-compliance will be a serious disciplinary matter which will be addressed using existing disciplinary procedures. All contractors will be responsible for the compliance of its workforce whilst on the Colmworth site. ALTR will take all reasonable steps to ensure full compliance with this policy. Where any other person is found not to comply with this policy, they will be asked to stop or leave the site. If they refuse to do so, police will be notified.ALTR offer advice and support to staff and young people who wish to give up smoking.   3. E-cigarettes E-cigarette use, known as vaping, is not covered by smoke free legislation because E-cigarettes do not burn tobacco and do not create smoke as such, however the 2015 prohibition on selling e-cigarettes to under-18s, and on adults buying them on behalf of under18s, offers safeguarding and protection for children and young people. ALTR supports this approach and as such has impacted our Policy and Procedure.Following guidance set out by Public Health England, July 2016, schools are advised to treat e-cigarettes in the same way as other age restricted products. As a result, we prohibit them onsite, in the same way as we prohibit smoking and the same protocols apply.The primary concern about e-cigarettes is their uptake by young people and unknown risks of harm to health, furthermore they stand to renormalize smoking, and smoking safety for bystanders. Advances that have been made in achieving clean air smoke free environments can be reversed and a normalisation of nicotine addiction supported. This Policy has been devised to support all ALTR site users from a potentially harmful activity until we are in receipt of guidance that dictates otherwise.
Policy Agreed: September 2020Agreed by: Keighly Murphy and the Governing Body



Anti-Bullying Policy  

Purpose
Bullying can take many forms, from physical or verbal abuse to bullying via text messages or the internet (cyber-bullying). Bullying has long lasting impact on mental health and wellbeing not just to the victim and perpetrator but also to those who observe the bullying or become involved through peer pressure. ALTR believes in establishing and maintaining a respectful, positive and consideration learning environment where the rights of individuals are safeguarded.At RISE we are aware that abuse, violence, threatening behaviour, trolling, insults and certain jokes can be found in society but aimed at protected characteristics such as age, disability, race, sex, gender reassignment, religion, belief or sexual orientation however, no one person should accept this. In addition, we recognise that those students with SENDV who may be at higher risk of peer group isolation and can suffer a disproportionate impact of bullying.  Students with SENDV may have difficulties with communication and it is imperative that staff members are trained to identify bullying through changes in mood, behaviour, engagement.Bullying will not be tolerated at ALTR. It is contrary to our values and ethos by which we work. Here at RISE and RISEX we believe that all have a responsibility to protect and maintain our learning environment, protect the health and well being of all young people and staff and protect all from harm. We endeavour to teach young people how to uphold our ethos and how to manage and challenge breaches of it. Everyone has the right to feel safe and respected. RISE and RISEX understand the importance of tackling bullying at the earliest opportunity and not allow it to escalate to a point where a pupil suffers emotional or physical distress. We support the bullied child, not the bully.
2. Principles Encourage understanding and tolerance of different social, religious, and cultural backgrounds.Raise awareness of bullying and through pastoral curriculum and staff training, teach young people and staff how to recognise it in yourself and others, teach strategies to challenge and address bullying, how to report it and get support, teach mutual respect and positive relationships.Adopt a definition of Bullying that is agreed withing ALTR RISE, RISEX and all other projects.Have a consistent approach to managing any incidents of Bullying that may arise.Consult all stakeholders in the design, implementation, and delivery of this Policy, including the student steering group.Provide support for any person who may be involved in dealing with a bullying incident as soon as identified.Ensure fair treatment for all, regardless of age, culture, disability, gender, religion, or sexuality. Ensure that any other partners accessible to our young people also have a no tolerance approach to bullying.
3. Definition of BullyingALTR define bullying as a persistent or repeated, deliberate attempt to hurt or humiliate someone else. We are aware that one off incident occurs, and these are not acceptable but may not constitute bullying. Bullying is repeated, reoccurring, is often premeditated and intended to cause physical or emotional damage. Bullying demonstrates one or more of the following characteristics:Repeated over a period of timeIt is deliberately hurtfulThere is an imbalance of power
Bullying can take different forms. It could include:physical bullying: use of violence, hitting, slapping, kicking, or pushing someoneverbal bullying: name calling, gossiping, or threatening someone, sarcasmnon-verbal abuse: hand signs or text messagesemotional abuse: threatening, intimidating, or humiliating someone, excluding from groups or games, tormenting, hiding things, threatening body language or gestures.exclusion: ignoring or isolating someoneundermining, constant criticism or spreading rumourscontrolling or manipulating someonemaking silent, hoax or abusive callsExtortion of money or other belongingsDeliberate damage to propertyCyber communication such as email, chat room misuse, mobile threats by text, calls or picture messaging and other social mediaPeer on peer: physical abuse, sexting, being coerced into sending sexual images (sexting), teenage relationship abuse, sexual violence, sexual harassment, physical abuse, up-skirting and ‘initiation ceremonies’Bullying itself is not a specific criminal offence however some types of harassing or threatening behaviour – or communications – could be criminal offences.  
The following types of bullying are also hate crime:Racial bullying: racial taunts, graffiti or comments, gestures, gossip, and all above forms.Sexual, transphobic, or homophobic: Bullying because of their sexuality, gender, in any above-mentioned form.Disability: Bullying because of their disability, in any above-mentioned form.

Roles and Responsibilities
RISE and RISEX pride we on creating a learning environment that is safe and secure for all staff, visitors, and learners. By working together, we aim to combat any incidents of bullying as soon as they arise and offer a comprehensive induction programme for staff and curriculum for young people to ensure all aware of the Provision Policies.
The provision leader Keighly Murphy has ultimate responsibility for the health and wellbeing of all young people and stake holders but all will be made aware of the policy and any issues or patterns that may be emerging in the community.
Staff responsibility Foster an environment that celebrates diversity and the right for everyone to feel safe and respected and demonstrate this as role models to the young people.To deliver pastoral programmes that teach students how to identify bullying and how to challenge it.To set high expectations of student behaviour and adopt clear and consistent boundaries.Be alert to signs of bullying as communication may be a challenge for the young person and support them in learning ways to share worries or concerns. Make a wide range of resources available for students to communicate bullying concerns.Listen to young people who have been bullied, take what they say seriously and act to support and protect them. Know the relevant school policy and procedures. All incidents of bullying to reported on Myconcern. Any imminent threat to safety must be taken directly to the Lead Safeguarding Officer Keighly Murphy.Follow up with student where appropriate and communicate all with parents and carers. Attend meetings with key pastoral staff, parents, and other agencies as appropriate.Discuss any concerns of personal bullying immediately with line manager.Where bullying takes place outside school it must be reported to school staff, to be investigated and acted on. New search powers included in the Education Act 2011 have given teachers stronger powers to tackle cyber-bullying (via text message or the internet) by providing a specific power to search for an image on a mobile phone if it is likely to be used to cause harm.  
Student responsibility Foster an environment that celebrates diversity and the right for everyone to feel safe and respected.To report incidents of bullying that they become aware of to protect the wellbeing of all and dispel a culture of secrecy and help prevent further bullying incidents.Speak up and intervene to protect any bullying they may encounter if it is safe to do so.Support each other in standing up to bullying by not tolerating it.Not to use bullying tactics as retaliation for their own bullying or the bullying of their friends.
Student Anti Bullying Charter
A student council will work together to agree an antibullying charter that reflects the concerns of the students, supports the ALTR ethos and reflects this policy. They will also showcase the work they do to prevent bullying by involving the whole school community in bringing about positive change.
Parent responsibility
Encourage your young person to report incidents of bullying to a member of staff and explain to the young person the implications for themselves others if the incident is not reported.Report any incidents of bullying as soon as it occurs to enable the school to put measures in place to support and protect the victim and to educate and support the bully.Take responsibility for any abuse of technology including texts, emails, and social media platforms.Not to support any retaliation between parent/ carer or young person.Reassure the young person that the school will take appropriate action.If the young person is accused of bullying, allow the school to investigate fully to ascertain the truth.Speaking respectfully to all members of staff who are managing the incidents.Informing the school of bullying that they may be aware of that is not directly linked to their young person.

Links
https://www.bullying.co.uk/
Helpline 0808 800 2222

https://www.kidscape.org.uk/advice/advice-for-parents-and-carers/bullying-at-school/

https://www.nspcc.org.uk/what-is-child-abuse/types-of-abuse/bullying-and-cyberbullying/

NSPCC Helpline for 18 and under 0800 1111NSPCC

Helpline for Parents/ carers 0808 800 5000
https://www.stompoutbullying.org/get-help/about-bullying-and-cyberbullying/are-you-being-bullied


School response flow chart: Student Bullying
1. Listen carefully and calmly, and document what the student tells youEnsure a private place to talk. Do not dismiss their concerns or make them feel they are at fault. Listen to their account fully first and then ask them (and maybe others) questions to get more detail. Avoid the terms 'bully' or 'victim' and instead talk about the behaviour of everyone involved, including bystanders. Clarify if there are immediate safety risks and let the student know how you will address these. Write a record of the conversation.
2. Collect additional information  Ask for any evidence from the student. Speak with all students involved, including bystanders. Be alert to your legal responsibilities regarding evidence if the incident may constitute a crime. Keep records. Ensure you have information that answers who, what, where, when, how, why. Students views on why bullying is happening can suggest ways the school can respond.
3. Discuss a plan of action with the studentsOnce you are confident you have a comprehensive picture of the situation, discuss a plan of action with the student/s. Refer to your school's policy in terms of expectations and implications.  Invite suggestions from students as appropriate.  Inform all students involved of your intention to inform their parents/guardians. Involve the parents and other caregivers in developing the plan of action if appropriate.
4. Inform the students what you intend to do and contact the parent/ carer to adviseProvide as much information as you can without violating the privacy of other students or parents. Also inform them about when you are planning to follow up with them after implementing the plan. Explain that you will look at immediate and short-term responses as well as other long-term preventative measures or efforts to promote a positive school climate.
5. Provide suggestions about what to do if the bullying occurs againHave information on hand to share with students or set up a meeting for them to talk about strategies with an appropriate staff member. If this is not viable (due to the nature of disclosure), refer to the appropriate guidelines and processes.
6. Set a date for follow up review/sBullying can require a sustained effort to prevent, particularly if situations are long standing. Reviews are critical to check in with students, and to ensure the school's efforts have not caused other problems or merely created a problem elsewhere.
7. Record the incident in school's data management systemProvision Lead to explore this for emerging patterns or concerns and take appropriate action at whole school level to target areas emerging.
8. Notify appropriate personnelRefer the matter to the young person’s key worker and responsible officer: Keighly Murphy, 
9. Contact the parent/guardian about the incident and the plan of actionIf parents/guardians have not yet been involved in the process of planning the course of action (Step 3), advise them of the incident and the resulting course of action, including referring to the school’s policy and guidelines. Refer parents to the responsible officer for further consultation if required.
10. Follow up with students over the next several weeks and monthIt is essential to be alert to ongoing bullying, particularly the possibility that the bullying can ‘reappear’ in another form sometime later.
Provision Leader should ensure that all staff are aware of the procedures to follow when responding to incidents of student bullying, and that these are regularly reviewed and updated if necessary. Training for staff and the support of the school principal for teachers in dealing with bullying incidents improves staff capacity and readiness to respond well. .  


Being Bullied: Advice for students SEE ABOVE

Know someone is being bullied? Advice for students see ABOVE

Advice for ParentsIf you observe any changes to behaviour, attitude, wellbeing in your young person and notify school.If you suspect they are being bullied inform the school immediately. School will listen and respond to your concerns as a priority.Please support your child by teaching them strategies to manage the bullying. School can advise on this or you can use the links in this policy. Fighting back is not to be recommended.Reassure your young person that this is not their fault and praise them for sharing.Discuss the school policy with the young person and reassure them that you trust the school to manage the bullying.
SUPPORT FOR THE VICTIM:Opportunity to talk with a trusted adult as and when neededTeaching strategies to manage the bullying now and if experienced again in the future using Comic strips and social stories.PSHE programme modified to tackle issues that may have arisen.Continued work to support self-confidence and self esteem
SUPPORT/ CONSEQUENCES FOR THE BULLY:Opportunity to talk with a trusted adult as to what happened, why they became involved. Explore if there are any reasons why they came to this course of action and support by teaching new ways to behave. Use of comic strips and social stories.Refer for additional counselling if required or appropriate.Inform parents or carers and offer support links and advice where required.Referral to the Behaviour policy for consequences to prevent further bullying. 

CYBER BULLYINGALTR recognise that the need to be part of a digital community is becoming more crucial and so part of the provision curriculum is to teach learners to manage IT in a safe and respectful way.  CYBER BULLYING ADVICE FOR YOUNG PEOPLE EXPERIENCING ITReport it and block people
If someone’s harassing or bullying you online, you can report it on the site or app. Even if someone else has reported it, making a report yourself can make it more likely the content will be removed. Do not reply to abusive messages or posts as this can make things worse.

Keep evidence
Keep a diary of what has been happening and when and take screenshots of online messages. This can help you prove what has been happening.Tell someone at school
If you are being bullied by people at school, your school has a responsibility to support you. If you have screenshots or evidence of what has been happening, show them to a teacher you trust.Practise being assertive
Being assertive means standing up for yourself without being aggressive. It can help you feel more confident and in control when someone is bullying you.


Get support from someone you trust
You do not have to cope with bullying alone. Talking to an adult you trust can help you to find ways to stop the bullying. If you don’t know who to talk to, talk to us.

Take a break from checking messages
It’s natural to want to see what people are saying when they’re bullying you. But taking time away from your phone or device, even for a few minutes, can help you to feel calmer.

Treat passwords Private
• Do not retaliate or reply to bullying
• Bullying is not against the law, but you may be able to talk to the police if someone commits a crime against you,

including:
•being violent or physically assaulting you
•sexually assaulting you
•stealing things from you
•bullying you because of your race, gender or sexual identity, or if you have a disability, this is hate crime
•sharing or threatening to share a naked image of you without your permission.

SUPPORTING SOMEONE WHO IS BEING BULLIED
It can be difficult to know where to start with helping someone who is being bullied. But just a few words of support and showing that you care can make a massive difference.Let them know you are there for them
Listening and letting someone who is being bullied know you are there if they want to chat can make a massive difference. Chatting to them regularly and saying you are there for them can help them feel less alone.

Help them to get support You could offer to go with them to report the bullying and help them think about what they want to say. Or you could help them report it on social media.Think before you like or comment on something: Liking, sharing, or commenting on a post designed to bully someone can make it more popular and visible, even if you are not supporting it. Do not respond to a post, even if you are not sure if it is meant to bully someone. Help to distract them
Help them to take their mind off things for a short while. You could watch a film, play sports or a game together. Be positive around people
Whether it is posting positive things online, or being friendly to people at school, being positive can help lots of people to feel better.
HELP IF YOU'RE CYBER BULLYING SOMEONE Bullying someone else is not okay. But if you are doing it and want to stop, there are things you can do:Recognise what you are doing is bullying
You might want to dismiss what is happened as just a joke or think that it is okay because you are not the only one. But sending nasty messages, sharing a post, or liking something that has been made to make someone feel bad, is bullying. It can be hard to accept this and we've got advice to help if you're feeling guilty.Delete and do not send any more posts or messages
Stop whatever you were doing to bully someone, do not post or share things and do not message the person. Go back and delete old posts or messages.Do not stay on group chats or pages
Even if you do not participate, if you stay on a group chat then you are encouraging other people.Say sorry
Apologise to the person you bullied or sent messages to. Offer them support if you can but respect their wishes if they do not want to talk to you.
Encourage others to stop bullying too
Talk to others who have been bullying and encourage them to stop. Sometimes it only takes one person to make a big change.Plans
Think about how you want to behave online in the future, and what you could do if you want to do this again. Try asking an adult for help if you're struggling with difficult feelings.

Key Safety Advice for Parents & Carers Be aware, your young person may as likely cyber-bully as be a target of cyber-bullying. Be alert to your child seeming distressed after using the internet or their mobile phone.  This might be changes in relationships with friends, secrecy about their online activities and mobile phone use. Be aware of and understand the ways in which they are using the internet and their mobile phone.  Use the tools on the service and turn on in-built internet safety features if vulnerable.Remind your child not to retaliate. Keep the evidence of bullying emails, text messages or online conversations. Report cyber-bullying with RISE or RISEX if it involves another student, so that they can take appropriate action. If the cyber-bullying is a potential criminal offence, you should consider contacting the police. Bullying is not against the law, but you may be able to talk to the police if someone commits a crime against you, including:being violent or physically assaulting yousexually assaulting youstealing things from youbullying you because of your race, gender or sexual identity, or if you have a disability, this is hate crimesharing or threatening to share a naked image of you without your permission.


Anti-Bullying Policy  

Rationale
Today’s young people are growing up in an increasingly complex world where lives are lived both on and offline. This has positive and exciting opportunities, but also risks and challenge. With this in mind, it is imperative that we teach our young people how to be happy, safe, and healthy, and how to manage their academic, personal, and social lives positively.
Teaching wellbeing is central to the work that we undertake at RISE and RISEX, understanding innate health and wellbeing is key to happiness and balance. With this in place students will be more resilient and better equipped to manage the increasing challenges, risks and disappointments that live can present. We hope to develop character and personal attributes.
ALTR RISE have adopted guidance from the Department of Education issued under Section 80A of the Education Act 2002 and section 403 of the Education Act 1996 when teaching Relationships Education, Relationships and Sex education (RSE) and Health Education. This replaces Sex and relationships guidance (2000).When teaching Relationships Education, Relationships and Sex Education (RSE) and Health Education, the depth and breadth of views is apparent, and often there are legitimate areas of contention. At ALTR our guiding principles have been that all of the content taught must be age appropriate and developmentally appropriate. It will be taught sensitively and inclusively, with respect to the backgrounds and beliefs of young people and their families. WE will however always provide young people with the knowledge they need of the law.
We understand that parents and carers are the prime educators on these topics however we will build on that knowledge and understanding and give opportunity for the young people to ask questions and share thoughts and opinions and for us to be adapt the curriculum to address the needs emerging in the school and local community.
Alongside this is Financial capability and awareness, life and living skills and Digital citizenship all geared towards independence, meeting ambitions and careers pathways; enabling all young people to be happy, successful adults who have meaning in their own lives and offer meaningful contribution to society. 
Relationships Education, Relationships and Sex Education (RSE) 
Subjects offered to young people are carefully designed to safeguard young people and build knowledge with life skills that will prepare them for issues that they may need to face in the coming years. This programme is about lifelong learning about physical, moral, and emotional behaviour and enabling young people to keep safe and make informed decisions. At ALTR our guiding principles have been that all of the content taught must be age appropriate and developmentally appropriate. It will be taught sensitively and inclusively, with respect to the backgrounds and beliefs of young people and their families. WE will however always provide young people with the knowledge they need of the law.
Broad Pillars taught across the full RSE and PSHE curriculum are:
different types of relationships, including friendships, family relationships, dealing with strangers and, at secondary school, intimate relationshipshow to recognise, understand and build healthy relationships, including self-respect and respect for others, commitment, tolerance, boundaries, and consent, and how to manage conflict, and how to recognise unhealthy relationshipshow relationships may affect health and wellbeing, including mental health  healthy relationships and safety online; and factual knowledge, at secondary school, around sex, sexual health, and sexuality, set firmly within the context of relationships.
PSHE
Work taught falls under the broad pillars of:healthy bodies and lifestyles, including keeping safe, puberty, drugs, and alcohol educationhealthy minds, including emotional wellbeing, resilience, mental healtheconomic wellbeing and financial capabilitycareers education, preparation for the workplace and making a positive contribution to society.Staff teaching this programme receive training and guidance and it is delivered by a variety of professionals to include school nurses, police, employers, employees, local services, and providers.
Relationships Education, Relationships and Sex Education (RSE)RISE are aware that the content of our course may well have already been covered at Secondary level. We anticipate that our young people will have made developmental and academic progress that may enable them to understand more clearly the content of the programme. In addition, they may be at different places in their lives socially and may now have some understanding of context to the content.Teachers and staff delivering the RSE programme will be given appropriate training and guidance and may be supported by community resources to include school nurses and other health professionals.Information for Parents/ carersAll parents and carers are made aware of the content of the curriculum being taught prior to delivery. Understanding what the young people are learning enables parents and carers to monitor young people’s response to the sessions, but also to answer any questions that they may have. To embed learning, it is also beneficial to transfer learning to a home and social context.Right to WithdrawParents and carers have the right to withdraw their child from sex education elements of the RISE RSE curriculum and we will then make alternative arrangements for the young people involved. Any requests to withdraw students should be made in writing to the Provision Lead.  The Circular 5/94 Education Act 1993: Sex Education in Schools states that teachers are not given consent to withdraw themselves from involvement in sex education lessons but if a teacher has concerns, they will be supported with further training. Following this if a teacher has the same reservations and concerns alternative provision will be made.Monitoring and EvaluationIt is crucial that our programme reflects the needs of the young people and emerging issues in the community. It will there for be reviewed regularly to ensure its appropriateness and that it continues to meet changing guidelines.
We will also monitor impact of the programme with feedback from young people, staff and other parents and carers.
Appendix A Curriculum Overview

Relationships Education, Relationships and Sex Education (RSE)
ALTR realise that areas of the Secondary curriculum may need revisiting to embed content for the young people with whom we work. As a result, we are adopting the Statutory Guidance from the government as to the content of our Relationships education. The aim is to give information young people need to help them develop healthy relationships of all kinds, not just intimate relationships. The programme will help the young people to understand the benefits that a healthy relationship can bring to mental wellbeing and self-respect.Topics to be covered:FamiliesRespectful relationships including friendshipsOnline and mediaBeing safePhysical health and mental wellbeingIntimate and sexual relationships including sexual healthThe LawTo explore the content of the RISE Relationship Education in greater detail please see Programme Relationships Education, Relationships and Sex Education (RSE) and Health Education Government Guidance. PDF CLICK HERE
Careers EducationEvery young person needs high quality careers guidance to make informed decisions about their future pathways. In order to offer the greatest provision, we can, we are committed to achieving the 10 recommendations stated in The Good careers’ guidance Report. https://www.gatsby.org.uk/uploads/education/reports/pdf/gatsby-sir-john-holman-good-career-guidance-2014.pdf
8 Gadsby Benchmarks followed by RISE
A stable career programmesLearning from career and labour market information through the ‘LMI for all’ Service.Addressing the need of each young personLinking curriculum learning to careers Encounters with employers, employees, and Review of encounters.Encounters with and the workplace and Review of encounters.Encounters with further and higher education and Review of encounters. Personal guidanceWe believe that this is particularly important for vulnerable adults or those with special educational needs where in order to make informed decisions they need to see, hear, feel what is available to them. RISE are fortunate enough to be based amid a variety of employers and employees and opportunity to experience a variety of vocations.RISE has a clear careers Plan demonstrates how we will achieve the benchmarks and good destination data.We have a member of the governing body who has the remit of encouraging employer engagement and have a strategic interest in careers guidance. 



Statement of Procedures for
Dealing with Allegations of Abuse
against Teachers and Other Staff and Volunteers

Statement of Procedures for Dealing with Allegations of Abuse against Teachers and Other Staff and Volunteers Introduction This Statement of Procedures follows the DfE Statutory Guidance Keeping Children Safe in Education Part four: Allegations of abuse made against teachers and other staff (Appendix 1) which is available from the provision website. It is about managing cases of allegations that might indicate that a person is unsuitable to continue to work with children in their present position, or in any capacity.  It will be used in respect of all cases where it is alleged that an employee or volunteer, or a person with permission to be on the premises or carrying out any activity on behalf of ALTR, RISE and RISEX has:Behaved in a way that has harmed a child, or may have harmed a childPossibly committed a criminal offence against or related to a childBehaved towards a child or children in a way that indicates he or she would pose a risk of harm to children. This will include allegations involving any type of abuse or neglect, including inappropriate relationships with pupils, grooming behaviour of any kind, possession of indecent photographs or images of children and other offences under the Sexual Offences Act 2003. 1.2. Any allegation of abuse will be dealt with as quickly as possible, in a fair, consistent and thorough way that provides effective protection for the child or children whilst acting fairly with the person who is the subject of the allegation. 2. Communicating the Procedures2.1. All members of the senior management team and the designated safeguarding lead with responsibility for child protection have a responsibility to ensure that all staff know about and understand paragraph 3 below. 2.2. In accordance with the DfE Statutory Guidance, all staff should also read and sign confirmation to accept responsibility to understand and follow Part one of Keeping children safe in education, which contains Safeguarding information for all staff 2.3. All members of the Management team and the designated safeguarding lead have a responsibility to be familiar with the Statutory Guidance in its entirety. 3. Immediately Reporting an Allegation 3.1. Everyone who encounters children and their families has a role to play in safeguarding children.  If you have a concern that a person (as described in paragraph 1.1 above) may have behaved inappropriately or you have received information that may constitute an allegation you must: Report the facts to the Safeguarding Lead: Keighly Murphy, Provision lead as soon as possible.  All concerns will be listened to and managed appropriately; do not withhold information however trivial it may seem.   In the absence of Keighly Murphy you must report the matter to the most senior person available who will carry out the Case Manager’s duties in his/her absence.  If the allegation concerns the Provision Lead, then the matter must be reported to the Chair of Governors. Make a signed and dated written record of your concerns, observations or the information you have received and give it to the allocated persons immediately.Maintain strict confidentiality. 3.2. You must not: Attempt to deal with the situation yourself. Make assumptions, offer alternative explanations or diminish or embellish the seriousness of the behaviour or alleged incidents. Keep the information to yourself or promise confidentiality. Take any action that might undermine any investigation or disciplinary procedure, such as disclosing confidential information, interviewing the alleged victim or potential witnesses, or informing the alleged perpetrator or parents/carers. 4. Duties and Responsibilities of the Case Manager 4.1. The duties and responsibilities of the Case Manager are as described in Keeping Children Safe in Education Part four: Allegations of abuse against teachers and other staff. 4.2. The contact details for the Designated Officer for Safeguarding are:
Keighly Murphy Provision and Safeguarding Lead 


Safeguarding, Child Protection
and Vulnerable adults Policy

Summary This Policy is written in line with the statutory guidance from the Department for Education (the department) issued under Section 175 of the Education Act 2002, the Education (Independent School Standards) Regulations 2014, and the Non-Maintained Special Schools (England) Regulations 2015. As an educational setting ALTR must have regard to it when carrying out our duties to safeguard and promote the welfare of children.For the purposes of this Policy children includes everyone under the age of 18 and adults from the age of 18 onwards.
About this guidance We use the terms “must” and “should” throughout the guidance. We use the term “must” when the person in question is legally required to do something and “should” when the advice set out should be followed unless there is good reason not to. The guidance should be read alongside:  • statutory guidance Working Together to Safeguard Children• departmental advice What to do if you are Worried a Child is Being Abused - Advice for Practitioners.  
This Policy is intended to cover all Board Members, Employees, Volunteers, Learners, Link organisations and Employers.  
1. Objectives 1.1. To ensure that all children, young people, and vulnerable adults who are involved in activities, training, events and placements facilitated by ALTR are effectively safeguarded in accordance with Keeping children safe in education Statutory guidance for schools and colleges September 2019. 1.2. To ensure that all ALTR employees, visitors and volunteers are aware of and are undertaking full and correct safeguarding procedures in line with Keeping children safe in education Statutory guidance for schools and colleges 2019. This includes the identification, recording and reporting of suspected cases of abuse, Female Genital Mutilation (FGM), extremism and radicalisation. 1.3. To ensure that ALTR remains up to date with legislation and practice relating to safeguarding. 1.4. To raise awareness and actively promote the principles of safeguarding and well-being throughout any ALTR activities. 1.5. To work in partnership with board members, children, young people, vulnerable adults, their parents, carers and other agencies and key stake holders to ensure effective implementation of this Policy.  
2. Scope  2.1. To cover any activity undertaken with ALTR2.2. To cover all activities carried out by learners, volunteers, employees, board members and employers.2.3. ALTR link organisations and working partnerships in other settings will need to provide their own Child Protection / Safeguarding Policies, which includes preventing extremism and radicalisation.  No alternative setting will be accessed unless adequate safeguarding measures are in place. Students will always be covered by ALTR Policy and procedure. 
3. Key Principles  3.1. For the purpose of this document, ‘individual’ or ‘individuals’ refers to all individuals working with, or in contact with, children, young people, or vulnerable adults at any time as part of their employment. This includes staff, volunteers, employers, consultants, visitors, and learners. All employers who have learners on learning programmes with ALTR are required to comply with the safeguarding policy. 3.2. ALTR is passionately committed to a child and vulnerable adult centred approach to safeguarding in all relevant aspects of its teaching and learning, employment training and business. ALTR is committed to ensuring the legal requirements and guidance are adhered to and widely promoted. Health, wellbeing, and safety is of paramount importance for all service users.3.3. ALTR will ensure that all individuals that have direct contact with children, young people, or vulnerable adults as part of their employment, working with ALTR in any other capacity, will have enhanced Disclosure and Barring Service (DBS) clearance. They will display this by wearing the appropriate coloured identity badge. 3.4. External Speakers and Visitors to ALTR without DBS clearance will always be supervised in the company of all learners and wear the appropriately coloured identity badge as a visual notice to all.3.5. Referral and reporting procedures will be in place and strictly adhered to in the event of any concerns relating to the abuse of children, young people, and vulnerable adults. 3.6. ALTR staff will maintain up-to-date knowledge of safeguarding practice and procedures, extended to include the Prevent agenda with training annually and updates as and when required by the designated safeguarding lead.3.7. ALTR prioritises the welfare of children, young people, and vulnerable adults.3.8. ALTR will work alongside all related agencies, companies, bodies, and providers in order to promote and maintain the highest standards of safeguarding. 
3.9. ALTR will comply with all applicable regulations set out in. The Protection of Children’s Act 1999.  The Safeguarding Vulnerable Groups Act 2006.  The Children’s Act 2004.   The Education Act 2002. The Sexual Offences Act 2003. The Protection of Freedoms Act 2012. Keeping Children Safe in Education. The Counterterrorism & Security Act 2015. The Modern Slavery Act 2015 Government Guidance – Sexual violence and sexual harassment between children in schools and colleges.  
4. Designated Persons   Keighly Murphy – Safeguarding and Well-being Manager Email: keighly@altrrise.comLianne Bedden – Deputy Designated Safeguarding Lead Email: Lianne@altrrise.com
5. Roles & Responsibilities  5.1. Safeguarding Leads a key duty for raising awareness across all staff of issues relating to the welfare of children, young people, and adults at risk.   5.2. The post holder is required to have training in safeguarding issues and inter-agency working, receiving refresher training at least every two years or as and when any new issues arise. Safeguarding Lead is responsible for:  Overseeing the referral of cases of suspected abuse or allegations to the relevant investigating agencies using MyConcern.  Providing advice and support to other staff on issues relating to safeguarding. Maintaining a detailed and accurate record of any child protection referral, complaint, or concern (even where that concern does not lead to a referral).  Liaising with the Local Authorities and other appropriate agencies. Supporting Heads of Centre and liaising with educational establishments and secondary schools that send pupils to RISE or access any of ALTR brand events, to ensure that appropriate arrangements are made for learners. Liaising with employers and training organisations that receive children or young people from ALTR on block placement work experience or long-term placements to ensure that appropriate safeguarding policies are put into place. Ensuring that staff will receive training in safeguarding issues appropriate to their roles and are aware of ALTR safeguarding procedures.  Advising the Directors on efficiency and adequacy of resources and training being available to implement this policy. Ensuring arrangements are made to bring this policy to the notice of all employees, volunteers, employers, sub-contractors, and visitors. The policy and its arrangements are regularly reviewed during ALTR Safeguarding Quality Improvement Groups.  5.3. Within ALTR other designated staff that hold a responsibility for safeguarding and are employed with ALTR are TBC. These designated staff: Report to the Safeguarding Lead, who has lead responsibility.  Know how to make an appropriate referral. Are available to provide advice and support to staff on issues relating to safeguarding. Are available to listen and respond appropriately to children, young people, vulnerable adults Looked After Children (LAC) and adults at risk studying within ALTR. Deal with individual cases, including attending case conferences and review meetings as appropriate. 5.4. The designated Chair of Board, Lianne Bedden, is responsible for liaising with the Directors and the Safeguarding Lead over matters regarding safeguarding, including:  Ensuring ALTR has procedures and policies in place which are consistent with guidelines. Ensuring the Board considers the organisation’s policy on safeguarding each year. Ensuring that each year the Board is informed of how ALTR and its staff have complied with the policy, including, but not limited to a report on the training that staff have undertaken. The designated Chair of Board is responsible for overseeing the liaison between agencies, e.g. Police, Social Services in connection with allegations against the Director. This will not involve undertaking any form of investigation but will ensure good communication between the parties and provide information to assist enquiries.   5.5. Directors have overall responsibility for all matters relating to Safeguarding and will refer any cases of suspected abuse or allegation, to relevant investigating agencies as agreed with the Local Safeguarding Board. The Director will: Ensure that all employees have knowledge and understanding of safeguarding and that it is taken seriously.  Ensure that appropriate child protection and safeguarding policies are adopted, implemented, and monitored. Ensure that, where services or activities are provided by sub-contractors or another body, the body concerned has appropriate safeguarding policies and procedures. Foster a culture of openness and support. Ensure that all employees feel able to raise concerns about poor or unsafe practice and such concerns are handled sensitively and in accordance with the whistle blowing procedure. Acknowledge and discuss any concerns about any members of staff. Ensure that the use of new and existing media technologies does not expose learners to any potential harm during their educational hours with ALTR. Work with the IT Coordinator to ensure safeguarding when using digital media and the internet in the education of our learners. Ensure that ALTR has access to the external and internal resources to offer extensive support around Child Protection and Safeguarding. Monitor the processes for promoting learner welfare and safeguarding to ensure that adequate resources are given to it, including staff training.  Work with the Safeguarding Lead to ensure procedures are in place to ensure that learners requiring safeguarding measures are monitored in relation to their situation and progress with their learning.  Report to the Board at each Board meeting.  Ensure that all recruitment procedures follow Safer Recruitment Guidance. Ensure that learners’ safety and welfare is addressed through the curriculum.   Director is responsible for referring cases of suspected abuse or allegations to the Local Authority Designated Officer (LADO) (see Allegations of Abuse Against Staff Policy). Director is responsible for dealing with allegations made against members of staff.
6. Child Welfare  6.1 ALTR recognises the need to prioritise the welfare of children, young people, and vulnerable adults with which it works. These are defined as follows: A child is anyone who is 18 years or younger. A young person is anyone who is 19 but has not reached their 20th Birthday. A vulnerable adult is someone who is aged 18 years or over, who is, or may be, in need of community care services by reason of SEND, mental health, or other disability, age or illness. They may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation. Individuals will always operate in line with this safeguarding policy.
6.2 ALTR considers abuse of any kind, neglect, maltreatment, aggressiveness, intimidation, and bullying, all as damaging to the welfare of a child, young person or vulnerable adult. 6.3 Complaints or concerns relating to individuals working with ALTR will be reported to the Director immediately. ALTR’s Whistleblowing Policy or Data Protection Policy do not prevent information sharing with investigating agencies where the information will help to safeguard welfare. ALTR will refer concerns that a child, young person, or vulnerable adult might be at risk of significant harm to Social Care Services/Police or the appropriate agencies as agreed with the relevant Local Safeguarding Board. 6.4 Individuals will be offered training that will help to make them aware of possible signs of abuse/exploitation and act appropriately. 6.5 Children, young people and vulnerable adults will always be respected and encouraged to interact in both formal (evaluation and feedback) and informal (spoken word) communication where possible. 6.6 Individuals will maintain appropriate relationships with children, young people, and vulnerable adults, reducing physical contact and one-on-one situations to the minimum practicable level. 6.7 Individuals will endeavour to avoid being alone with a child, young person, or vulnerable adult whenever in a closed room. Doors will always remain open when lone working. The Safeguarding Lead, when receiving safeguarding disclosures, will work in accordance with the Lone Working Policy. 6.8 ALTR recognises the right of children, young people, vulnerable adults, and/or their parents/guardians, to withdraw from featuring in promotional material, either on video or in photographs. opt out forms will be prioritised and strictly adhered to in relevant situations. 6.9 Peer on Peer abuse: ALTR’s procedures for minimising the risk of Peer on Peer abuse, ensure learners are issued with: Learner code of conduct Learner handbook, contain the contact details for the Safeguarding and Wellbeing Manager and Centre Designated Safeguarding Leads and Deputy Safeguarding Leads Anti-bullying Policy Safeguarding, Child Protection and Vulnerable Adults Policy All learners receive a face-to-face safeguarding induction with Safeguarding Lead when they enrol at ALTR, which addresses Peer on Peer abuse. 
7. Children who may be particularly vulnerable  7.1. Some children may have an increased risk of abuse. Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues and reluctance on the part of some adults to accept that abuse can occur. LAC are particularly vulnerable as the most common reason for children becoming looked after is because of abuse and/or neglect. ALTR will ensure that employees have the skills, knowledge and understanding necessary to keeping LAC safe. In particular, they will ensure that appropriate employees have the information they need in relation to a child’s looked after legal status and contact arrangements with birth parents or those with parental responsibility. They will also have information about the child’s care arrangements and the levels of authority delegated to the carer by the authority looking after him/her.  7.2. To ensure that all children, young person, or vulnerable adult working alongside ALTR receive appropriate protection, we will give special consideration to those who are:   Disabled or have Special Education Needs Living in a domestically abusive situation Affected by parental substance misuse Asylum seekers Regularly absent from school Living away from home (frequent movers) Vulnerable to being bullied, or engaging in bullying Living in temporary accommodation Living a transient lifestyle Living in chaotic and unsupportive home situations Vulnerable to discrimination and maltreatment on the grounds of race, ethnicity, religion, or sexuality  Involved directly or indirectly in prostitution or child trafficking Speakers or another first language Children that are subject to a Full Care order (LAC), Child Protection Plan or Children in Need Plan  Children that may be vulnerable to messages of violence and extreme ideologies and radicalisation  Peer on Peer abuse  Allegations of Peer on Peer abuse, within ALTR, will be investigated. This will include meetings between the Safeguarding Lead, the class teacher, the Learner and their Parent(s)/Carer(s) and any relevant external agencies. This is in line with ALTR’s Support Policy, including the disciplinary process.  The victim, perpetrator and any other learner affected by Peer on Peer abuse will be supported in accordance to the Support Policy. Both victims and perpetrators will be dealt with on a case by case basis, taking into account circumstances and individual needs.  
8. Definitions and categories of abuse  ALTR recognises the following as definitions of abuse; physical, emotional, neglect, and sexual with the additional categories of acts of omission, psychological, financial, or material, institutional, or professional abuse.   Someone may abuse or neglect a child or young person by inflicting harm, by failing to act to prevent harm, or by failing to ensure safety and adequate care. Harm may occur intentionally or unintentionally. Children may be abused in a family, an institution or community setting, by those known to them, or by a stranger. Examples of abuse are set out below these examples are by no means exhaustive.  
8.1. Physical abuse 
 A form of abuse which may involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Possible signs of physical abuse include:  Any injuries not consistent with the explanation given for them.  Injuries which occur to the body in places which are not normally exposed to falls or rough games.  Injuries which have not received medical attention.  Reluctance to change for, or participate in, games or swimming. Bruises, bites, burns, and fractures, for example, which do not have an accidental explanation.  The child gives inconsistent accounts for the cause of injuries.   
8.2. Emotional abuse The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone. Possible signs of emotional abuse include:  Depression, aggression, extreme anxiety, changes or regression in mood or behaviour, particularly where a child withdraws or becomes clingy.  Obsessions or phobias.  Sudden underachievement or lack of concentration.  Seeking adult attention and not mixing well with other children.  Sleep or speech disorders.  Negative statements about self.  Highly aggressive or cruel to others.  Extreme shyness or passivity.  Running away, stealing, and lying.   
8.3. Neglect  The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment.  It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. Possible signs of neglect include:  Dirty skin, body smells, unwashed, uncombed hair, and untreated lice.  Clothing that is dirty, too big, or small, or inappropriate for weather conditions.  Frequently left unsupervised or alone.  Frequent diarrhoea.  Frequent tiredness. Untreated illnesses, infected cuts, or physical complaints which the carer does not respond to. Frequently hungry.  Overeating junk food.  
8.4. Sexual abuse  Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening.  The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.  Possible signs of sexual abuse include:  The child has an excessive preoccupation with sexual matters and inappropriate knowledge of adult sexual behaviour for their age, or regularly engages in sexual play inappropriate for their age.  Sexual activity through words, play or drawing.  Repeated urinary infections or unexplained stomach pains.  The child is sexually provocative or seductive with adults. Inappropriate bed-sharing arrangements at home. Sleep disturbances with fears, phobias, vivid dreams, or nightmares which sometimes have overt or veiled sexual connotations.  Eating disorders such as anorexia or bulimia.   
8.5 Domestic Abuse/Violence The cross-government definition of abuse is: “Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality. This can encompass but is not limited to the following types of abuse: psychological physical sexual financial emotional Controlling behaviour is: a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour. Coercive behaviour is an act or a pattern of acts of assault, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten their victim.” * This definition, which is not a legal definition, includes so called ‘honour’ based violence, female genital mutilation (FGM) and forced marriage, and is clear that victims are not confined to one gender or ethnic group.” (GOV.UK) Exposure to Domestic Abuse and/or Violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family as a result. Domestic Abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life. 
8.6 Bullying and Cyberbullying Cyberbullying is bullying that takes place over digital devices, such as mobile phones and internet use through computers, laptops, and tablets. Cyberbullying can occur through SMS, Text, and Apps or online with social media, forums, or gaming, where people can view, participate in, or share content. Cyberbullying includes sending, posting, or sharing negative, harmful, false, or mean content about someone else. It can include sharing personal or private information or images about someone else causing embarrassment and humiliation. Some Cyberbullying crosses the line into unlawful or criminal behaviour. See ALTR’s Anti-Bullying Policy for further information. The most common places where Cyberbullying takes place: Social Media, such as Facebook, Instagram, Snapchat, and Twitter SMS (short Message Service) also known as a ‘text message’ sent through devices. Instant Messaging (via devices, email provider services, Apps, and social media messaging features) Email 
8.7 Child Criminal Exploitation – County Lines  Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money (on occasions weapons) from urban areas to suburban and rural areas, market and seaside towns. The key to identifying potential involvement in county lines are missing episodes, where the victim may have been trafficked for the purpose of transporting drugs. Like other forms of abuse and exploitation, county lines exploitation: Can affect any child or young person (male or female) under the age of 18 years; Can affect any vulnerable adult over the age of 18 years; Can still be exploitation even if the activity appears consensual;  Can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;  Can be perpetrated by individuals or groups, males and females, and young people or adults; and Is typified by some form of power imbalance in favour of those perpetrating the exploitation.  Whilst age may be the most obvious, the power of imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources.  
8.8 Child Sexual Exploitation Child Sexual Exploitation (CSE) is a form of child sexual abuse. It can affect any child or young person (male or female) under the age of 18 years, including 16- and 17-year olds who can legally consent to have sex.    CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants (for example food, accommodation, drugs, alcohol, gifts, money or in some cases simply affection), and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship, where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups.   Sexual exploitation involves varying degrees of coercion, intimidation, or enticement, including unwanted pressure from peers to have sex and sexual bullying. CSE does not always involve physical contact; it can also occur through the use of technology; cyber bullying and grooming.   However, it is also important to recognise that some young people who are being sexually exploited do not exhibit any external signs of this abuse. The victim may have been sexually exploited even if the sexual activity appears consensual.   
8.9 Peer on Peer Abuse When considering if a behaviour between a child or young   person to another child or young person has been abusive it is important to consider; whether there is a large difference in power (for example age, size, ability, development between the young people concerned); or whether the perpetrator has repeatedly tried to harm one or more other children; or whether there are concerns about the intention of the alleged perpetrator. Peer on Peer abuse can manifest itself in many different ways and different gender issues can be prevalent.  Severe harm may be caused to children by abusive and bullying behaviour of other children, which may be physical, sexual, or emotional (blackmail/threats) and can include gender based violence/sexual assaults, sexting, teenage relationship abuse, peer on peer exploitation, serious youth violence, sexual bullying, harmful sexual behaviour, cyber bullying, initiations, and showing prejudice in race, religion or disability.    All Peer on Peer abuse is unacceptable and will be taken seriously, regardless of the gendered nature of abuse.  Peer on Peer abuse is categorised under ‘abuse’ and should never be tolerated or passed off as ‘banter’, ‘just having a laugh’ or ‘part of growing up’.  
8.10 Teenage Relationship Abuse This is a pattern of abusive behaviours over a course of time used to exert power and control over a dating partner.  Violent words and actions are tools an abusive partner uses to gain and maintain power and control over their partner.  Types of abuse include emotional, verbal, physical, financial, sexual, stalking, and digital (using technology to threaten, stalk, intimidate or bully).  
8.11 Sexual Violence and Sexual Harassment between children in schools and colleges  When referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003 as described below:  Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents.  Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents. A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents. Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g. to vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal, or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.  Further information on consent:  a child under the age of 13 can never consent to any sexual activity; the age of consent is 16; sexual intercourse without consent is rape.  Sexual Harassment: When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of child on child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded, or humiliated and/or create a hostile, offensive, or sexualised environment.  Whilst not intended to be an exhaustive list, sexual harassment can include:  sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance, and calling someone sexualised namessexual “jokes” or taunting;  physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (ALTR will consider when any of this crosses a line into sexual violence - it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include:non-consensual sharing of sexual images and videossexualised online bullyingunwanted sexual comments and messages, including, on social mediasexual exploitation; coercion and threats.  It is important that staff consider sexual harassment in broad terms. Sexual harassment (as set out above) creates an atmosphere that, if not challenged, can normalise inappropriate behaviours and provide an environment that may lead to sexual violence.  
8.12 Honour Based Violence  So-called ‘honour based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including forced marriage, Female Genital Mutilation (FGM) and practices such as breast ironing. All forms of so-called HBV are abuse (regardless of the motivation) and must be reported immediately.   
8.13 Forced Marriage A forced marriage is a marriage without the full consent of both parties and where pressure or threats are a factor. This is quite different to an arranged marriage, which both people will have agreed to. Emotional pressure from their family might stop them from saying anything to anyone else. The lack of control over their own decisions can lead to depression and self-harm. Signs and indicators of concern: Truancy / absence from school. Low Motivation. Lack of Punctuality. Self-Harm. Depression. Isolation. Attempted Suicide.Eating Disorders. Brother/Sisters forced to marry or reported missing. Family disputes. Runaways. Domestic violence. Substance misuse. While many of these signs and indicators could be linked to their issues, it is important to consider all potential reasons and keep an open mind. Honour Based Abuse and Forced Marriages are a fundamental abuse of human rights. As of 16th June 2014, changes to legislation made Forced Marriages a criminal offence. Remember the ‘One Chance Rule’. 
If someone you know is at risk: Contact the Forced Marriage Unit (FMU) if you know someone who has been taken abroad to be forced into marriage. Give as many details as you can, for example: where the person has gone when they were due back when you last heard from them  The FMU will contact the relevant embassy. If they are a British national, the embassy will try to contact the person and help them get back to the UK if that is what they want.   
8.14 Female Genital Mutilation:  Female genital mutilation (sometimes referred to as female circumcision or ‘cutting’) refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. The practice is illegal in the UK. It has been estimated that over 65,000 girls under the age of 13 are at risk of female genital mutilation (FGM) in the UK each year, and that 170,000 women and girls in the UK are living with the consequences of FGM. However, the true extent is unknown, due to the "hidden" nature of the crime. Females may be taken to their countries of origin so that FGM can be carried out during the summer holidays, allowing them time to "heal" before they return to school. There is evidence that girls have now undergone this FGM in the UK.  Risk Factors: A child talking about a special ceremony. A young person talking about being ‘cut’. A child belonging to certain communities. Planning an extended trip abroad. Knowledge of previous siblings. Indicators it may have taken place: Prolonged absence. Change in behaviour on returning from an extended holiday. Urinary infections, bladder, or menstrual problems. Describing pain in the groin. Avoiding physical activity. Appears uncomfortable including when sitting. Finds it difficult to sit still. Talking about something happening to them or someone hurting them and having to keep a secret.  Making a Report The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crime Act 2015). The legislation requires Teachers in England and Wales to make a report to the police where, in the course of their professional duties, they either: are informed by a girl under 18 that an act of FGM has been carried out on her; or  observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth  For the purposes of the duty, the relevant age is the girl’s age at the time of the disclosure/identification of FGM (i.e. it does not apply where a woman aged 18 or over discloses she had FGM when she was under 18).   Complying with the duty does not breach any confidentiality requirement or other restriction on disclosure which might otherwise apply. The duty is a personal duty which requires the Teacher who becomes aware of the case to make a report; the responsibility cannot be transferred. The only exception to this is if you know that another individual from your profession has already made a report; there is no requirement to make a second. For staff that are not teachers, reports concerning FGM must be made directly to Safeguarding Lead who will make any necessary reports directly to the Police.  Where there is a risk to life or likelihood of serious immediate harm, professionals should report the case immediately to police, including dialling 999 if appropriate.  
8.15 Recognising Young People Who May Be Affected by Gang Activity  Gang involvement is a multi-agency issue; partnership working, and information sharing is therefore a key to safeguarding children, young people, vulnerable adults at risk of gang-related harm. Children, young people, vulnerable adults are put at risk by gang activity both through participation in and as victims of gang violence. Learners particularly vulnerable to suffering harm in the gang context are those who are: Not involved in gangs but living in an area where gangs are active.  Not involved in gangs, but at risk of becoming victims of gangs; by way of truanting from education, permanent exclusion from school/college or having been a victim of abuse or neglect. Not involved in gangs but at risk of becoming drawn in, for example, siblings or children of known gang members; or Gang-involved and at risk of harm through their gang-related activities (e.g. drug supply, weapon use, sexual exploitation, and risk of attack from own or rival gang members). Victims and offenders are often the same people. When adults treat a young person as just a victim or just an offender, they are not taking into account the complex, cyclical nature of the victim-offender link and the factors that influence young people’s lives. There are particular risk factors and triggers that young people experience in their lives that can lead to them becoming involved in gangs. Many of these risk factors are similar to involvement in other harmful activities such as youth offending or violent extremism.  Risk factors for a person becoming involved in gangs may include: Becoming withdrawn from familySudden loss of interest in education - decline in attendance or academic achievementStarting to use new or unknown slang wordsHolding unexplained money or possessionsStaying out unusually late without reasonSudden change in appearance - dressing in a particular style or ‘uniform’Dropping out of positive activitiesNew nicknameUnexplained physical injuriesGraffiti style tags on possessions, schoolbooks, wallsConstantly talking about another young person who seems to have a lot of influence over themBroken off with old friends and hanging around with a new group Increased use of social networking sitesStarting to adopt codes of group behaviour e.g. ways of talking and hand signsExpressing aggressive or intimidating views towards other groups of young people some of whom may have been friends in the pastBeing scared when entering certain areasBeing concerned by the presence of unknown youths in their neighbourhood.  This is not an exhaustive list and should be used as a guide, amended as appropriate in light of local knowledge of the risk factors in a particular area.  
8.16 Contextualised Safeguarding  Contextualised Safeguarding is an approach to understanding, and responding to, young people’s experiences of significant harm beyond their families. It recognises that the different relationships that young people form in their neighbourhoods, schools and online can feature violence and abuse. Parents and Carers have little influence over these contexts, and young people’s experiences of extra-familial abuse can determine parent-child relationships.   Link to further information: https://contextualsafeguarding.org.uk/about/what-iscontextual-safeguarding  
8.17 Recognising extremism and radicalisation  The following guidance is written with regard to the Home Office guidance “Channel: Protecting Vulnerable People from Being Drawn into Terrorism” and “Channel: Vulnerability Assessment Framework”.   Engagement: Example needs, susceptibilities, motivations and contextual influences that make individuals vulnerable to engagement with an extremist group, cause or ideology include:Feelings of grievance and injustice.  Feeling under threat.  A need for identity, meaning and belonging. Desire for status.  A desire for excitement and adventure.  A need to dominate and control others.  Susceptibility to indoctrination. A desire for political or moral change.  Opportunistic involvement.  Family or friend’s involvement in extremism.  Being at a transitional time of life. Being influenced or controlled by a group. Relevant mental health issues.  Pre-existing conviction that their religion / culture is under threat.   
Example indicators that an individual is engaged with an extremist group, cause or ideology include:  Spending increasing time in the company of other suspected extremists.  Changing their style of dress or personal appearance to accord with the group.  Their day-to-day behaviour becoming increasingly centred on an extremist ideology, group, or cause.  Loss of interest in other friends and activities not associated with the extremist ideology, group, or cause.  Possession of material or symbols associated with an extremist cause (e.g. the swastika for far-right groups). Attempts to recruit others to the group/cause/ideology.  Communication with others that suggest identification with a group/cause/ideology.Increased Social Media use, changes in their profile/image or name and being overly secretive about it. Extremist groups/individuals use social media to recruit those vulnerable to radicalisation.  Intent to cause harm: Not all those who become engaged by a group, cause or ideology go on to ALTR an intention to cause harm, so this dimension is considered separately.  Intent factors describe the mind-set that is associated with a readiness to use violence and address what the individual would do and to what end. They can include:  Over-identification with a group or ideology.  ‘Them and Us’ thinking.   Dehumanisation of the enemy.  Attitudes that justify offending.  Harmful means to an end.  Harmful objectives.  Example indicators that an individual has an intention to use violence or other illegal means include:  Clearly identifying another group as threatening what they stand for and blaming that group for all social or political ills.  Using insulting or derogatory names or labels for another group.  Speaking about the imminence of harm from the other group and the importance of action now.   Expressing attitudes that justify offending on behalf of the group, cause, or ideology.  Condoning or supporting violence or harm towards others plotting or conspiring with others. 
Capability to cause harm: Not all those who have a wish to cause harm on behalf of a group, cause or ideology are capable of doing so, and plots to cause widespread damage take a high level of personal capability, resources and networking to be successful. What the individual is capable of is therefore a key consideration when assessing risk of harm to the public. Example indicators that an individual is capable of directly or indirectly causing harm include:  Having a history of violence.  Being criminally versatile and using criminal networks to support extremist goals.  Having occupational skills that can enable acts of terrorism (such as civil engineering, pharmacology, or construction). Having technical expertise that can be deployed (e.g. IT skills, knowledge of chemicals, military training, or survival skills).  Please refer to ALTR’s Preventing Extremism and Radicalisation Safeguarding Policy for further details. 
8.18 Hate crime  What are hate incidents? The Police and Crown Prosecution Service have agreed a common definition of hate incidents. They say something is a hate incident if the victim or anyone else thinks it was motivated by hostility or prejudice based on one of the following things:  ● Disability ● Race   ● Religion      ● Transgender identity ● Sexual orientation.  This means that if you believe something is a hate incident it should be recorded as such by the person you are reporting it to, i.e. Head of Centre, Safeguarding Lead. Anyone can be the victim of a hate incident.  Other personal characteristics: Those people who live by an alternative sub-culture can be subject to hate incidents. These are incidents based on someone’s appearance and include Goths, Emos, Punks and other similar groups.  What type of incidents can be a hate incident? Hate incidents can take many forms, for example: Verbal abuse like name-calling and offensive jokes. Harassment. Bullying or intimidation by children, adults, neighbours, or strangers. Physical attacks such as hitting, punching, pushing, spitting. Threats of violence. Hoax calls, abusive phone, or text messages hate mail. Online abuse for example on Facebook or Twitter. Displaying or circulating discriminatory literature or posters. Harm or damage to things such as your home, pet, vehicle. Graffiti. Arson. Throwing rubbish into a garden. Malicious complaints for example over parking, smells, or noise.  When is a hate incident also a hate crime? When hate incidents become criminal offences they are known as hate crimes.  A criminal offence is something which breaks the law of the land. Any criminal offence can be a hate crime if it was carried out because of hostility or prejudice based on disability, race, religion, transgender identity, or sexual orientation. When something is classed as a hate crime, the courts can impose a tougher sentence on the offender under the Criminal Justice Act 2003. Incidents which are based on other personal characteristics, such as age and belonging to an alternative subculture, are not considered to be hate crimes under the law. These should still be reported, but they will not be prosecuted specifically as hate crimes by the police and the Crown Prosecution Service. Examples of hate crimes:● Assaults ● Criminal damage ● Harassment ● Murder ● Sexual assault ● Theft ● Fraud ● Burglary ● Hate mail (Malicious Communications Act 1988) ● Causing harassment, alarm, or distress (Public Order Act 1988).  What can you do about a hate incident or crime? If you have experienced a hate incident or crime you must report it to the Safeguarding and Well-being Manager, who can report it to the police. You should also report a hate incident or crime even if it was not directed at you. For example, if another learner behaves inappropriately. When reporting the incident or crime you should say whether you think it was because of disability, race, religion, transgender identity, sexual orientation, or a combination of these things. This is important because when it gets reported to the police it gets recorded as a hate incident or crime. It is also important to keep in mind that some hate crimes start as smaller incidents which may escalate into more serious and frequent attacks - so it is always best to act early. If you are being repeatedly harassed, should you report all the incidents? If you've experienced hate crime, it may have been just one isolated incident. But sometimes, you may be repeatedly harassed by the same person or group of people. 
8.19 Modern Slavery Modern slavery is a form of organised crime in which individuals including children and young people are treated as possessions/supplies and exploited for criminal gain. Traffickers and slave drivers’ trick, force and/or persuade children and parents to let them leave their homes.   Grooming methods are used to gain the trust of a child and their parents, e.g. the promise of a better life or education, which results in a life of abuse, enslavement, and inhumane treatment.  Child modern slavery is identified as child abuse which requires a child protection response. It is an abuse of human rights, and all children, irrespective of their immigration status, are entitled to protection under the law. Children are recruited, moved, or transported and then exploited, forced to work or sold. The Modern Slavery Act 2015 includes two substantive offences) human trafficking, and ii) slavery, servitude and forced or compulsory labour. It also provides two civil prevention orders - the Slavery and Trafficking Prevention Orders (STPO) and Slavery and Trafficking Risk Order (STRO) and provision for child trafficking advocates. Children are not considered able to give ‘informed consent’ to their own exploitation (including criminal exploitation), so it is not necessary to consider the means used for the exploitation - whether they were forced, coerced or deceived, i.e. a child’s consent to being trafficked is irrelevant and it is not necessary to prove coercion or any other inducement. Boys and girls of all ages are affected and can be trafficked into, within (‘internal trafficking’), and out of the UK for many reasons and all forms of exploitation - e.g. sex trafficking - children can be groomed and sexually abused before being taken to other towns and cities where the sexual exploitation continues. Victims are forced into sexual acts for money, food, or a place to stay. Other forms of slavery involve children who are forced to work, criminally exploited, and forced into domestic servitude. Victims have been found in brothels or saunas, farms, in factories, nail bars, car washes, hotels and restaurants and commonly are exploited in cannabis cultivation. Criminal exploitation can involve young people as drug carriers, begging and pickpocketing. Debt bondage (forced to work to pay off debts that realistically they will never be able to), organ harvesting, and benefit fraud are other types of modern slavery. Victims often face more than one type of abuse and slavery, for example they may be sold to another trafficker and then forced into another form of exploitation. Children and young people may be exploited by parents, carers, or family members. Often the child or young person will not realise that family members are involved in the exploitation. Some young people may not be victims of human trafficking but are still victims of modern slavery.  Slavery, servitude and forced or compulsory labour may also be present in trafficking cases; however, not every young person who is exploited through forced labour has been trafficked. In all cases, protection and support is available through different agencies (e.g. the police, Home Office, including Border Force, UK Visas and Immigration, local authorities, and voluntary organisations).  
Risk Factors and Vulnerable Circumstances Victims may not always be recognised by those who come into contact with them. They may be unwilling to come forward to agencies not seeing themselves as victims or fearing further reprisals from their abusers. Vulnerable circumstances include: Poverty, limited opportunities at home, low levels of education, and the effects of war are some of the key drivers that contribute to trafficking of victimsPoor and displaced families may hand over care of their children to traffickers who promise to provide them with a source of income, education, or skills training, but ultimately exploit themWanting to help their families back at home or seeking better futuresEscaping familial situations of harm and abuse, homelessness or being orphanedA lack of equal opportunities, discrimination or marginalisation and social customs such as children being expected to respect and follow the adult in charge. Faith abuse and other specific practices may be used to control the child. A demand for cheap or free labour or a workforce who can be easily controlled and forced into criminal activityUnaccompanied, internally displaced childrenSome children may say they are unaccompanied when claiming asylum - the trafficker may have told the child that in doing so they will be granted permission to stay in the UK and be entitled to claim welfare benefitsFormer victims of modern slavery or traffickingTrafficked children have an increased risk of going missing from care in the UK, with some re-joining those who exploited them in the first place.  Indicators Signs that a child has been trafficked may not be obvious, or children may show signs of multiple forms of abuse and neglect. Spotting the potential signs of child slavery/trafficking in referrals and children you work with can include: A reluctance to seek help - victims may be wary of the authorities for many reasons such as not knowing who to trust or a fear of deportation or concern regarding their immigration status and may avoid giving details of accommodation or personal detailsThe child seeming like a willing participant in their exploitation, e.g. involvement in lucrative criminal activity - however this does not mean they have benefitted from the proceeds Discrepancies in the information victims have provided due to traffickers forcing them to provide incorrect storiesAn unwillingness to disclose details of their experience due to being in a situation of dependencyBrought or moved from another countryAn unrelated or new child discovered at an addressUnsatisfactory living conditions - may be living in dirty, cramped, or overcrowded accommodationMissing - from care, home, or school - including a pattern of registration and deregistration from different schoolsChildren may be found in brothels and saunasSpending a lot of time doing household choresMay be working in catering, nail bars, caring for children and cleaningRarely leaving their home, with no freedom of movement and no time for playing Orphaned or living apart from their family, often in unregulated private foster care Limited English or knowledge of their local area in which they live False documentation, no passport or identification documentsFew or no personal effects - few personal possessions and tend to wear the same clothingNo evidence of parental permission for the child to travel to the UK or stay with the adultLittle or no evidence of any pre-existing relationship with the adult or even an absence of any knowledge of the accompanying adultSignificantly older partnerUnderage marriage. Physical Appearance - Victims may show signs of physical or psychological abuse, look malnourished or unkempt, or appear withdrawn. Physical illnesses - including work-related injuries through poor health and safety measures, or injuries apparently as a result of assault or controlling measures. There may be physical indications of working (e.g. overly tired in school or indications of manual labour). Sexual health indicators - sexually transmitted infections, or pregnancy; injuries of a sexual nature and/or gynaecological symptoms. Psychological indicators - suffering from post-traumatic stress disorder which may include symptoms of hostility, aggression, and difficulty with recalling episodes and concentrating. Depression/self-harm and/or suicidal feelings; an attitude of self-blame, shame, and extensive loss of control; drug and or/alcohol use. Protection and Action to be Taken Modern slavery is child abuse, and any potential victim should immediately be referred to the Safeguarding Lead through MyConcern. See section 10 of this Policy for reporting procedures.   
8.20 Further information  Expert and professional organisations are best placed to provide up-to-date guidance and practical support on specific safeguarding issues. NSPCC offers information for schools on its website www.nspcc.org.uk Broad government guidance on the issues listed below can also be accessed via the www.gov.uk website Missing Children and Vulnerable Adults  ● children missing education https://www.gov.uk/government/publications/children-missing-education ● children missing from home or care https://www.gov.uk/government/publications/children-who-run-away-or-gomissing-from-home-or-care ● Missing children and adults https://www.gov.uk/government/publications/missing-children-and-adultsstrategy  Other  ● Drugs  ● Fabricated or induced illness  ● Faith abuse  ● Gangs and youth violence  ● Gender-based violence/violence against women and girls  ● Mental health  ● Private fostering  ● Radicalisation  ● Sexting  ● Teenage relationship abuse  ● Human trafficking.   
9. Procedure for dealing with a disclosure 
When a child, young person or vulnerable adult discloses abuse to a member of ALTR the employee must report the disclosure to the Safeguarding Lead or the Deputy Designated Safeguarding Lead at ALTR immediately. All concerns must be reported within 24 hours. Failure to do so may result in disciplinary action. See flow chart appendices.   All external speakers and visitors are issued with the ALTR leaflet setting out guidance about their courses of action in this circumstance and a lanyard with details on the reverse.  The member of staff concerned should refer to the following guidance when hearing the allegation of abuse from a child, young person, or vulnerable adult.   The staff member should listen carefully: Notify the person that the disclosure cannot be kept a secret, and you are required to inform the relevant Designated Safeguarding Leads. Allow the person to speak without interruption, remember ‘TED’ (Tell, Explain, Describe). Never trivialise or exaggerate the issue. Never make suggestions Never coach or lead, in any way. Re-assure the person and let them know that they are glad the person has spoken up and that they were right to do so. Always question enough to clarify understanding, but not to probe or interrogate. Always remain calm, this is not an easy thing for them to do. Do not show emotions such as anger, disgust, or disbelief as this may stop the person communicating further.  This may be because the person may feel that they are upsetting the staff member or may feel the staff member’s negative feelings are directed towards them.  Let the person know that ALTR will take their disclosure very seriously and will take the appropriate action. Employees and volunteers are not required by ALTR to investigate suspicions where they may suspect that a child, young person, or vulnerable adult may be at risk of suffering significant harm. They must always refer such concerns to the Safeguarding Lead or Deputy Designated Safeguarding Lead and never explore concerns or allegations themselves; the designated people will then determine the appropriate course of action.  
10. Reporting concerns and disclosures  Immediately report concerns/disclosures to the Safeguarding Lead, Deputy Safeguarding Lead or Director. Inform them about any medical attention needed or other requirements needed to safeguarding children, young people, vulnerable adults, or themselves for immediate protection.  If the Safeguarding Lead, Deputy Safeguarding Lead or Director are unavailable please refer to your internal list of trained Safeguarding assistant leaders in the staff handbook and or on the leaflet for visitors and on the back of the lanyard. Records will be kept of all such incidents on Myconcern.  Their outcomes will be held by the Safeguarding Lead/Deputy Safeguarding Lead in accordance with the Data Protection Act.   The law provides that these outcomes may be shared with Children’s Services, the Police, DBS, and Local Safeguarding Boards, upon request. 
11. Recording Concerns  Record all disclosures by using the appropriate forum, as advised by the Safeguarding Lead or Deputy Designated Safeguarding Lead. This will either be the electronic reporting system, MyConcern or alternative forms provided by the Safeguarding Lead.  Effective recording: Reports must be factual and accurate and include as much detail as possible. Opinions should be clearly stated e.g. “I thought this might be because…In my opinion…” List any witnesses who may corroborate your testimony. Differentiate between fact, opinion, interpretation, observation, and allegation. Always record in the child’s words no matter how distressing e.g. “The child told me…” Report all concerns, as advised, using ALTR’s current online reporting system, located on the internet, no later than 12 hours after the disclosure. Allegation of Peer on Peer abuse will be recorded by all ALTR staff using Myconcern and on the bullying register, in line with our reporting procedure.  
12. Confidentiality  12.1. ALTR employees and volunteers will inform the child, young person, or vulnerable adult at the earliest possible stage of the disclosure that information will be shared with appropriate persons. 12.2. ALTR will ensure that all data about learners is handled in accordance with the requirements of the Data Protection Act 1998, and any national laws and legislations and local guidance. 12.3. All ALTR employees or volunteers who gain access to sensitive information about a learner or the learner’s family must take all reasonable steps to ensure that such information is only disclosed to those people who need to know. 12.4. ALTR ensures that confidentiality and trust will be maintained within limits, but staff must act on the basis that the safety of the person disclosing is the overriding concern. The degree of confidentiality will be governed by the need to protect those concerned.  
13. Learners awareness of Safeguarding  13.1. ALTR will issue all learners with induction materials explaining how to report safeguarding matters. This is to make learners aware of what constitutes a safeguarding issue by keeping communal notice boards up to date with relevant information.   13.2. ALTR assures that all policies and procedures, including those on abuse, bullying and internet safety, are implemented.  13.3. Learners that participate on programmes through ALTR are made aware of methods to report concerns to ensure opportunities are not missed.   
14. Allegations against members of staff  14.1. Any Allegations that are made about any employee of ALTR (including any volunteers or Board Members) the allegation will be dealt with in accordance with national guidance and agreements, as implemented locally. 14.2. The Director rather than the Safeguarding Lead will handle such allegations, unless the allegation is against the Director, where the Chair of Board will handle the response on behalf of ALTR). 14.3. Chair of board may also be involved from a HR position as any serious allegations against a member of staff may require the individual to be suspended pending investigation. 14.4. The Director will gather information about the allegation, and report these without delay to LADO.  
15. Allegations by a learner against another learner   15.1. If allegations are made by a learner against another learner, the Safeguarding and Well-being Manager/Deputy Safeguarding Lead must be informed and will refer to the relevant organisations, as deemed appropriate.  Please inform us by completing ALTR’s current online reporting system for Safeguarding and Prevent.  
16. Recruitment and Selection Procedures 
16.1. ALTR follows safer recruitment principles when recruiting staff and volunteers who will work with children, young people, and vulnerable adults. Please see Recruitment Policy. 16.2. In order to ensure that everyone is protected whilst at ALTR, we will ensure that our employees and volunteers are carefully selected, screened, trained, and supervised. 16.3. ALTR has a responsibility to ensure safe recruitment and employment practices. All employees and volunteers are vetted appropriately before commencement of employment/voluntary position, including a DBS check. 
17. Disclosure and Barring Service (DBS)  17.1. All individuals working with children, young people and vulnerable adults will be made aware of DBS processes and regulations. 17.2. ALTR will ensure rapid and efficient interaction with DBS with regard to the discovery of new and relevant information relating to any individual. 17.3. DBS checks and any subsequent queries or concerns will be conducted through official channels and in keeping with the Data Protection Act 2018. 17.4. The Director has overall responsibility for the DBS policy. 17.5. ALTR recognises its legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult where: The harm test is satisfied in respect of that individualThe individual has received a caution or conviction for a relevant offence, or if there is reason to believe that the individual has committed a listed offence The individual has been removed from (paid or unpaid) regulated activity or would have been removed had they not left. 
This will be the responsibility of the Director 17.6. ALTR will refer information to the DBS where an individual is deployed to another area of work that is not regulated activity, or they are suspended in regard to point 17.5.   
18. Identification Badges  18.1. ALTR have taken the view that it is appropriate for employees to wear ID badges especially when representing ALTR and will make their own arrangements for issuing such badges to all staff. 18.2. Any persons attending any ALTR event will be issued an identification band that will be on a lanyard coloured to demonstrate their level of security checks.  
19. Training  19.1. ALTR has a duty to promote safeguarding issues and measures to staff and ensure they: ● Analyse their own practice against established good practice and assess risk to ensure their practice is likely to protect them from false allegations. ● Recognise their responsibilities and report any concerns about suspected possible abuse or poor practice.  19.2. Safeguarding Lead is required to undertake a minimum of level two training in safeguarding and inter-agency working and receives refresher training at least every two years. They will also undertake appropriate training on current safeguarding issues and legislation. 19.3. Other Designated Safeguarding staff are required to have training in safeguarding and inter-agency working and receive refresher training at least every two years and every year and when updates are required.  19.4. All employees/volunteers working directly with children, young people and adults at risk will undertake appropriate training on safeguarding to raise awareness of current issues and legislation every year and when updates are required. 19.5. Mandatory training for all employees and volunteers working directly with learners will take the form of attendance on the relevant face to face course annually.  The mandatory training for those working directly with learners must not just take the form of E-Learning.    
19.6. All employees/volunteers will receive an induction on commencement of service which will include online training on ssscpd.co.uk. In addition, they will be given a copy of Part A of the Department of Education’s “Keeping Children Safe in Education” and they will be required to sign to say that that they have read, received and understood this document. 19.7. Safeguarding training is mandatory to all ALTR employees/volunteers. Refusal to undertake safeguarding training, will be a matter of gross misconduct, and may lead to dismissal.  19.8. Safeguarding Training will be required to be undertaken by all Board Members and the Director. 19.9. Safeguarding Training will be regularly reviewed by Heads of Centre during staff reviews and with consultation with the Safeguarding Lead.    
20. Health and Safety 
20.1. The Health and Safety Manager has overall responsibility for health and safety matters and will work closely with Safeguarding Lead on all matters relating to Safeguarding. 20.2. ALTR will ensure the safety of children, young people, and vulnerable adults through the following measures: ● Risk assessment will be carried out by qualified individuals in all areas and settings where ALTR is responsible. ● ALTR practice will be carried out in accordance with Health and Safety at Work, etc Act 1974, the Management of Health and Safety at Work Regulations 1999 and ALTR’s Health and Safety policy.  ● Non-qualified individuals will be aware of Health and Safety procedure and refer any concerns or queries directly to qualified personnel.  
20.3. Wherever relevant and possible, ALTR will promote good health and safety practice when: ● Undertaking excursions, trips or any other activity taking place away from ALTR premises. ● Children, young people, and vulnerable adults are required to travel alone or unsupervised to and/or from any activity, event or training organised by ALTR. ● ALTR recognises that Health and Safety is vital to safeguarding children, young people and vulnerable adults and accordingly will ensure that it remains a priority.  
21. Monitoring and Evaluation  21.1. Through an annual review of this Policy. 21.2. Through the Quality Improvement Group. Safeguarding will be on a weekly agenda with designated safeguarding staff to ensure complete transparency, support and to identify any emerging concerns or patterns.21.3. Through Local Children Safeguarding Board, inter-agency communication, training, and feedback. 21.4. This policy is liable to full equality impact assessment annually.    
7. Children who may be particularly vulnerable  
7.1. Some children may have an increased risk of abuse. Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues and reluctance on the part of some adults to accept that abuse can occur. LAC are particularly vulnerable as the most common reason for children becoming looked after is because of abuse and/or neglect. ALTR will ensure that employees have the skills, knowledge and understanding necessary to keeping LAC safe. In particular, they will ensure that appropriate employees have the information they need in relation to a child’s looked after legal status and contact arrangements with birth parents or those with parental responsibility. They will also have information about the child’s care arrangements and the levels of authority delegated to the carer by the authority looking after him/her.  7.2. To ensure that all children, young person, or vulnerable adult working alongside ALTR receive appropriate protection, we will give special consideration to those who are:   Disabled or have Special Education Needs Living in a domestically abusive situation Affected by parental substance misuse Asylum seekers Regularly absent from school Living away from home (frequent movers) Vulnerable to being bullied, or engaging in bullying Living in temporary accommodation Living a transient lifestyle Living in chaotic and unsupportive home situations Vulnerable to discrimination and maltreatment on the grounds of race, ethnicity, religion, or sexuality  Involved directly or indirectly in prostitution or child trafficking Speakers or another first language Children that are subject to a Full Care order (LAC), Child Protection Plan or Children in Need Plan  Children that may be vulnerable to messages of violence and extreme ideologies and radicalisation  Peer on Peer abuse  Allegations of Peer on Peer abuse, within ALTR, will be investigated. This will include meetings between the Safeguarding Lead, the class teacher, the Learner and their Parent(s)/Carer(s) and any relevant external agencies. This is in line with ALTR’s Support Policy, including the disciplinary process.  The victim, perpetrator and any other learner affected by Peer on Peer abuse will be supported in accordance to the Support Policy. Both victims and perpetrators will be dealt with on a case by case basis, taking into account circumstances and individual needs. 
 8. Definitions and categories of abuse  ALTR recognises the following as definitions of abuse; physical, emotional, neglect, and sexual with the additional categories of acts of omission, psychological, financial, or material, institutional, or professional abuse.   Someone may abuse or neglect a child or young person by inflicting harm, by failing to act to prevent harm, or by failing to ensure safety and adequate care. Harm may occur intentionally or unintentionally. Children may be abused in a family, an institution or community setting, by those known to them, or by a stranger. Examples of abuse are set out below these examples are by no means exhaustive. 
 8.1. Physical abuse  A form of abuse which may involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Possible signs of physical abuse include:  Any injuries not consistent with the explanation given for them.  Injuries which occur to the body in places which are not normally exposed to falls or rough games.  Injuries which have not received medical attention.  Reluctance to change for, or participate in, games or swimming. Bruises, bites, burns, and fractures, for example, which do not have an accidental explanation.  The child gives inconsistent accounts for the cause of injuries.   
8.2. Emotional abuse The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone. Possible signs of emotional abuse include:  Depression, aggression, extreme anxiety, changes or regression in mood or behaviour, particularly where a child withdraws or becomes clingy.  Obsessions or phobias.  Sudden underachievement or lack of concentration.  Seeking adult attention and not mixing well with other children.  Sleep or speech disorders.  Negative statements about self.  Highly aggressive or cruel to others.  Extreme shyness or passivity.  Running away, stealing, and lying.  
 8.3. Neglect  The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment.  It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. Possible signs of neglect include:  Dirty skin, body smells, unwashed, uncombed hair, and untreated lice.  Clothing that is dirty, too big, or small, or inappropriate for weather conditions.  Frequently left unsupervised or alone.  Frequent diarrhoea.  Frequent tiredness. Untreated illnesses, infected cuts, or physical complaints which the carer does not respond to. Frequently hungry.  Overeating junk food.  
8.4. Sexual abuse  Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening.  The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.  Possible signs of sexual abuse include:  The child has an excessive preoccupation with sexual matters and inappropriate knowledge of adult sexual behaviour for their age, or regularly engages in sexual play inappropriate for their age.  Sexual activity through words, play or drawing.  Repeated urinary infections or unexplained stomach pains.  The child is sexually provocative or seductive with adults. Inappropriate bed-sharing arrangements at home. Sleep disturbances with fears, phobias, vivid dreams, or nightmares which sometimes have overt or veiled sexual connotations.  Eating disorders such as anorexia or bulimia.   
8.5 Domestic Abuse/Violence The cross-government definition of abuse is: “Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality. This can encompass but is not limited to the following types of abuse: psychological physical sexual financial emotional Controlling behaviour is: a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour. Coercive behaviour is an act or a pattern of acts of assault, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten their victim.” * This definition, which is not a legal definition, includes so called ‘honour’ based violence, female genital mutilation (FGM) and forced marriage, and is clear that victims are not confined to one gender or ethnic group.” (GOV.UK) Exposure to Domestic Abuse and/or Violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family as a result. Domestic Abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life. 
8.6 Bullying and Cyberbullying Cyberbullying is bullying that takes place over digital devices, such as mobile phones and internet use through computers, laptops, and tablets. Cyberbullying can occur through SMS, Text, and Apps or online with social media, forums, or gaming, where people can view, participate in, or share content. Cyberbullying includes sending, posting, or sharing negative, harmful, false, or mean content about someone else. It can include sharing personal or private information or images about someone else causing embarrassment and humiliation. Some Cyberbullying crosses the line into unlawful or criminal behaviour. See ALTR’s Anti-Bullying Policy for further information. The most common places where Cyberbullying takes place: Social Media, such as Facebook, Instagram, Snapchat, and Twitter SMS (short Message Service) also known as a ‘text message’ sent through devices. Instant Messaging (via devices, email provider services, Apps, and social media messaging features) Email 
8.7 Child Criminal Exploitation – County Lines  Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money (on occasions weapons) from urban areas to suburban and rural areas, market and seaside towns. The key to identifying potential involvement in county lines are missing episodes, where the victim may have been trafficked for the purpose of transporting drugs. Like other forms of abuse and exploitation, county lines exploitation: Can affect any child or young person (male or female) under the age of 18 years; Can affect any vulnerable adult over the age of 18 years; Can still be exploitation even if the activity appears consensual;  Can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;  Can be perpetrated by individuals or groups, males and females, and young people or adults; and Is typified by some form of power imbalance in favour of those perpetrating the exploitation.  Whilst age may be the most obvious, the power of imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources. 
 8.8 Child Sexual Exploitation Child Sexual Exploitation (CSE) is a form of child sexual abuse. It can affect any child or young person (male or female) under the age of 18 years, including 16- and 17-year olds who can legally consent to have sex.    CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants (for example food, accommodation, drugs, alcohol, gifts, money or in some cases simply affection), and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship, where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups.   Sexual exploitation involves varying degrees of coercion, intimidation, or enticement, including unwanted pressure from peers to have sex and sexual bullying. CSE does not always involve physical contact; it can also occur through the use of technology; cyber bullying and grooming.   However, it is also important to recognise that some young people who are being sexually exploited do not exhibit any external signs of this abuse. The victim may have been sexually exploited even if the sexual activity appears consensual.  
 8.9 Peer on Peer Abuse When considering if a behaviour between a child or young   person to another child or young person has been abusive it is important to consider; whether there is a large difference in power (for example age, size, ability, development between the young people concerned); or whether the perpetrator has repeatedly tried to harm one or more other children; or whether there are concerns about the intention of the alleged perpetrator. Peer on Peer abuse can manifest itself in many different ways and different gender issues can be prevalent.  Severe harm may be caused to children by abusive and bullying behaviour of other children, which may be physical, sexual, or emotional (blackmail/threats) and can include gender based violence/sexual assaults, sexting, teenage relationship abuse, peer on peer exploitation, serious youth violence, sexual bullying, harmful sexual behaviour, cyber bullying, initiations, and showing prejudice in race, religion or disability.    All Peer on Peer abuse is unacceptable and will be taken seriously, regardless of the gendered nature of abuse.  Peer on Peer abuse is categorised under ‘abuse’ and should never be tolerated or passed off as ‘banter’, ‘just having a laugh’ or ‘part of growing up’. 
 8.10 Teenage Relationship Abuse This is a pattern of abusive behaviours over a course of time used to exert power and control over a dating partner.  Violent words and actions are tools an abusive partner uses to gain and maintain power and control over their partner.  Types of abuse include emotional, verbal, physical, financial, sexual, stalking, and digital (using technology to threaten, stalk, intimidate or bully).
  8.11 Sexual Violence and Sexual Harassment between children in schools and colleges  When referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003 as described below:  Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents.  Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents. A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents. Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g. to vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal, or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.  Further information on consent:  a child under the age of 13 can never consent to any sexual activity; the age of consent is 16; sexual intercourse without consent is rape.  
Sexual Harassment: When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of child on child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded, or humiliated and/or create a hostile, offensive, or sexualised environment.  Whilst not intended to be an exhaustive list, sexual harassment can include:  sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance, and calling someone sexualised namessexual “jokes” or taunting;  physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (ALTR will consider when any of this crosses a line into sexual violence - it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include:non-consensual sharing of sexual images and videossexualised online bullyingunwanted sexual comments and messages, including, on social mediasexual exploitation; coercion and threats.  It is important that staff consider sexual harassment in broad terms. Sexual harassment (as set out above) creates an atmosphere that, if not challenged, can normalise inappropriate behaviours and provide an environment that may lead to sexual violence. 
 8.12 Honour Based Violence  So-called ‘honour based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including forced marriage, Female Genital Mutilation (FGM) and practices such as breast ironing. All forms of so-called HBV are abuse (regardless of the motivation) and must be reported immediately.   
8.13 Forced Marriage A forced marriage is a marriage without the full consent of both parties and where pressure or threats are a factor. This is quite different to an arranged marriage, which both people will have agreed to. Emotional pressure from their family might stop them from saying anything to anyone else. The lack of control over their own decisions can lead to depression and self-harm. Signs and indicators of concern: Truancy / absence from school. Low Motivation. Lack of Punctuality. Self-Harm. Depression. Isolation. Attempted Suicide.Eating Disorders. Brother/Sisters forced to marry or reported missing. Family disputes. Runaways. Domestic violence. Substance misuse. While many of these signs and indicators could be linked to their issues, it is important to consider all potential reasons and keep an open mind. Honour Based Abuse and Forced Marriages are a fundamental abuse of human rights. As of 16th June 2014, changes to legislation made Forced Marriages a criminal offence. Remember the ‘One Chance Rule’. 
If someone you know is at risk: Contact the Forced Marriage Unit (FMU) if you know someone who has been taken abroad to be forced into marriage. Give as many details as you can, for example: where the person has gone when they were due back when you last heard from them  The FMU will contact the relevant embassy. If they are a British national, the embassy will try to contact the person and help them get back to the UK if that is what they want. 
  8.14 Female Genital Mutilation:  Female genital mutilation (sometimes referred to as female circumcision or ‘cutting’) refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. The practice is illegal in the UK. It has been estimated that over 65,000 girls under the age of 13 are at risk of female genital mutilation (FGM) in the UK each year, and that 170,000 women and girls in the UK are living with the consequences of FGM. However, the true extent is unknown, due to the "hidden" nature of the crime. Females may be taken to their countries of origin so that FGM can be carried out during the summer holidays, allowing them time to "heal" before they return to school. There is evidence that girls have now undergone this FGM in the UK.  Risk Factors: A child talking about a special ceremony. A young person talking about being ‘cut’. A child belonging to certain communities. Planning an extended trip abroad. Knowledge of previous siblings. Indicators it may have taken place: Prolonged absence. Change in behaviour on returning from an extended holiday. Urinary infections, bladder, or menstrual problems. Describing pain in the groin. Avoiding physical activity. Appears uncomfortable including when sitting. Finds it difficult to sit still. Talking about something happening to them or someone hurting them and having to keep a secret.  Making a Report The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crime Act 2015). The legislation requires Teachers in England and Wales to make a report to the police where, in the course of their professional duties, they either: are informed by a girl under 18 that an act of FGM has been carried out on her; or  observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth  For the purposes of the duty, the relevant age is the girl’s age at the time of the disclosure/identification of FGM (i.e. it does not apply where a woman aged 18 or over discloses she had FGM when she was under 18).   Complying with the duty does not breach any confidentiality requirement or other restriction on disclosure which might otherwise apply. The duty is a personal duty which requires the Teacher who becomes aware of the case to make a report; the responsibility cannot be transferred. The only exception to this is if you know that another individual from your profession has already made a report; there is no requirement to make a second. For staff that are not teachers, reports concerning FGM must be made directly to Safeguarding Lead who will make any necessary reports directly to the Police.  Where there is a risk to life or likelihood of serious immediate harm, professionals should report the case immediately to police, including dialling 999 if appropriate. 
 8.15 Recognising Young People Who May Be Affected by Gang Activity  Gang involvement is a multi-agency issue; partnership working, and information sharing is therefore a key to safeguarding children, young people, vulnerable adults at risk of gang-related harm. Children, young people, vulnerable adults are put at risk by gang activity both through participation in and as victims of gang violence. Learners particularly vulnerable to suffering harm in the gang context are those who are: Not involved in gangs but living in an area where gangs are active.  Not involved in gangs, but at risk of becoming victims of gangs; by way of truanting from education, permanent exclusion from school/college or having been a victim of abuse or neglect. Not involved in gangs but at risk of becoming drawn in, for example, siblings or children of known gang members; or Gang-involved and at risk of harm through their gang-related activities (e.g. drug supply, weapon use, sexual exploitation, and risk of attack from own or rival gang members). Victims and offenders are often the same people. When adults treat a young person as just a victim or just an offender, they are not taking into account the complex, cyclical nature of the victim-offender link and the factors that influence young people’s lives. There are particular risk factors and triggers that young people experience in their lives that can lead to them becoming involved in gangs. Many of these risk factors are similar to involvement in other harmful activities such as youth offending or violent extremism.  Risk factors for a person becoming involved in gangs may include: Becoming withdrawn from familySudden loss of interest in education - decline in attendance or academic achievementStarting to use new or unknown slang wordsHolding unexplained money or possessionsStaying out unusually late without reasonSudden change in appearance - dressing in a particular style or ‘uniform’Dropping out of positive activitiesNew nicknameUnexplained physical injuriesGraffiti style tags on possessions, schoolbooks, wallsConstantly talking about another young person who seems to have a lot of influence over themBroken off with old friends and hanging around with a new group Increased use of social networking sitesStarting to adopt codes of group behaviour e.g. ways of talking and hand signsExpressing aggressive or intimidating views towards other groups of young people some of whom may have been friends in the pastBeing scared when entering certain areasBeing concerned by the presence of unknown youths in their neighbourhood.  This is not an exhaustive list and should be used as a guide, amended as appropriate in light of local knowledge of the risk factors in a particular area. 
 8.16 Contextualised Safeguarding  Contextualised Safeguarding is an approach to understanding, and responding to, young people’s experiences of significant harm beyond their families. It recognises that the different relationships that young people form in their neighbourhoods, schools and online can feature violence and abuse. Parents and Carers have little influence over these contexts, and young people’s experiences of extra-familial abuse can determine parent-child relationships.   Link to further information: https://contextualsafeguarding.org.uk/about/what-iscontextual-safeguarding 
 8.17 Recognising extremism and radicalisation  The following guidance is written with regard to the Home Office guidance “Channel: Protecting Vulnerable People from Being Drawn into Terrorism” and “Channel: Vulnerability Assessment Framework”.   Engagement: Example needs, susceptibilities, motivations and contextual influences that make individuals vulnerable to engagement with an extremist group, cause or ideology include:Feelings of grievance and injustice.  Feeling under threat.  A need for identity, meaning and belonging. Desire for status.  A desire for excitement and adventure.  A need to dominate and control others.  Susceptibility to indoctrination. A desire for political or moral change.  Opportunistic involvement.  Family or friend’s involvement in extremism.  Being at a transitional time of life. Being influenced or controlled by a group. Relevant mental health issues.  Pre-existing conviction that their religion / culture is under threat.   
Example indicators that an individual is engaged with an extremist group, cause or ideology include:  Spending increasing time in the company of other suspected extremists.  Changing their style of dress or personal appearance to accord with the group.  Their day-to-day behaviour becoming increasingly centred on an extremist ideology, group, or cause.  Loss of interest in other friends and activities not associated with the extremist ideology, group, or cause.  Possession of material or symbols associated with an extremist cause (e.g. the swastika for far-right groups). Attempts to recruit others to the group/cause/ideology.  Communication with others that suggest identification with a group/cause/ideology.Increased Social Media use, changes in their profile/image or name and being overly secretive about it. Extremist groups/individuals use social media to recruit those vulnerable to radicalisation.  Intent to cause harm: Not all those who become engaged by a group, cause or ideology go on to ALTR an intention to cause harm, so this dimension is considered separately. 
 Intent factors describe the mind-set that is associated with a readiness to use violence and address what the individual would do and to what end. They can include:  Over-identification with a group or ideology.  ‘Them and Us’ thinking.   Dehumanisation of the enemy.  Attitudes that justify offending.  Harmful means to an end.  Harmful objectives.  Example indicators that an individual has an intention to use violence or other illegal means include:  Clearly identifying another group as threatening what they stand for and blaming that group for all social or political ills.  Using insulting or derogatory names or labels for another group.  Speaking about the imminence of harm from the other group and the importance of action now.   Expressing attitudes that justify offending on behalf of the group, cause, or ideology.  Condoning or supporting violence or harm towards others plotting or conspiring with others. 
Capability to cause harm: Not all those who have a wish to cause harm on behalf of a group, cause or ideology are capable of doing so, and plots to cause widespread damage take a high level of personal capability, resources and networking to be successful. What the individual is capable of is therefore a key consideration when assessing risk of harm to the public. Example indicators that an individual is capable of directly or indirectly causing harm include:  Having a history of violence.  Being criminally versatile and using criminal networks to support extremist goals.  Having occupational skills that can enable acts of terrorism (such as civil engineering, pharmacology, or construction). Having technical expertise that can be deployed (e.g. IT skills, knowledge of chemicals, military training, or survival skills).  Please refer to ALTR’s Preventing Extremism and Radicalisation Safeguarding Policy for further details. 
8.18 Hate crime  What are hate incidents? The Police and Crown Prosecution Service have agreed a common definition of hate incidents. They say something is a hate incident if the victim or anyone else thinks it was motivated by hostility or prejudice based on one of the following things:  ● Disability ● Race   ● Religion      ● Transgender identity ● Sexual orientation.  This means that if you believe something is a hate incident it should be recorded as such by the person you are reporting it to, i.e. Head of Centre, Safeguarding Lead. Anyone can be the victim of a hate incident.  Other personal characteristics: Those people who live by an alternative sub-culture can be subject to hate incidents. These are incidents based on someone’s appearance and include Goths, Emos, Punks and other similar groups.  What type of incidents can be a hate incident? Hate incidents can take many forms, for example: Verbal abuse like name-calling and offensive jokes. Harassment. Bullying or intimidation by children, adults, neighbours, or strangers. Physical attacks such as hitting, punching, pushing, spitting. Threats of violence. Hoax calls, abusive phone, or text messages hate mail. Online abuse for example on Facebook or Twitter. Displaying or circulating discriminatory literature or posters. Harm or damage to things such as your home, pet, vehicle. Graffiti. Arson. Throwing rubbish into a garden. Malicious complaints for example over parking, smells, or noise.  When is a hate incident also a hate crime? When hate incidents become criminal offences they are known as hate crimes.  A criminal offence is something which breaks the law of the land. Any criminal offence can be a hate crime if it was carried out because of hostility or prejudice based on disability, race, religion, transgender identity, or sexual orientation. When something is classed as a hate crime, the courts can impose a tougher sentence on the offender under the Criminal Justice Act 2003. Incidents which are based on other personal characteristics, such as age and belonging to an alternative subculture, are not considered to be hate crimes under the law. These should still be reported, but they will not be prosecuted specifically as hate crimes by the police and the Crown Prosecution Service. Examples of hate crimes:● Assaults ● Criminal damage ● Harassment ● Murder ● Sexual assault ● Theft ● Fraud ● Burglary ● Hate mail (Malicious Communications Act 1988) ● Causing harassment, alarm, or distress (Public Order Act 1988).  What can you do about a hate incident or crime? If you have experienced a hate incident or crime you must report it to the Safeguarding and Well-being Manager, who can report it to the police. You should also report a hate incident or crime even if it was not directed at you. For example, if another learner behaves inappropriately. When reporting the incident or crime you should say whether you think it was because of disability, race, religion, transgender identity, sexual orientation, or a combination of these things. This is important because when it gets reported to the police it gets recorded as a hate incident or crime. It is also important to keep in mind that some hate crimes start as smaller incidents which may escalate into more serious and frequent attacks - so it is always best to act early. If you are being repeatedly harassed, should you report all the incidents? If you've experienced hate crime, it may have been just one isolated incident. But sometimes, you may be repeatedly harassed by the same person or group of people. 
8.19 Modern Slavery Modern slavery is a form of organised crime in which individuals including children and young people are treated as possessions/supplies and exploited for criminal gain. Traffickers and slave drivers’ trick, force and/or persuade children and parents to let them leave their homes.   Grooming methods are used to gain the trust of a child and their parents, e.g. the promise of a better life or education, which results in a life of abuse, enslavement, and inhumane treatment.  Child modern slavery is identified as child abuse which requires a child protection response. It is an abuse of human rights, and all children, irrespective of their immigration status, are entitled to protection under the law. Children are recruited, moved, or transported and then exploited, forced to work or sold. The Modern Slavery Act 2015 includes two substantive offences) human trafficking, and ii) slavery, servitude and forced or compulsory labour. It also provides two civil prevention orders - the Slavery and Trafficking Prevention Orders (STPO) and Slavery and Trafficking Risk Order (STRO) and provision for child trafficking advocates. Children are not considered able to give ‘informed consent’ to their own exploitation (including criminal exploitation), so it is not necessary to consider the means used for the exploitation - whether they were forced, coerced or deceived, i.e. a child’s consent to being trafficked is irrelevant and it is not necessary to prove coercion or any other inducement. Boys and girls of all ages are affected and can be trafficked into, within (‘internal trafficking’), and out of the UK for many reasons and all forms of exploitation - e.g. sex trafficking - children can be groomed and sexually abused before being taken to other towns and cities where the sexual exploitation continues. Victims are forced into sexual acts for money, food, or a place to stay. Other forms of slavery involve children who are forced to work, criminally exploited, and forced into domestic servitude. Victims have been found in brothels or saunas, farms, in factories, nail bars, car washes, hotels and restaurants and commonly are exploited in cannabis cultivation. Criminal exploitation can involve young people as drug carriers, begging and pickpocketing. Debt bondage (forced to work to pay off debts that realistically they will never be able to), organ harvesting, and benefit fraud are other types of modern slavery. Victims often face more than one type of abuse and slavery, for example they may be sold to another trafficker and then forced into another form of exploitation. Children and young people may be exploited by parents, carers, or family members. Often the child or young person will not realise that family members are involved in the exploitation. Some young people may not be victims of human trafficking but are still victims of modern slavery.  Slavery, servitude and forced or compulsory labour may also be present in trafficking cases; however, not every young person who is exploited through forced labour has been trafficked. In all cases, protection and support is available through different agencies (e.g. the police, Home Office, including Border Force, UK Visas and 
Immigration, local authorities, and voluntary organisations).  
Risk Factors and Vulnerable Circumstances Victims may not always be recognised by those who come into contact with them. They may be unwilling to come forward to agencies not seeing themselves as victims or fearing further reprisals from their abusers. Vulnerable circumstances include: Poverty, limited opportunities at home, low levels of education, and the effects of war are some of the key drivers that contribute to trafficking of victimsPoor and displaced families may hand over care of their children to traffickers who promise to provide them with a source of income, education, or skills training, but ultimately exploit themWanting to help their families back at home or seeking better futuresEscaping familial situations of harm and abuse, homelessness or being orphanedA lack of equal opportunities, discrimination or marginalisation and social customs such as children being expected to respect and follow the adult in charge. Faith abuse and other specific practices may be used to control the child. A demand for cheap or free labour or a workforce who can be easily controlled and forced into criminal activityUnaccompanied, internally displaced childrenSome children may say they are unaccompanied when claiming asylum - the trafficker may have told the child that in doing so they will be granted permission to stay in the UK and be entitled to claim welfare benefitsFormer victims of modern slavery or traffickingTrafficked children have an increased risk of going missing from care in the UK, with some re-joining those who exploited them in the first place.  Indicators Signs that a child has been trafficked may not be obvious, or children may show signs of multiple forms of abuse and neglect. Spotting the potential signs of child slavery/trafficking in referrals and children you work with can include: A reluctance to seek help - victims may be wary of the authorities for many reasons such as not knowing who to trust or a fear of deportation or concern regarding their immigration status and may avoid giving details of accommodation or personal detailsThe child seeming like a willing participant in their exploitation, e.g. involvement in lucrative criminal activity - however this does not mean they have benefitted from the proceeds Discrepancies in the information victims have provided due to traffickers forcing them to provide incorrect storiesAn unwillingness to disclose details of their experience due to being in a situation of dependencyBrought or moved from another countryAn unrelated or new child discovered at an addressUnsatisfactory living conditions - may be living in dirty, cramped, or overcrowded accommodationMissing - from care, home, or school - including a pattern of registration and deregistration from different schoolsChildren may be found in brothels and saunasSpending a lot of time doing household choresMay be working in catering, nail bars, caring for children and cleaningRarely leaving their home, with no freedom of movement and no time for playing Orphaned or living apart from their family, often in unregulated private foster care Limited English or knowledge of their local area in which they live False documentation, no passport or identification documentsFew or no personal effects - few personal possessions and tend to wear the same clothingNo evidence of parental permission for the child to travel to the UK or stay with the adultLittle or no evidence of any pre-existing relationship with the adult or even an absence of any knowledge of the accompanying adultSignificantly older partnerUnderage marriage. Physical Appearance - Victims may show signs of physical or psychological abuse, look malnourished or unkempt, or appear withdrawn. Physical illnesses - including work-related injuries through poor health and safety measures, or injuries apparently as a result of assault or controlling measures. There may be physical indications of working (e.g. overly tired in school or indications of manual labour). Sexual health indicators - sexually transmitted infections, or pregnancy; injuries of a sexual nature and/or gynaecological symptoms. Psychological indicators - suffering from post-traumatic stress disorder which may include symptoms of hostility, aggression, and difficulty with recalling episodes and concentrating. Depression/self-harm and/or suicidal feelings; an attitude of self-blame, shame, and extensive loss of control; drug and or/alcohol use. Protection and Action to be Taken Modern slavery is child abuse, and any potential victim should immediately be referred to the Safeguarding Lead through MyConcern. See section 10 of this Policy for reporting procedures.   
8.20 Further information  Expert and professional organisations are best placed to provide up-to-date guidance and practical support on specific safeguarding issues. NSPCC offers information for schools on its website www.nspcc.org.uk Broad government guidance on the issues listed below can also be accessed via the www.gov.uk website Missing Children and Vulnerable Adults  ● children missing education https://www.gov.uk/government/publications/children-missing-education ● children missing from home or care https://www.gov.uk/government/publications/children-who-run-away-or-gomissing-from-home-or-care ● Missing children and adults https://www.gov.uk/government/publications/missing-children-and-adultsstrategy  Other  ● Drugs  ● Fabricated or induced illness  ● Faith abuse  ● Gangs and youth violence  ● Gender-based violence/violence against women and girls  ● Mental health  ● Private fostering  ● Radicalisation  ● Sexting  ● Teenage relationship abuse  ● Human trafficking.   9. Procedure for dealing with a disclosure When a child, young person or vulnerable adult discloses abuse to a member of ALTR the employee must report the disclosure to the Safeguarding Lead or the Deputy Designated Safeguarding Lead at ALTR immediately. All concerns must be reported within 24 hours. Failure to do so may result in disciplinary action. See flow chart appendices.   All external speakers and visitors are issued with the ALTR leaflet setting out guidance about their courses of action in this circumstance and a lanyard with details on the reverse.  The member of staff concerned should refer to the following guidance when hearing the allegation of abuse from a child, young person, or vulnerable adult.   The staff member should listen carefully: Notify the person that the disclosure cannot be kept a secret, and you are required to inform the relevant Designated Safeguarding Leads. Allow the person to speak without interruption, remember ‘TED’ (Tell, Explain, Describe). Never trivialise or exaggerate the issue. Never make suggestions Never coach or lead, in any way. Re-assure the person and let them know that they are glad the person has spoken up and that they were right to do so. Always question enough to clarify understanding, but not to probe or interrogate. Always remain calm, this is not an easy thing for them to do. Do not show emotions such as anger, disgust, or disbelief as this may stop the person communicating further.  This may be because the person may feel that they are upsetting the staff member or may feel the staff member’s negative feelings are directed towards them.  Let the person know that ALTR will take their disclosure very seriously and will take the appropriate action. Employees and volunteers are not required by ALTR to investigate suspicions where they may suspect that a child, young person, or vulnerable adult may be at risk of suffering significant harm. They must always refer such concerns to the Safeguarding Lead or Deputy Designated Safeguarding Lead and never explore concerns or allegations themselves; the designated people will then determine the appropriate course of action. 
 10. Reporting concerns and disclosures  Immediately report concerns/disclosures to the Safeguarding Lead, Deputy Safeguarding Lead or Director. Inform them about any medical attention needed or other requirements needed to safeguarding children, young people, vulnerable adults, or themselves for immediate protection.  If the Safeguarding Lead, Deputy Safeguarding Lead or Director are unavailable please refer to your internal list of trained Safeguarding assistant leaders in the staff handbook and or on the leaflet for visitors and on the back of the lanyard. Records will be kept of all such incidents on Myconcern.  Their outcomes will be held by the Safeguarding Lead/Deputy Safeguarding Lead in accordance with the Data Protection Act.   The law provides that these outcomes may be shared with Children’s Services, the Police, DBS, and Local Safeguarding Boards, upon request. 
 11. Recording Concerns  Record all disclosures by using the appropriate forum, as advised by the Safeguarding Lead or Deputy Designated Safeguarding Lead. This will either be the electronic reporting system, MyConcern or alternative forms provided by the Safeguarding Lead.  Effective recording: Reports must be factual and accurate and include as much detail as possible. Opinions should be clearly stated e.g. “I thought this might be because…In my opinion…” List any witnesses who may corroborate your testimony. Differentiate between fact, opinion, interpretation, observation, and allegation. Always record in the child’s words no matter how distressing e.g. “The child told me…” Report all concerns, as advised, using ALTR’s current online reporting system, located on the internet, no later than 12 hours after the disclosure. Allegation of Peer on Peer abuse will be recorded by all ALTR staff using Myconcern and on the bullying register, in line with our reporting procedure.  12. Confidentiality  12.1. ALTR employees and volunteers will inform the child, young person, or vulnerable adult at the earliest possible stage of the disclosure that information will be shared with appropriate persons. 12.2. ALTR will ensure that all data about learners is handled in accordance with the requirements of the Data Protection Act 1998, and any national laws and legislations and local guidance. 12.3. All ALTR employees or volunteers who gain access to sensitive information about a learner or the learner’s family must take all reasonable steps to ensure that such information is only disclosed to those people who need to know. 12.4. ALTR ensures that confidentiality and trust will be maintained within limits, but staff must act on the basis that the safety of the person disclosing is the overriding concern. The degree of confidentiality will be governed by the need to protect those concerned.  
13. Learners awareness of Safeguarding  13.1. ALTR will issue all learners with induction materials explaining how to report safeguarding matters. This is to make learners aware of what constitutes a safeguarding issue by keeping communal notice boards up to date with relevant information.   13.2. ALTR assures that all policies and procedures, including those on abuse, bullying and internet safety, are implemented.  13.3. Learners that participate on programmes through ALTR are made aware of methods to report concerns to ensure opportunities are not missed.  
 14. Allegations against members of staff  14.1. Any Allegations that are made about any employee of ALTR (including any volunteers or Board Members) the allegation will be dealt with in accordance with national guidance and agreements, as implemented locally. 14.2. The Director rather than the Safeguarding Lead will handle such allegations, unless the allegation is against the Director, where the Chair of Board will handle the response on behalf of ALTR). 14.3. Chair of board may also be involved from a HR position as any serious allegations against a member of staff may require the individual to be suspended pending investigation. 14.4. The Director will gather information about the allegation, and report these without delay to LADO.  
15. Allegations by a learner against another learner   15.1. If allegations are made by a learner against another learner, the Safeguarding and Well-being Manager/Deputy Safeguarding Lead must be informed and will refer to the relevant organisations, as deemed appropriate.  Please inform us by completing ALTR’s current online reporting system for Safeguarding and Prevent. 
 16. Recruitment and Selection Procedures 
16.1. ALTR follows safer recruitment principles when recruiting staff and volunteers who will work with children, young people, and vulnerable adults. Please see Recruitment Policy. 16.2. In order to ensure that everyone is protected whilst at ALTR, we will ensure that our employees and volunteers are carefully selected, screened, trained, and supervised. 16.3. ALTR has a responsibility to ensure safe recruitment and employment practices. All employees and volunteers are vetted appropriately before commencement of employment/voluntary position, including a DBS check. 
17. Disclosure and Barring Service (DBS)  17.1. All individuals working with children, young people and vulnerable adults will be made aware of DBS processes and regulations. 17.2. ALTR will ensure rapid and efficient interaction with DBS with regard to the discovery of new and relevant information relating to any individual. 17.3. DBS checks and any subsequent queries or concerns will be conducted through official channels and in keeping with the Data Protection Act 2018. 17.4. The Director has overall responsibility for the DBS policy. 17.5. ALTR recognises its legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult where: The harm test is satisfied in respect of that individualThe individual has received a caution or conviction for a relevant offence, or if there is reason to believe that the individual has committed a listed offence The individual has been removed from (paid or unpaid) regulated activity or would have been removed had they not left. 
This will be the responsibility of the Director 17.6. ALTR will refer information to the DBS where an individual is deployed to another area of work that is not regulated activity, or they are suspended in regard to point 17.5.  
 18. Identification Badges  18.1. ALTR have taken the view that it is appropriate for employees to wear ID badges especially when representing ALTR and will make their own arrangements for issuing such badges to all staff. 18.2. Any persons attending any ALTR event will be issued an identification band that will be on a lanyard coloured to demonstrate their level of security checks. 
 19. Training  19.1. ALTR has a duty to promote safeguarding issues and measures to staff and ensure they: ● Analyse their own practice against established good practice and assess risk to ensure their practice is likely to protect them from false allegations. ● Recognise their responsibilities and report any concerns about suspected possible abuse or poor practice.  19.2. Safeguarding Lead is required to undertake a minimum of level two training in safeguarding and inter-agency working and receives refresher training at least every two years. They will also undertake appropriate training on current safeguarding issues and legislation. 19.3. Other Designated Safeguarding staff are required to have training in safeguarding and inter-agency working and receive refresher training at least every two years and every year and when updates are required.  19.4. All employees/volunteers working directly with children, young people and adults at risk will undertake appropriate training on safeguarding to raise awareness of current issues and legislation every year and when updates are required. 19.5. Mandatory training for all employees and volunteers working directly with learners will take the form of attendance on the relevant face to face course annually.  The mandatory training for those working directly with learners must not just take the form of E-Learning.    
19.6. All employees/volunteers will receive an induction on commencement of service which will include online training on ssscpd.co.uk. In addition, they will be given a copy of Part A of the Department of Education’s “Keeping Children Safe in Education” and they will be required to sign to say that that they have read, received and understood this document. 19.7. Safeguarding training is mandatory to all ALTR employees/volunteers. Refusal to undertake safeguarding training, will be a matter of gross misconduct, and may lead to dismissal.  19.8. Safeguarding Training will be required to be undertaken by all Board Members and the Director. 19.9. Safeguarding Training will be regularly reviewed by Heads of Centre during staff reviews and with consultation with the Safeguarding Lead.  
  20. Health and Safety 
20.1. The Health and Safety Manager has overall responsibility for health and safety matters and will work closely with Safeguarding Lead on all matters relating to Safeguarding. 20.2. ALTR will ensure the safety of children, young people, and vulnerable adults through the following measures: ● Risk assessment will be carried out by qualified individuals in all areas and settings where ALTR is responsible. ● ALTR practice will be carried out in accordance with Health and Safety at Work, etc Act 1974, the Management of Health and Safety at Work Regulations 1999 and ALTR’s Health and Safety policy.  ● Non-qualified individuals will be aware of Health and Safety procedure and refer any concerns or queries directly to qualified personnel.  
20.3. Wherever relevant and possible, ALTR will promote good health and safety practice when: ● Undertaking excursions, trips or any other activity taking place away from ALTR premises. ● Children, young people, and vulnerable adults are required to travel alone or unsupervised to and/or from any activity, event or training organised by ALTR. ● ALTR recognises that Health and Safety is vital to safeguarding children, young people and vulnerable adults and accordingly will ensure that it remains a priority.  
21. Monitoring and Evaluation  21.1. Through an annual review of this Policy. 21.2. Through the Quality Improvement Group. Safeguarding will be on a weekly agenda with designated safeguarding staff to ensure complete transparency, support and to identify any emerging concerns or patterns.21.3. Through Local Children Safeguarding Board, inter-agency communication, training, and feedback. 21.4. This policy is liable to full equality impact assessment annually.    


RISE E-Safety Policy

The e-safety policy aims to create an environment where young people, staff, parents, governors and the wider school community work together to keep each other safe and inform each other of ways to use the Internet responsibly, safely and positively. Teaching Digital Employability, PSHE and Life and Life skills we equip young people to participate in a rapidly changing digital world where work and leisure activities, social interactions, self-care, independent living are increasingly dependent on technology. By enable young people to find, explore, analyse, exchange and present information in a functional way and safe manner they become more independent and capable digital citizens. The e-safety policy encourages appropriate and safe conduct and behaviour when achieving this.  Pupils, staff, and all other users of ALTR technologies will agree standards and expectations relating to usage to promote and ensure safe, positive behaviour and prepare them for experiences and expectations in the workplace. The policy is intended to explore areas to discuss, teach and inform, to develop positive ICT use and knowledge. RISE expects that the positive effects of the policy will be seen online and offline; in school and at home; and ultimately beyond school and into the workplace.  
This Policy will be monitored by Provision Lead and Board Members and reviewed biannually due to vast changes with technological advances.Any serious incidents that are reported will refer to the Safeguarding and Child Protection Policies.RISE will monitor the impact of this policy and safety of ICT by:Surveys and questionnaires of young people, parents, carers, staff.Logging incidents of misuse.Monitoring internet activity
The Link School E-safety Policy Scope The school e-safety Policy and agreements apply to all young people, staff, support staff, supply staff, external contractors, agencies and members of the wider provision community who use, have access to or maintain school and school related Internet, computer systems and mobile technologies internally and externally. RISE make reasonable use of relevant legislation and guidelines to affect positive behaviour and understanding regarding ICT and Internet usage at school and at home. ‘In Loco Parentis’ provision under the Children Act 1989 also allows RISE to report and act on:instances of cyber bullying, abuse, harassment (including sexual harassment), malicious communication and grossly offensive material reporting to the police, social media websites, and hosting providers on behalf of pupils.  The Education and Inspections Act 2006 empowers Head teachers when reasonable, to regulate the behaviour of students when they are off the Academy site and empowers members of staff to impose disciplinary penalties for inappropriate behaviour. This is applicable to incidents of cyber-bullying or other E-safety incidents covered by this policy, which may take place away from the RISE provision, but is linked by membership of RISE the ALTR Group.  The 2011 Education Act increased these powers with regard to the searching for and of electronic devices and the deletion of data. In the case of both acts, action can only be taken over issues covered by the published Behaviour Policy. The e-safety policy covers the use of: Provision based ICT systems and equipmentProvision based intranet and networking Provision related external Internet, including but not exclusively, extranet, e-learning platforms, blogs, social media websites. External access to internal school networking, such as webmail, network access, file-serving (document folders) and printing. School ICT equipment off-site, for example staff laptops, digital cameras, mobile phones, tablets Pupil and staff personal ICT equipment when used in school and which makes use of school networking, file-serving, or Internet facilities.  Tablets, mobile phones, devices, and laptops when used on the school site.  
Managing Information Systems It is important to review the security of the whole system from user to Internet. This significant responsibility includes not only the delivery of essential learning services but also the personal safety of staff and learners.Local Area Network (LAN) security issues include: Users must act reasonably — e.g. Downloading large files outside of the working day so not to affect the service that others receive. Users must take responsibility for their network use. For Link School staff, flouting electronic use policy is regarded as a reason for dismissal.Workstations should be secured against user mistakes and deliberate actions. Servers must be located securely and physical access restricted. The server operating system must be secured and kept up to date; through regular monthly patching Virus protection for the whole network must be installed and current. Access by wireless devices must be proactively managed and secured with WPA2 PSK (pre-shared key).  Guest Wi-Fi will use Meraki radius. Wide Area Network (WAN) security issues include: Link School broadband firewalls are configured to prevent unauthorised access. Decisions on WAN security are made on a partnership between partner organisations. The Link provision broadband network is protected by a cluster of high-performance firewalls at the Internet connecting nodes. The security of the provision information systems and users will be reviewed regularly.Virus protection will be updated regularly. Personal data sent over the Internet or taken off site will be password protected.Portable media may not be used unless it has been encrypted and virus checked.Unapproved software will not be allowed in work areas or attached to email. Files held on the network will be regularly checked. System capacity in relation to storage will be checked regularly. The use of user logins and passwords to access the network will be enforced.   
Filter Management. The school’s broadband access provides filtering appropriate to the age and maturity of learners. There is flexibility in the filtering system to allow for changes in provision depending on the learning required. A description of the filtering service should be shared with the school (Infrastructure).  Smooth wall works via Standard Browsing Categories and has a default policy set by Smooth wall.  Any breaches in filtering should be reported to the Provision Lead/or emailed to the Board Member. If staff or learners discover unsuitable sites, the URL will be reported to the Data and assessment manager who will then record the incident and escalate the concern as appropriate. The School filtering system will block all sites on the Internet Watch Foundation (IWF) list. Changes to the school filtering policy will be risk assessed by staff with educational and technical experience prior to any changes and where appropriate with consent from the Leadership team.The Leadership Team will ensure that regular checks are made to ensure that the filtering methods selected are effective. Any material that the school believes is illegal will be reported to appropriate agencies. The academy’s access strategy will be designed by educators to suit the age and curriculum requirements of the learners, with advice from network managers.  
Monitoring the e-safety policy:  The e-safety policy will be actively monitored and evaluated by the Board Members and Provision Lead. E-safety Coordinator/Officer (Keighly Murphy), Safeguarding Lead (Keighly Murphy), Board Members to be confirmed.
E-safety policy review and evaluation schedule: The e-safety policy and Acceptable Use Policy are reviewed at or prior to the start of each academic year. Additionally, the policy will be reviewed promptly upon: Serious and/or frequent breaches of the acceptable Internet use policy or other in the light of e-safety incidents. New guidance by government / LA / safeguarding authorities.  Significant changes in technology as used by the provision or pupils in the wider community. E-safety incidents in the community or local schools which might impact on the provision    community.  Advice from the Police and/or the Bedfordshire Safeguarding Partnership.  The e-safety policy review will be documented in the provision development plan and school    self-evaluation and improvement profiling.  The Board Members will receive a report on the progress, evaluation, impact, and this report will include suitably redacted accounts and statistics of e-safety incidents and how these   have been resolved, and counter measures implemented.  In line with OFSTED recommendations, it is also useful to consult with pupils over the policy    and to ask for their opinion on keeping themselves self when using the Internet. 
School Management and e-safety School senior leadership team is responsible for determining, evaluating, and reviewing e-safety policies to encompass teaching and learning, use of school IT equipment and facilities by pupils, staff, and visitors. In addition, the agreed criteria for acceptable use by pupils, school staff and governors of Internet capable equipment for school related purposes or in situations which will impact on the reputation of the school, and/or on school premises. The e-safety policy is a continuous cycle of evaluation and review based on new initiatives, and partnership discussion with stakeholders and outside organisations; technological and Internet developments, current government guidance and provision related e-safety incidents. The policy development cycle develops good practice within the teaching curriculum and wider pastoral curriculum. Regular assessment of strengths and weaknesses help determine training provision for staff and governors and guidance provided to parents, pupils, and local partnerships.  e-safety provision is always designed to encourage positive behaviours and practical real-world strategies for all members of the provision and wider community. The leadership team is encouraged to be aspirational and innovative in developing strategies    for e-safety provision.  
The school e-safety Coordinator: 
The school has a designated e-safety Coordinator [Keighly Murphy] who reports to the Director (Lianne Murphy) and Governors and coordinates e-safety provision across the school and wider provision community. The committee liaises with SLT, the schools designated safeguarding officer and other senior managers as required.   The school’s e-safety coordinator chairs the school e-safety committee which includes representatives of the Leadership team, teaching and support staff and governors. The e-safety committee meets regularly.  The e-safety coordinator is responsible for e-safety issues on a day to day basis and liaises with LA contacts, filtering and website providers and school ICT support.  The school e-safety coordinator maintains a log of submitted e-safety reports and incidents on MyConcern.  The e-safety coordinator audits and assesses inset requirements for staff, support staff and Governor e-safety training, and ensures that all staff are aware of their responsibilities and the provision’s e-safety procedures. The coordinator is also the first port of call for staff requiring advice on e-safety matters.  Although all staff are responsible for upholding the school e-safety policy and safer Internet practice, the e-safety Coordinator, the Director, Board members and ICT support are responsible for monitoring Internet usage by pupils and staff, and on school machines, such as laptops, used off-site.  The e-safety Coordinator is responsible for promoting best practice in e-safety within the wider community, including providing and being a source of information for parents and partner stakeholders.  The provision e-safety coordinator (along with IT support) should be involved in any risk assessment of new technologies, services, or software to analyse any potential risks   
Governors’ responsibility for e-safety:  One Governor has responsible for e-safety, and the school e-safety Coordinator will liaise directly with the Governor and report on e-safety effectiveness, incidents, monitoring, evaluation and developing and maintaining links with local stakeholders and the wider provision community. The e-safety coordinator will be responsible for auditing Governor e-safety training and inset requirements.   
ICT support staff and external contractors:  External ICT support staff and technicians are responsible for maintaining the provisions networking, IT infrastructure and hardware. They are aware of current thinking and trends in IT security and ensure that the RISE system, particularly file-sharing and access to the Internet is secure. They further ensure that all reasonable steps have been taken to ensure that systems are not open to abuse or unauthorised external access, with regard to external logins and wireless networking.  Support staff maintain and enforce the provision’s password policy. External contractors, such as VLE providers, website designers/hosts/maintenance contractors are made fully aware of and agree to the ’s e-safety Policy. Where contractors have access to sensitive school information and material covered by the Data Protection Act, for example on a VLE, school website or email provision, the contractor should also be Enhanced DBS checked. 

Teaching and teaching support staff: Teaching and teaching support staff need to ensure that they are aware of the current e-safety policy, practices, and associated procedures for reporting e-safety incidents.  Teaching and teaching support staff will be provided with e-safety induction as part of the overall staff induction procedures.  All staff need to ensure that they have read, understood, and signed (thereby indicating an agreement) the Acceptable Use Agreement relevant to Internet and computer use in school.  All staff need to follow the provision’s social media policy, in regard to external off site use, personal use (mindful of not bringing ALTR/ RISE into disrepute), possible contractual obligations, and conduct on Internet messaging or communication platforms, for example email, VLE messages and forums and the website.  All teaching staff need to rigorously monitor pupil Internet and computer usage in line with the policy. This also includes the use of personal technology such as cameras, phones, and other gadgets on site.  Teaching staff should promote best practice regarding avoiding copyright infringement and plagiarism.  Be aware of online propaganda and help pupils with critical evaluation of online materials. Internet usage and suggested websites should be pre-vetted and documented in lesson planning.  In lessons where internet use is pre-planned students should be guided to sites checked as suitable for their use and that processes are in place for dealing with any unsuitable material that is found in internet searchesS
taff Use of Personal Devices 
Staff are not permitted to use their own personal phones or devices for contacting children, young people, and their families within or outside of the setting in a professional capacity. Staff will be issued with a provision phone where contact with learners or parents/carers is required. Mobile Phone and devices will be switched off or switched to ‘silent’ mode, Bluetooth communication should be “hidden” or switched off and mobile phones or devices will not be used during teaching periods unless permission has been given by a member of Senior Leadership Team in emergency circumstances. If members of staff have an educational reason to allow children to use mobile phones or personal device as part of an educational activity, they must ensure that they are used appropriately. Staff should not use personal devices such as mobile phones or cameras to take photos or videos of learners and will only use work-provided equipment for this purpose. If a member of staff breaches the academy policy, then disciplinary action may be taken. 
Designated Safeguarding Officer: The Designated Safeguarding Officer is trained in specific e-safety issues. Accredited training with reference to child protection issues has been accessed.  The Designated Safeguarding Officer can differentiate which e-safety incidents are required to be:reported to CEOP, local Police, LADO, Local Safeguarding Children’s Board, social services, and parents/guardians; and determine whether the information from such an incident should be restricted to nominated members of the leadership team.  Possible scenarios might include:Allegations against members of staff. Computer crime – for example hacking of RISE systems. SextingAllegations or evidence of ‘grooming’. Allegations or evidence of cyber bullying in the form of threats of violence, harassment, or a malicious communication.  Producing and sharing of Youth Produced Sexual Imagery (YPSI) Acting ‘in loco parentis’ and liaising with websites and social media platforms such as Twitter, Instagram, Snapchat, and Facebook to remove instances of illegal material or cyber bullying.  sharing of personal data  access to illegal / inappropriate materials inappropriate on-line contact with adults / strangers
Learners: Are required to use RISE Internet and computer systems in agreement with the terms specified in the provision’s Acceptable Use Policies. Pupils are expected to sign the policy to indicate agreement, and/or have their parents/guardians sign on their behalf.  Pupils need to be aware of how to report e-safety incidents at RISE, and how to use external reporting facilities, such as the Click CEOP button or Childline number. Reporting concerns on my concern.Pupils need to be aware that Acceptable Use Policies cover all computer, Internet, and mobile technology usage in school, including the use of personal items such as phones. Pupils need to be aware that their Internet use out of provision on social networking sites such as Instagram is covered under the Acceptable Use Policy if it impacts on the school and/or its staff and pupils in terms of cyber bullying, reputation, or illegal activities.   
Learners Use of Personal Devices Mobile phones will be handed in at registration, they will be placed in an individual names wallet and stored securely until they are returned at breaks/lunch times. Mobile phones will not be taken on outdoor activities. Phones and devices must not be taken into examinations. Learners found in possession of a mobile phone during an exam will be reported to the appropriate examining body. This may result in the student’s withdrawal from either that examination or all examinations. If a learner needs to contact his/her parents/carers they will be allowed to use a RISE phone. Parents/Carers are advised not to contact their child via their mobile phone during the learning day, but to contact the office. Children and young people should protect their phone numbers by only giving them to trusted friends and family members. Learners will be instructed in safe and appropriate use of mobile phones and personal devices and will be made aware of boundaries and consequences. 
 Parents and Guardians: It is hoped that parents and guardians will support the school’s stance on promoting good Internet behaviour and responsible use of IT equipment and mobile technologies both at RISE and at home.  RISE expects parents and guardians to sign the Acceptable Use Agreement, indicating agreement regarding their child’s use and also their own use with regard to parental access to RISE systems such as extranets, websites, forums, social media, online reporting arrangement, questionnaires and the VLE.  RISE will provide opportunities to educate parents about e-safety through the school website and APP. 
Other users:Other users such visitors, or wider school community stakeholders or external contractors should be expected to agree to a visitor’s AUA document specific to their level of access and usage. External users with significant access to school systems including sensitive information or information held securely under the Data Protection Act should be Enhanced DBS checked. This includes external contractors who might maintain the RISE domain name and web hosting – which would facilitate access to cloud file storage, website documents, and email. 
How will the school provide e-safety education?  Pupils – curriculum teaching:   'Teaching online safety in school (DfE, June 2019) outlines to schools the importance of helping children and young people not only use the internet safely, but also give them opportunities to learn how to behave online. Throughout the new compulsory Relationships (Sex Education) and Health Education pupils will be taught what positive, healthy and respectful online relationships look like. The PSHE curriculum will following the underpinning knowledge and behaviours: How to evaluate what they see online How to recognise techniques used for persuasion Online behaviour How to identify online risks How and when to seek support  Throughout the curriculum teaching about potential harms will include: Age restrictions Content: How it can be used and shared Disinformation, misinformation, and hoaxes Fake websites and scam emails Fraud (online) Password phishing Personal data Persuasive design which keeps 'users online for longer than they might have planned or desired' Privacy settings Targeting of online content  Abuse (online) Challenges [to do something and post about it]  Content which incites...hate, violence Fake profiles Grooming Live streaming Pornography Unsafe communication  Impact on confidence (including body confidence) Impact on quality of life, physical and mental health, and relationships Online vs. offline behaviours Reputational damage Suicide, self-harm and eating disorders  E-safety is accessed as part of pastoral care – form time activities, presentations, tutorial opportunities, E-safety events – such as Safer Internet Day and Anti Bullying Week, the Live and Living skills course and digital employability course.
Parents/Carers – information and events:  E-safety information is directly available to parents via the website which is updated with the latest E safety news and issues.  
Staff – inset and training: E-safety information is directly delivered to staff annually and in between should new training, patterns or concerns emerge. A planned programme of e-safety training opportunities is available for staff, including on site inset, whole staff training, online training opportunities (for example E-safety Support courses), external CPD courses, accredited CPD courses, (for example CEOP) and Coordinator training.  The e-safety Coordinator should be the first port of call for staff requiring e-safety advice.   
Governors – training:  E-safety information will be directly delivered to governors via the e-safety Coordinator.  
ICT support staff – contractors, filtering, and monitoring: IT support staff and contractors will ensure that bought in hardware and software solutions feature built in training provision Support staff and contractors will be DBS checked and agree and sign the school’s e-safety AUA.  IT technical support staff and network managers have relevant industry experience and   Microsoft/Cisco certified qualifications.   Policy guidance for handling personal data, dealing with freedom of information requests, and complying with privacy regulations pertaining to website data:  All of these areas are regulated by the Information Commissioner (ICO), and every UK organisation has to comply with the responsibilities and obligations as defined by the ICO. Schools are no different to any other organisation in this regard. The ICO guidance on how to comply with these obligations is updated regularly. The Link School refer directly to this guidance in these areas.  When disposing of computer equipment, schools needs to ensure all data, including personal data is wiped, not deleted from storage.  Use of IT facilities for curriculum teaching and learning:  Use of the Internet and IT facilities should be clearly planned prior to the activity. Websites and software Apps should be suggested, Students should be trusted to be responsible when researching the Internet, and teaching staff will consider the age and maturity of the students.  
General Data Protection and e-safety: The GDPR sets out the key principles that all personal data must be processed in line with.  Data must be: processed lawfully, fairly and transparently; collected for specific, explicit and legitimate purposes; limited to what is necessary for the purposes for which it is processed; accurate and kept up to date; held securely; only retained for as long as is necessary for the reasons it was collected There are also stronger rights for individuals regarding their own data. The individual’s rights include: to be informed about how their data is used, to have access to their data, to rectify incorrect information, to have their data erased, to restrict how their data is used, to move their data from one organisation to another, and to object to their data being used at all. The General Data Protection Act is relevant to e-safety since it impacts on the way in which personal information should be secured on school networks, computers and storage devices; and the security required for accessing, in order to prevent unauthorised access and dissemination of personal material.  Staff need to ensure that care is taken to ensure the safety and security of personal data regarding all the school population and external stakeholders, particularly, but not exclusively: pupils, parents, staff, and external agencies. Personal and sensitive information should only be sent by e mail when on a secure network. Personal data should only be stored on secure devices. In other words, only computers, servers, file- servers, cloud space, or devices which require a username and password to access the information.   Secure accounts need to be logged off after use to prevent unauthorised access.   Personal e mails should not be used for school business. 
Personal information on the school website: No material defined as ‘personal information’ under the General Data Protection Act will be used on the RISE website. RISE considers staff privacy issues carefully about publishing staff email addresses, staff lists, photos of staff, staff qualifications and any other personally identifying information.     
Communications and acceptable use RISE hopes to make full use of ever developing communication technologies and appreciates that these technologies can enhance learning. 
E-safety and the Law: This e safety policy takes cognizance of the following legislation: The Education and Inspections Act 2006 (Head teachers have the power “to such an extent as is reasonable” to regulate the conduct of pupils off site. Also, staff can confiscate mobile phones if they cause disturbance in class breach the school behaviour policy.) Computer Misuse Act 1990, sections 1-3 Data Protection Act 1998 General Data Protection Regulations Freedom of Information Act 2000 Communications Act 2003 section 1,2 Protection from Harassment Act 1997 Regulation of Investigatory Powers Act 2000 Copyright, Designs and Patents Act 1988 Racial and Religious Hatred Act 2006
Protection of Children Act 1978 Sexual Offences Act 2003 Schools have a ‘duty of care’ to pupils, and as such act “in loco parentis.” Under the Children Act 1989, this enables schools to remove personal information, cyber bullying and comments relating to school pupils as if they were the child’s parent. Facebook has provision for using ‘in loco parentis’ when reporting cyber bullying. This is relevant to all schools. 
Useful links to external organisations: CEOP (Child Exploitation and Online Protection Centre): www.ceop.police.uk  Childline: www.childline.org.uk  Childnet: www.childnet.com  Click Clever Click Safe Campaign: http://clickcleverclicksafe.direct.gov.uk  Cybermentors: www.cybermentors.org.uk  Digizen: www.digizen.org.uk  EiS - ICT Support for Schools and ICT Security Advice: www.eiskent.co.uk  Internet Watch Foundation (IWF): www.iwf.org.uk  Police: In an emergency (a life is in danger or a crime in progress) dial 999. For other non-urgent enquiries contact local Police. Sunderland Safeguarding Partnership:  www.sunderland.gov.uk/safersunderland Kidsmart: www.kidsmart.org.uk Teach Today: http://en.teachtoday.eu  Think U Know website: www.thinkuknow.co.uk Virtual Global Taskforce — Report Abuse: www.virtualglobaltaskforce.com

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