Safeguarding Policy

Last Updated: 5th July, 2022

Everyone working with children or young people has a responsibility to understand what safeguarding means and what their responsibilities are in relation to keeping children and young people safe. In your role, as an Educator at Union Education Group you are likely to have some interaction or engagement with the students. Children and young people may find it easier to speak to you as a non-teacher if they are experiencing abuse or being neglected. In addition, our Educators are often well-placed to notice students’ behaviours and if their behaviour changes over time, which can be a tell-tale sign of abuse.

The purpose of this policy is to provide managers and Educators with information about safeguarding children and young people, and to give guidance on the procedures to follow should there be any concerns about the safety of a child or young person attending the school. The policy and procedures are aimed to ensure that, as far as reasonably possible, all children or young people are protected from harm, including risk from any inappropriate behaviour from a member of Union Education Group. It provides guidance on the risks that Educators should be vigilant about and how processes, such as recruitment and selection, are used to minimise some of these risks. The policy includes information on working as an Educator, particularly the role of the designated safeguarding lead, (DSL) to ensure pupils are safe and that Union Education Group are playing an effective role in keeping them safe.

Legislation and Key Documents

The legislative framework underpinning safeguarding of children and young people includes:
The Children Act (2004)
Prevent Strategy (2011)
Counter Terrorism and Security Act (2015)
Keeping Children Safe in Education (September 2019)
Working Together to Safeguarding Children (2018)
Add any local policies i.e. Local Authority polices that might be relevant

Safeguarding - Definition

In relation to children and young people, safeguarding and promoting their welfare is defined in ‘Working together to safeguard children’ as:
• Protecting children from maltreatment
• Preventing impairment of children’s health and development
• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care
• Taking action to enable all children to have the best outcomes
A child is defined as everyone under the age of 18 (United Nations Convention on the Rights of a Child).

Safeguarding is everybody’s responsibility.

Safeguarding is about embedding practices throughout the company to ensure the protection of children and young people wherever possible.

The NSPCC define child abuse as:
‘Any action by another person – child or adult – that causes significant harm to a child. It can be physical, sexual or emotional, but can just as often be about a lack of love, care and attention. We know that neglect, whatever form it takes can be just as damaging as physical abuse.’

Abuse can be caused by those inflicting harm or those who fail to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children. Abuse is not restricted to any socio-economic group, gender or culture.

Safeguarding - Types of Abuse

Types of Abuse
The following definitions of physical, sexual, emotional abuse and neglect are taken from Working Together to Safeguard Children:

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.

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.

Child sexual exploitation is a form of child sexual abuse. It 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, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

Upskirting, which typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm.

Serious violence Para 29-30

Emotional abuse

The persistent emotional maltreatment of a child such as to cause severe and persistent 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 cyber bullying), 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, though it may occur alone.

In the course of your duties, you may come across a child who isolates themselves from others; they may disclose details of how they are being abused. Any concerns you have should be reported as soon as possible.

The persistent failure to meet a child’s basic physical and/or psychological needs, is 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.

Child protection is part of safeguarding and promoting welfare. It refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.

In addition to physical, sexual, emotional abuse and neglect, the following are further risks to children and young people identified in Keeping Children Safe in Education and risks that staff need to be aware of and be vigilant about:
• Radicalisation into extremist ideas and terrorism: this involves looking out for adults and children who may express extremist ideologies, distribute material which promotes extremist ideas or demonstrate negative behaviour towards others based on their race, religion, sexual orientation etc. The government’s Prevent strategy aims to counter all forms of extremism including: far right ideologies; Islamist fundamentalism; football hooliganism; animal rights extremism etc. The underlying signs include spreading hate and advocating, being willing to or actually committing violence. The government has a de-radicalisation programme, Channel, where those who wish to spread hate and violence based on their extremist ideas are de-programmed.
• Domestic violence and abuse: this may come to your notice through disclosure by a pupil at the school; you may see bruising that is unlikely to have been caused by the usual rough and tumble that children often engage in.
• Bullying and harassment, including harassment based on discrimination against a protected characteristic: any form of harassment by an adult to a child or by one child to another is unacceptable. Where pupils use derogatory language based on a protected characteristic such as race, religion, gender, sexual orientation, gender identity, physical disability etc, it must be reported.
• Children missing in education: children going missing, particularly repeatedly, can act as a vital warning sign of a range of safeguarding possibilities. This may include abuse and neglect, which may include sexual abuse or exploitation and child criminal exploitation. It may indicate mental health problems, risk of substance abuse, risk of travelling to conflict zones, risk of female genital mutilation or risk of forced marriage.
• Female genital mutilation: FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences.
• Forced marriage: this is distinct from an arranged marriage and is when parents, or a parent, forces their child to get married against their will, i.e. the child does not give free consent, and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. Some communities use religion and culture as a way to coerce a young person into marriage, misrepresenting this as an ‘arranged’ marriage. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Forced marriage is illegal in England and Wales.
• Peer on peer abuse: Children can abuse other children. This is generally referred to as peer on peer abuse and can take many forms. This can include (but is not limited to) bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals.
• Sexual violence and harassment between children: sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children.
• 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 from urban areas to suburban and rural areas, market and seaside towns.
• Modern slavery: child slavery occurs when a child is exploited for someone else’s gain. It can include child trafficking, child marriage and child domestic slavery.


This is a process by which adults and other children, especially older children, use to establish control over a child with the ultimate purpose of exploiting them. The grooming can be for:
• Sexual exploitation
• Criminal exploitation
• Fundamentalism and terrorism.

The process of grooming for sexual exploitation involves:
• Targeting the victim – often someone who is vulnerable, lonely, emotionally needy, lacking in confidence or self-esteem
• Gaining the victim’s trust – groomers are very patient and invest a great deal of time in gaining trust. They have the long-term gain in mind.
• Filling a need – making the victim feel better about themselves; giving attention and also gifts and presents.
• Isolating the victim – creating situations where the victim is alone with the groomer and, little by little, cutting the victim off from friends and family.
• Sexualising the relationship – this occurs where the groomer has created sufficient emotional dependency so that the victim does not resist/cannot resist.
• Maintaining control - this is possible because through the processes above, the victim no longer trusts anyone else and trusts the groomer above all, which enables the groomer to manipulate the victim and control them completely.

Grooming for criminal exploitation or into fundamentalism is not very different. These also involve careful targeting, gaining trust, isolating the victim, filling a need, providing propaganda to make the victim willing to commit crimes, includes desensitising them to violence, and maintaining control.

Those individuals involved in grooming children are adept at convincing adults around them, and the children, that they mean no harm and that they are caring people.

Relevance to Your Role

In the course of your work, you may see behaviours in children that may suggest a safeguarding issue or risk, for example, children suffering from neglect looking for food, possibly even going through bins to find remnants of food thrown away by others or asking for food from you or others; children who appear to be poorly dressed or in a poor state of dress and cleanliness; you may find children avoiding lessons by hiding around the school or the grounds; children who appear to have expensive clothes and possessions, such as designer jewellery, watches etc may have acquired these as a result of being exploited, sexually or through involvement with criminal gangs. These are just some of the examples of how abuse manifests itself.

Vulnerable children and young people might find it easier to speak to you. Therefore, they may disclose information about being abused or exploited, or something which suggests that they may be being abused or exploited.

You may also come across information from within the local community about, for example, gangs, criminal activity, peer-on-peer abuse which school staff who do not live locally may be unaware of.

It is important that if you have any concerns about the safety of a child or children, no matter how small, that you report it immediately to the Designated Safeguarding Lead.

What to do if a child discloses any form of abuse to you

It is important to take the following action if a child decides they want to confide or disclose to you:
• Do not promise to keep it a secret – be clear that you will have to pass on the information
• Do listen to what they have to say
• Do not judge the child or show your own emotions i.e. do not show disgust; feelings of abhorrence or shock at what you are being told
• Do not give views about the allegations or the person about whom allegations are being made
• Reassure the child that they have done the right thing in speaking about what they are experiencing
• Reassure the child that whatever is happening to them is not their fault
• Take notes of what they say; if you are not able to write it down while they are disclosing, then do so as soon as possible after they have spoken to you
• Do not ask leading or probing questions or try to investigate it further yourself – this will be done by safeguarding professionals
• Any questions being asked should be to seek clarification only
• Make a report of disclosure as soon as possible to the Designated Safeguarding Lead.
• At the same time, or immediately following informing the person responsible for the safeguarding on-site of the concern make a report to the Project Co General manager.
• Do not speak to others unless they are professionally involved in the case, such as the designated safeguarding lead, the police, a social worker assigned to the case etc. You must maintain confidentiality about what has been disclosed and not share information inappropriately.


If you observe any member of Union Education Group behaving towards a child in a way that causes you concern, you should report this immediately to the Union Education Group office or the Safeguarding Lead. It is not the role of individual Educators to make a decision about whether the Educator they are reporting is guilty of an offence against a child. However, it is everyone’s responsibility to report suspicious behaviour or behaviour towards a child from another member of staff that concerns them. The company has a clear policy on how it handles such allegations and whether an investigation is necessary to establish the full facts.

If the member of Union Education Group staff is a senior member of staff, report your concerns to Harry Darell or Michael Phong Le, the company directors. You can also report directly to LADO, the local authority designated safeguarding lead.

Allegations about a member of staff maybe made by:
• A child
• Another Educator of member of staff at Union Education Group
• A contractor
• A visitor
• A volunteer
• A parent

If an allegation relating to safeguarding against a member of staff is substantiated, the DBS must be informed. There is a legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult. (see Keeping Children Safe in Education para 153)

Relationships with Pupils

As part of the day-to-day at Union Education Group many Educators will be interacting with children. It is important to remain polite and respectful towards students but on no account to form friendships either in person or on social media. If students or close relatives, such as a parent, request you to join their social media circle, you must refrain from doing so.

To keep yourself safe from false allegations, ensure that you are never alone in a room or a lift with a pupil from the school. Never offer to give lifts or gifts, no matter how small, to a student.

In addition, you should not need to enter changing rooms or toilets in your role. If you need to use the toilet ensure they are vacated before entering.

Be a positive role model and professional in your behaviour towards all students and families.

If any student is rude or disrespectful, or is behaving badly to a point of concern, you must report this to the to the Designated Safeguarding Lead.

You should ensure that you do not make any physical contact with a child or young person.

Do not take pictures or videos of students either deliberately or by accident. If you do need to photograph a part of the site or a specific area of the school as part of the process of repair and renewal, make sure this is done at a time when pupils are not around.


All Educators will be provided with training on safeguarding.

All Educators must read Section 1 of Keeping Children Safe in Education.

New Educators must complete any safeguarding training within the first month of starting work. The school’s designated safeguarding lead will provide training as part of induction for new Educators.

Relationship with the School and particularly the Designated Safeguarding Lead

Our Educators need to work closely with the safeguarding team and ensure that any concerns we have are shared for the safety of students.

It is unlikely that Union Education Group will deal directly with social services, the police or other agencies expect in the rare circumstances.

Any concerns reported by Educators will be shared as soon as possible with the school’s designated safeguarding lead.


All concerns that are reported should be recorded, no matter how small.

Records should be dated and contain brief but clear details. Copies should be shared with the designated safeguarding lead. Records must be kept safe and secure.

Safer Recruitment

One of the ways to keep children at the school safe is to make sure that the recruitment and selection process is carried out diligently so that anyone who may be unsuitable to be around children is appointed. This process is called ‘safer recruitment’ and involves a full range of checks, including an enhanced disclosure and disbarring service checks (DBS) to be made before anyone is employed.

It is important to note that those who wish to abuse children and groom them often seek out work, including voluntary work, in organisations that give them easy access to children and young people.

All prospective employees must be able to explain satisfactorily any gaps in their work history.

As part of the employment checks, prospective employees must show current ID; documents which confirm their address and right to work in the UK. In addition, where relevant, a police check may also be requested from a police force in another country.

If a DBS check is returned and it provides details of any prior offence, conviction, caution, or reprimand (other than parking or speeding convictions) we undertake a written risk assessment to support the final decision on whether any job offer stands or should be withdrawn.

All Educators must have, or apply for a DBS before beginning work. If an Educator os living abroad, they must provide an equivalent check. We require all staff to renew their enhanced DBS check every three years or we require all new staff to sign up to the update service provided by the DBS.

Expectations of All Educators

All Educators should:
• know and understand the company policy
• attend training as required, and update training when required
• be vigilant and look out for any signs that may indicate a child is at risk or in need of support
• be ready to listen to any concerns or disclosures from children in the school
• know the procedures to follow
• know who to report to
• understand how they are expected to behave around children and model positive behaviours and values.
• understand the requirements for confidentiality with regard to safeguarding information while also being aware of the need to share this information with relevant agencies and safeguarding professionals.

Expectations of the Safeguarding Lead for Union Education Group

• Attend safeguarding training and updates
• Understand policies and procedures required to safeguard children
• Be familiar with Keeping Children Safe in Education and Working together to Safeguard Children
• Ensure that all new Educators complete the required training
• Ensure that concerns staff raise about safeguarding are passed onto the school’s designated safeguarding lead
• If an allegation is made against a member of staff, report this to company directors who will take the appropriate action
• In the event of a serious safeguarding issue, take responsibility for contacting the police and/or social services
• Ensure that any concerns have shared are properly recorded
• Maintain records of all concerns
• Ensure that the company policy is effectively implemented
• Check Educators understanding from time-to-time by asking individuals what they would do in various situations.

Expectations of the Safeguarding Lead for Union Education Group

• Ensure that the company policy is implemented by all staff and Educators
• Monitor the policy, and review and revise it as needed annually
• Promote a positive safeguarding culture where safeguarding is everybody’s responsibility
• Ensure that all Educators and staff know their responsibilities in relation to keeping children safe, who to report to if they have a concern and what to do if a child discloses abuse
• Create and maintain an environment where children and staff feel safe and secure
• Ensure that appropriate training is in place including training by the designated safeguarding lead
• Ensure that recruitment and selection of new employees/Educators are conducted in line with safer recruitment requirements and all the required checks are carried out
• Deal appropriately with any safeguarding complaints or allegations made against a member of Union Education Group