Safeguarding and Child protection Policy

Policy Statement

This plicy focuses on the measures in place for students of any age who are under the care of Oxford Education Ltd, with the best interests of the student being at the centre of our work. In line with our company aims, this policy supports Oxford Education’s duty to safeguard and promote the welfare of students and to create a culture of safety, equality and protection in our workplace.

Oxford Education Services is committed to safeguard and promote the welfare of children at any age under our care and to protect children from the risk of harm and potential abuse.

The purpose of this policy is to provide staff, volunteers and homestays with the framework they need in order to keep children safe and secure whilst they are in our care. The policy also informs parents, agents and partner schools how we will safeguard their children whilst they are in our care. We will give equal priority to keeping all children and young people safe regardless of their age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation. Accepting children with different abilities can have different safeguarding challenges to support their development and protect them from all forms of abuse and safeguarding issues.

This policy also aims to create a culture of safe recruitment, adopting procedures to help identify people who might be a risk for children and create an environment where staff remain vigilant. It is to ensure that all of Oxford Education Services staff, local coordinators, host family and volunteers have a valid enhanced DBS check, understanding their roles and responsibilities in respect of identifying risks of safeguarding issues, reporting concerns and are provided with regular training opportunities to develop their knowledge, understanding and professionalism.

This policy ensures appropriate action is taken in the event of an incident/ concern reported to Oxford Education Services and that the support is provided to individuals who raise/ disclose the concern. It ensures that confidential, detailed and accurate records of all safeguarding concerns will be kept safe and securely stored.

This policy will be reviewed every year after development or sooner in accordance with the latest government guidance,as required by the LSP and as a result of any other significant change or event.

This policy is made with reference to Statutory Guidance for Schools and Colleges on Safeguarding Children and Safer Recruitment in Education, Department for Education, July 2015; Keeping Children Safe in Education, September 2022; Working Together to Safeguard Children, 2018. It also makes use of guidance from the NSPCC website.

Child Protection Principles

The following principles underpin our provisions and practices in relation to safeguarding and child protection:

• Oxford Education and Services will provide a safe and secure environment for all students;

• Homestays and transfer companies provide a safe and secure environment for all students;

• All students feel safe, secure and protected from harm;

• All students know who to turn to for help, advice or support, can access services confidentially, quickly and easily and have access to 24-hour support;

• Oxford Education and services have overall responsibility and accountability for the safeguarding and welfare of the students;

• All staff share in the responsibility to protect students from harm, remain vigilant in identifying safeguarding and child protection issues and to follow policies and procedures relating to safeguarding and child protection;

• Students and staff have effective means by which they can raise child protection concerns or report issues;

• Staff have at least one reliable means to contact all students quickly and directly;

• Staff are aware of the medical or learning needs of individual students via the Student Record;

• In cases where the whereabouts of a student under Oxford Education and Services is not known or the student is believed to be at risk of harm, procedures to locate the student by the safest and quickest means possible, or secure the safety of the student will be invoked immediately by following the Missing Student policy;

• The company has procedures in place that enable child protection concerns and incidents to be dealt with promptly and effectively and in line with relevant legislation.

• Oxford Education and Services is committed to the protection of all children in its care. We are committed to safeguarding student welfare and undertake rigorous checks on all who work with us and we expect all staff, volunteers and homestays to share this commitment.

• Safeguarding students is the responsibility of us all, including full-time, part-time, contracted, agency and volunteer staff including those who do not have cause to come into direct or regular contact with students in order to carry out their daily duties. It also applies to those who provide homestay accommodation for our students and third party contractors.

The safety and welfare of children, or Child Protection, means protecting children from physical, emotional or sexual abuse or neglect where there is an identified risk. Safeguarding is the minimisation of the risk to children from all forms of child abuse including for example:

• child sexual exploitation

• radicalisation and extremism

• female genital mutilation

• physical, emotional, sexual abuse or neglect

• domestic abuse

• online abuse

• bullying and cyberbullying

We aim to ensure that the students in our care experience at all times a caring and secure environment in which they feel safe, respected and valued.

In pursuit of this aim, Oxford Education & Services undertakes the following:

1. Training is provided for all staff and homestays to a level appropriate for their role (see training section below);

2. We promote an environment of trust, openness and clear communication between students, school and Oxford Education and Services  staff and our Homestays, so that student welfare, safety and pastoral care is recognised as the top priority;

3. We respond to any reported low- level concerns，allegation or suspicion of child abuse in accordance with the  Oxford Education and Services procedures as outlined below;

4. We ensure that all guardianship personnel, homestays and personnel offering outsourced services who come into direct contact with students in our care, are recruited using safer recruitment practices and are formally screened through the completion of an enhanced DBS check;

5. We maintain links with the appropriate agencies who have a statutory responsibility to deal with child welfare and child protection concerns. If you have any reason to believe that a child in your care is suffering from any form of abuse or neglect then please report it immediately in confidence to the DSL using the contact details listed in this policy.

Supporting procedures

This policy is to be read in conjunction with the following policies and documents:

• Anti-bullying and Cyber-bullying and E- safety policy

• Anti-Radicalisation – Prevent Duty Policy

• Missing student Policy

• Safer Recruitment Policy

• Staff and Homestay Code of Conduct

• Whistleblowing Policy

• Emergency procedure (This includes information on the guardianship organisation’s approach to foreseeable emergencies, such as a pandemic.)

Definitions

1. Safeguarding is defined as: “protecting children from maltreatment, preventing impairment of children’s mental and physical health or 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” (Keeping Children safe in Education, 2022). Safeguarding children is the term used to cover all aspects of promoting a child’s welfare.

According to Working Together 2018, safeguarding children is defined as:

• Protecting children from maltreatment: Protecting children from harm, abuse and neglect.  

• Preventing impairment of children’s health or development: Ensuring children have access to the care and support they need.

• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care: Enabling safe and effective parenting.

• Taking action to enable all children to have the best outcomes: Giving children equal opportunities in life.

2. ‘Child Protection’ is a part of safeguarding and promoting welfare. The term refers to the activity undertaken to protect specific children who are suffering or at risk of suffering significant harm.

3. ‘Designated Safeguarding Lead (DSL)’ is the person identified as taking the lead in safeguarding matters in an organisation. This person will be trained to a higher level.

4. ‘Prevent’ is the name given to part of the government's strategy to prevent terrorism by reducing the possibility of radicalisation.

5. ‘Local Safeguarding Partnership (LSP)’ : Formerly Local Safeguarding Children Board (LSCB) and consisting of the local authority, the clinical commissioning group within the local authority and the chief office of police within the local authority.

6. ‘LADO’ :The role of the Local Authority Designated Officer (LADO) is to coordinate all allegations and concerns made against a person who works with children.

7. ‘Children’ : ‘Children’ includes everyone under the age of 18.

8.‘MASH’: The Multi-Agency Safeguarding Hub (MASH) is the single point of contact for all professionals to report immediate safeguarding concerns and make referral. If there is an immediate safeguarding concern where a child is deemed at risk or has potentially suffered significant harm, the MASH team should be contacted immediately. MASH enables the sharing of information across police, social care and medical services to identify risks to vulnerable adults and children.

9.‘LCSS’: The LCSS provides anonymous consultation to universal professional partner agencies including schools, health and voluntary and community groups when emerging concerns are raised for children that do not require an immediate safeguarding response.

Designated Safeguarding Lead

Oxford Educarion Services Designated Safeguarding Lead (DSL) is Dr. Iling Lee. Concerns about any member of staff must be reported to the DSL or directly to a statutory authority including Crimestoppers or the NSPCC Whistleblowing Hotline.

The DSL has lead responsibility for safeguarding and child protection and is expected to:

- refer cases of suspected abuse to the local authority children’s social care as required;

- support staff who make referrals to local authority children’s social care;

- refer cases to the Channel programme where there is a radicalisation concern as required;

- support staff who make referrals to the Channel programme;

- refer cases where a person is dismissed or left due to risk/harm to a child to the Disclosure and Barring Service as required;

- refer cases where a crime may have been committed to the Police as required.

- liaise with the head teacher or principal to inform him or her of issues especially ongoing enquiries under section 47 of the Children Act 1989 and police investigations;

- as required, liaise with the “case manager” and the designated office and liaise with staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with relevant agencies; and act as a source of support, advice and expertise for staff.

DSL of Oxford Education Services is trained by (OSCB, Oxfordshire Safeguarding Children Board) to Level 3. Annual safeguarding refresher training is made available to staff at the yearly conference. Level 1 training (Awareness of Safeguarding) has also been made available to all host families with a request for completion. All host families need to refresh safeguarding training every 3 years.

Safeguarding information for all staff 

Oxford Education and Services is aware that protecting children is a matter of national importance. We also understand that no single practitioner has a full picture of a child’s needs and circumstances. Oxford Education Services recognises itself as a part of the wider safeguarding system for Children. Therefore, we will work together with schools and local authorities to provide our services.

To better fulfill our role and our responsibilities, we provide training to our staff so that they can identify concerns/risks and take necessary actions to report their concerns. Staff need to be able to excise their professional curiosity to identify the problem. We share information with other childcare organisations in the spirit of safeguarding and protecting children. We will also make sure every incident will be carefully recorded and stored securely on a confidential computer drive by the Director and will be reviewed to improve our services so that we can better protect children’s welfare.

Oxford Education Services also aims to be alert to the potential need for early help for children who have special educational needs or disabilities.

Any child may benefit from early help, our staff is trained to be alert to the potential need for early help for a child who have the following conditions:

• Certain health condition (Disable)

• A mental health need

• Special education need

• A young carer

• Showing sign of being drawn into anti-social group

• Frequently missing from education/ goes missing from host family

• Family circumstances presenting challenges (mental issues, drug, abuse)

• Misusing drugs and alcohol

Abuse and Neglect 

Apart from identifying the need for early help, this policy is also to protect children from all forms of maltreatment and prevent impairment of children’s health and development. We understand that Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm to a child or  by failing to prevent harm to a child. 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., school, in the organisation or host family. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children. There are indicators of abuse and neglect, which all staff should be aware of. There are four types of abuses:

Physical abuse — may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child or failing to protect a child from that harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a child.

The NSPCC says that some signs and indicators of physical abuse are:

Bruises: commonly on the head but also on the ear or neck or soft areas – the abdomen, back and buttocks defensive wounds commonly on the forearm, upper arm, back of the leg, hands or feet clusters of bruises on the upper arm, outside of the thigh or on the body bruises with dots of blood under the skin a bruised scalp and swollen eyes from hair being pulled violently bruises in the shape of a hand or object.

Burns or scalds: can be from hot liquids, hot objects, flames, chemicals or electricity on the hands, back, shoulders or buttocks; scalds may be on lower limbs, both arms and/or both legs a clear edge to the burn or scald sometimes in the shape or an implement for example, a circular cigarette burn multiple burns or scalds

Bite marks: usually oval or circular in shape visible wounds, indentations or bruising from individual teeth.

Fractures or broken bones: fractures to the ribs or the leg bones in babies multiple fractures or breaks at different stages of healing.

Other injuries and health problems: scarring effects of poisoning such as vomiting, drowsiness or seizures respiratory problems from drowning, suffocation or poisoning.

Sexual abuse – involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact including both penetrative (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing,  rubbing and touching outside of clothing. They may 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.  Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education (See Pear on pear abuse).

The NSPCC says some signs and indicators of sexual abuse are as follows:

Children who are sexually abused may: Stay away from certain people; they might avoid being alone with people, such as family members or friends; they could seem frightened of a person or reluctant to socialise with them; show sexual behaviour that’s inappropriate for their age; a child might become sexually active at a young age; they might be promiscuous; they could use sexual language or know information that you wouldn’t expect them to; have physical symptoms: anal or vaginal soreness; an unusual discharge;sexually transmitted infection (STI); pregnancy.

Emotional abuse — Emotional abuse is 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. This form of abuse 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, though it may occur alone. The NSPCC says some signs and indicators of emotional abuse may be that:

Babies and pre-school children who are being emotionally abused or neglected may be overly-affectionate towards strangers or people they haven’t known for very long; lack confidence or become wary or anxious; not appear to have a close relationship with their parent, e.g. when being taken to or collected from nursery etc.; be aggressive or nasty towards other children and animals.

Older children may use language, act in a way or know about things that you wouldn’t expect them to know for their age; struggle to control strong emotions or have extreme outbursts; seem isolated from their parents; lack social skills or have few, if any, friends.

Neglect – Neglect is the persistent failure to meet a child's basic physical and/ or psychological, likely to result in serious impairment of the child’s health or development.Neglect may occur during pregnancy, for example, 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.

Neglect is dangerous and can cause serious, long-term damage – even death.

The NSPCC says some signs of neglect are as follows:

“Neglected children” may be smelly or dirty; have unwashed clothes; have inadequate clothing, e.g. not having a winter coat; seem hungry or turn up to school without having breakfast or any lunch money; have frequent and untreated nappy rash in infants.

They may have untreated injuries, medical and dental issues; repeated accidental injuries caused by lack of supervision; recurring illnesses or infections; not been given appropriate medicines; missed medical appointments such as vaccinations; poor muscle tone or prominent joints; skin sores, rashes, flea bites, scabies or ringworm; thin or swollen tummy; anaemia; tiredness; faltering weight or growth and not reaching developmental milestones (known as failure to thrive); poor language, communication or social skills.

They may be living in an unsuitable home environment for example dog mess being left or not having any heating; left alone for a long time; taking on the role of carer for other family members.

Further Detail on specific types of abuse

The following information is taken from Keeping Children Safe in Education (2022). Please refer to this document for further details, including additional types of abuse. 

Safeguarding issues

All staff and homestays should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and sexting (also known as youth produced sexual imagery) put children in danger.

Child on Child abuse 

All staff and homestays should be aware that children can abuse other children (often referred to as peer on peer abuse). This is most likely to include, but may not be limited to:

• bullying (including cyberbullying);

• physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm;

• sexual violence, such as rape, assault by penetration and sexual assault;

• sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be stand-alone or part of a broader pattern of abuse;

• 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;

• Sharing nudes/semi nudes (also known as sexting/ youth produced sexual imagery); and initiation/hazing type violence and rituals.

Serious violence 

All staff and homestays should be aware of indicators, which may signal that children are at risk from, or are involved with serious violent crime. These may include increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs.

Children missing from education

All staff and homestays should be aware that 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. Early intervention is necessary to identify the existence of any underlying safeguarding risk and to help prevent the risks of a child going missing in future. Staff should contact the students’ school or college should they suspect a student is missing from education. The school or college will have a procedure for reporting this absence.

Child sexual exploitation 

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. Like all forms of child sex abuse, child sexual exploitation:

• 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;

• can still be abuse even if the sexual activity appears consensual;

• can include both contact (penetrative and non-penetrative acts) and noncontact sexual activity;

• can take place in person or via technology, or a combination of both;

• can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence;

• may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media);

• can be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse; and

• is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources. Some of the following signs may be indicators of child sexual exploitation:

• children who appear with unexplained gifts or new possessions;

• children who associate with other young people involved in exploitation;

• children who have older boyfriends or girlfriends;

• children who suffer from sexually transmitted infections or become pregnant;

• children who suffer from changes in emotional well-being;

• children who misuse drugs and alcohol;

• children who go missing for periods of time or regularly come home late; and

• children who regularly miss school or education or do not take part in education.

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. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. 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 or 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, this power 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

Honour-based violence (including Female Genital Mutilation and Forced Marriage)

So-called ‘honour-based’ violence (including Female Genital Mutilation and Forced Marriage) So-called ‘honour-based’ violence (HBV) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take. All forms of HBV are abuse (regardless of the motivation) and should be handled and escalated as such. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBV, or already having suffered HBV.

Actions

If staff have a concern regarding a child that might be at risk of HBV or who has suffered from HBV, they should speak to the designated safeguarding lead. As appropriate, they will activate local safeguarding procedures, using existing national and local protocols for multi-agency liaison with police and children’s social care. In schools, where FGM has taken place, since 31 October 2015 there has been a mandatory reporting duty placed on teachers- if a teacher, in the course of their work in the profession, discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report this to the police.

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

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties 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. 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). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools and colleges can play an important role in safeguarding children from forced marriage.

Domestic Abuse

The cross-government definition of domestic violence and abuse is:

Any incident or pattern of incidents of controlling, coercive, 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.

The abuse can encompass, but is not limited to:

• psychological;

• physical;

• sexual;

• financial; and

• emotional.

Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children through seeing, hearing or experiencing the effect of domestic abuse. Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.  In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Upskirting

‘Upskirting’ 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. It is now a criminal offence.

Online safety

The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation: technology often provides the platform that facilitates harm.

The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk:

• content: being exposed to illegal, inappropriate or harmful material; for example pornography, fake news, racist or radical and extremist views;

• contact: being subjected to harmful online interaction with other users; for example commercial advertising as well as adults posing as children or young adults; and

• conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example making, sending and receiving explicit images, or online bullying.

Oxford Education and Services recognises the risks posed to students online. Oxford Education will inform the host family to set parental control/ filters on their internet system. Further information can be found in the e-safety and bullying (including cyber-bullying) policies.

Oxford Education Services works to ensure that all members of staff are aware that the responsibility for specific safeguarding issues and child protection from all forms of abuse belongs to everyone, and that families, communities and professionals must work together to promote their welfare.

Mental Health

All staff should be aware that mental health can be an indicator that a child has suffered or is at risk of suffering abuse neglect or exploitation (Keeping Children safe in Education, 2022).

If staff have a mental health concern about a child, they should treat it as a safeguarding concern and act on it. Following OES safeguarding policy, they should report to their DSL or a deputy safeguarding lead.

Procedures

When new staff, volunteers or homestays join our organisation, they are informed of the safeguarding arrangements in place, the name of the DSL and how to share concerns with them. Please note that the usual reporting channel is via the DSL, however anyone can make a referral directly to the LSP or LADO. The contact details are included in the end of this document.

Responding to individual safeguarding concerns

• Staff must respond promptly to any safeguarding concerns (including mental health concerns) and submit their concerns in writing to the DSL.

• Incidents of students being reported as absent or missing from Oxford Education Services (for example half terms or exeat weekends), must be dealt with as per the Oxford Education Absent or Missing Student Policy. Students who are reported as absent or missing from school premises during term time are accommodated by the relevant school’s missing student policy.

• All reports to Oxford Education and Services from local coordinators, schools and students are initially regarded as children in need. The Safeguarding Lead is notified. The record is created on the Guardianship Student Record in order for the incident to be effectively managed, the safety of the student to be maximised and any risk to be minimised. Any report pertaining to Child Protection will be automatically classified as a RED incident. Incident form and Low-level concern form in Appendix will be used.

• The incident is investigated through discussions with the school, parents, LC’s, existing records and other agencies as appropriate. Parental consent for referral will be sought unless the child may be at risk of significant harm or there may be the risk of a loss of evidential material. All verbal conversations should be recorded in writing.

• The information is evaluated (assessment) on the day of receipt and a decision made and recorded regarding what next actions to take and/or outcome. This could include referral or no further action (with the provision of information and advice or signposting to another agency). Oxford Education Emergency Meeting to decide on future actions, or emergency action to protect a child through the statutory authorities (e.g. Police or Social Services) where there is a risk to the life of a child or the possibility of serious immediate harm. (Refer to Oxford Education Absent or Missing Student Policy).

• A member of the Senior Management Team must review, approve the outcomes of the incident and ensure the record has been updated.

• Where a crime may have been committed the police must be informed at the earliest opportunity, and they will decide whether to commence a criminal investigation. The reporting of the matter to the police must be recorded.

Concerns/ allegations against a member of staff or homestay

• If the allegation/ low level concerns are made about a member of the guardianship organisation staff or homestay, the DSL must contact the LADO immediately and follow their advice. They must not investigate themselves. If the allegation is about the DSL, please contact Dr. Helen Wu who will contact the LADO and follow the advice as above.

• Low level concerns: anyone working with children (staff/ host family) behaved in a way that may have harmed a child or possibly committed a criminal affence against or related to a child; behaved in a way that indicates he/she may pose a risk of harm to children; may have behaved in a way that indicates they may not be suitable to work with children.

• romptly to the DBS any person whose services are no longer used for regulated activity because they have caused harm or posed a risk of harm to a child.

How to receive a disclosure from a child or young person

• Reassure the child and listen carefully – it is important that they know you believe them

• Do not say you will not say anything to anyone – in fact you have a duty to disclose this to another person so do not promise confidentiality

• Make sure you take detailed notes, write everything down

• Ask open questions if appropriate, do not lead the conversation to find out what has happened. Use words such as tell me, explain or describe, and allow the student to speak

• Avoid words such as what, why, how when – these will be asked by the relevant agency if appropriate.

• Ensure that you notify the police by calling 999 if you believe that the young person is at immediate or serious risk of harm

• Contact the DSL Dr. Iling Lee as soon as practicable and in any case within 24 hours

• If the disclosure is made out of hours, please use the emergency phone number 07714145162.

Safeguarding measures, training and development

Oxford Education Services students are provided with a student handbook which states important safeguarding issues, how to keep themselves safe in the UK and details the 24 hours 7 days a week emergency number should they wish to contact staff from Head Office.

Students are provided with information on what to do if they need help or advice while in the UK. The handbook is a safeguarding measure and outlines to students where they can go to obtain help and support if they are troubled. It also includes contact details for the NSPCC, Samaritans and Police.

We aim to ensure that the students in our care experience at all times a caring and secure environment in which they feel safe, respected and valued. In pursuit of this aim, Oxford Education Services undertakes the following:

To train Head Office staff to a minimum of Level 1 Child Protection training. Training is available from Oxfordshire Safeguarding Children Board (www.oscb.org.uk). Head Office staff maintain the responsibility of responding to concerns raised by students, parents, schools, other guardianship personnel, host families and transfer companies.

To ensure Head Office staff record any allegations/concerns in an incident and refer them to the DSL, Dr. Iling Lee. Where appropriate concerns will be reported to the relevant Children’s Services or Multi- Agency Safeguarding Hub (MASH) in the local area.

To ensure that Oxford Education Services DSL or Duty Manager is available for advice and guidance if staff are not sure whether a referral to Children’s Services is required.

To ensure that all guardianship personnel and partners (for example, travel companies and host families where possible) receive Child Protection Awareness Training and to make them and the students in our care aware of the need to report allegations and suspicions of child abuse to Head Office. In cases where the strategic leads are unavailable, staff must make direct contact where appropriate with the local Children’s Services or MASH On Duty Team, as delay could put a child/Young Person at further risk of harm. Contact with the local Children’s Services or MASH is made via the telephone numbers available on the Local Authority website.

To promote an environment of trust, openness and clear communication between students, school and Oxford Education Services staff and our host families, so that student welfare, safety and pastoral care is recognised as the top priority.

To respond to any reported allegation or suspicion of child abuse in accordance with the Oxford Education Services Safeguarding Policy and those set out in the Child Protection Procedures of the Association for the Education and Guardianship of International Students (AEGIS).

To ensure that all guardianship personnel and personnel offering outsourced services who come into direct contact with students in our care, are recruited using safe recruitment practices and are formally screened through the completion of an Enhanced DBS check

To maintain links with the appropriate agencies who have a statutory responsibility to deal with child welfare and child protection concerns. If you have any reason to believe that a child in your care is suffering from any form of abuse or neglect then please report it immediately in confidence to Dr. Iling Lee or Dr. Helen Wu by telephone at the office or out of hours via the emergency telephone.

To circulate regular safeguarding and child protection updates to all staff and partners (where possible) to ensure that the most current and comprehensive information is made available to them.

Safer recruitment

Safer recruitment of staff members (including Local Co-ordinators and Host Family Inspectors) and partners (host families and travel companies), is aligned to the Department for Children, Schools and Families ‘Safeguarding children and safer recruitment in education’ (2010).

The document sets out the highest standards of safeguarding and promoting the welfare of children and recruitment best practice (some areas underpinned by legislation) for schools, local authorities and further education sectors. The guidance contained within this document is relevant for Oxford Education Services who are responsible for children (under 18’s) and who work in partnership with schools, colleges and universities.

Oxford Education Services has individual policy and process documents for staff, travel companies and host families which are designed to maximise the safeguarding and welfare of our students according to the role being performed:

Safer recruitment for staff members

Oxford Education Services has a Safer Recruitment Policy for staff which includes Head Office Staff, Local Coordinators and Host Family.

The recruitment of staff in accordance with the principles of Safer Recruitment ensures that employees are recruited in an effective and secure way, and is designed to deter candidates who would be unsuitable to work with children.

A curriculum vitae (CV) will only be accepted alongside a full application form and is not sufficient on its own to support safer recruitment.

Oxford Education Services seeks references with comment on work, professional competence and personal qualities from each application to obtain objective and factual information to support appointment decisions. Referees are asked to comment on the applicant’s suitability to work with children, to outline any concerns about the applicant with children or any disciplinary details.

Oxford Education services will also consider online searches as part of their due diligence checks on shortlisted candidates.

Safer Recruitment of Transfer Companies

Oxford Education Services only uses school recommended licensed transfer companies and school badged taxi drivers for our students.

Safer Recruitment for Oxford Education Host Families

Oxford Education has a specific safeguarding policy for the recruitment of host families who care for students for periods of less than 28 days, for example during half terms, exeat weekends, periods of sickness or other occasions when the school is closed. Oxford Education Services does not provide private fostering for students (i.e. for periods over 28 days) though is aware of the mandatory duty to inform the local authority of children where such arrangements exist.

The Safer Recruitment Policy outlines the processes which ensure the highest level of safeguarding is afforded to our students while staying with a host family.

The new host family should meet the requirement for ID and DBS checking. They also need to provide two references to satisfy our requirements. This applies to all family members who are 16 years old and over.

The host family will be requested to obtain Level 1 Safeguarding training certificate and require to complete safeguarding training every 3 years.

Oxford Education Services will pay a visit and conduct an inspection before recruitment of a new host family.

Oxford Education will review all our host families regularly, at least annually.

A statement of Whistle blowing Policy

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. The wrongdoing disclosed must be in the public interest.

Oxford Education Services Whistleblowing Policy is to encourage all Oxford Education staff to report any serious concerns about any aspect of the company or the conduct staff or others acting on behalf of the company in order to improve our practice.

Oxford Education Services believes that reporting of suspected wrongdoing in the workplace involving systemic or procedural failures can help safeguard children or staff from risk. This is in support of our commitment to safeguarding and promoting the welfare of children and young people. Oxford Education expects all staff, partners and volunteers to share the commitment to the company’s overall aim.

Oxford Education Service Ltd encourages all staff to report a whistleblowing under those circumstances which follows the law and places the safety of others at the forefront of their duties. It could be any aspect of the company including such as:

• Child protection or safeguarding concerns

• damage to the environment

• a criminal offence

• negligence at work

• health and safety concerns

• financial fraud or mismanagement

• the employer is failing to comply with his legal obligation

• not obeying the law

• covering up wrongdoing

Our company hopes that in many cases staff could report their concerns with the manager or director, speaking to them in person or putting the matter in writing first. However, the employee has the right to take their concern to an independent body such as regulator (AEGIS), environment agency and Health & safety Executive, if they feel it has not been addressed adequately or if an allegation is about a senior member in Oxford Education Services. We strongly encourage the staff to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. Please see the contact details below:

Public Concern at Work (Independent whistle blowing charity)

Helpline: 020 7404 6609

E-mail: whistle@pcaw.co.uk

Website: www.pcaw.co.uk

The NSPCC Whistleblowing Helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and email: help@nspcc.org.uk

Information Sharing

• Oxford Education recognises that keeping children safe from harm requires the early, effective sharing of information and is a vital element of safeguarding and child protection, as per ‘Information Sharing’ March 2015 and ‘Working Together To Safeguard Children’ 2018: “Effective sharing of information between professionals and local agencies is essential for effective identification, assessment and service provision”

• Oxford Education recognises the need for confidentiality of their student, school, host family, staff and transfer company records and works in adherence to GDPR and the Data Protection Act 2018. (Refer to Confidentiality and General Data Protection Regulation Policy)

• In the case that a child is believed to have been put at risk or is likely to be put at risk of harm, staff will use their professional judgement when making decisions on what information to share and when. As per HM Government Information Sharing Advice for Safeguarding Practitioners 2015, GDPR, “The Data Protection Act 2018 and human rights law do not prevent the sharing of information for the purpose of keeping children safe, but a framework to ensure that organisation and individuals process personal information fairly and lawfully and keep the information they hold safe and secure.“

• Oxford Education company procedures should be followed and staff should consult with their manager if in doubt. Such decisions on disclosure should be proportionate to the extent of the harm that a child may be or has been exposed to. Where any doubt exists about sharing the information concerned, advice will be sought from other practitioners without disclosing the identity of the individual where possible.

• Oxford Education will be open and honest with the individual (and/or family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.

• Oxford Education will share with informed consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information.

• Oxford Education understands that information can still be shared without consent if, in our judgement (based on facts), there is good reason to do so, such as where safety may be at risk. When sharing or requesting personal information from someone, Oxford Education staff will be aware of the basis upon which they are doing so. Where Oxford Education have consent to share information, staff are mindful that an individual might not expect information to be shared.

• Oxford Education considers safety and well-being of the individual and others who may be affected, when forming information sharing decisions.

• Oxford Education will only share information which is necessary for the purpose for which the information is being shared, will share information only with those individuals who need to have the information, will ensure the information is accurate, current and is shared in a secure and timely fashion.

Confidentiality/Data Protection Policy

Oxford Education services staff have access to personal confidential information about students, their families, and staff members. This information is stored securely in the Director’s computer and processed in accordance with GDPR and the Data Protection Act 2018. The principles of this Act are considered when sharing confidential information when legally permissible and when in the interests of the child. Oxford Education adhere to the principles of GDPR and the Data Protection Act 2018 which are to ensure that the information is:

- used fairly and lawfully

- used for limited, specifically stated purposes

- used in a way that is adequate, relevant and not excessive

- accurate – kept for no longer than is absolutely necessary

- handled according to people’s rights

- kept safe and secure

- not transferred outside the European Economic Area without adequate protection

Oxford Education Services will only share records with those who have a legitimate professional need to see them. Staff should never use confidential or personal information about a pupil or her/his family for their own, or others’ advantage (including that of partners, friends, relatives or other organisations). Information must never be used to intimidate, humiliate, or embarrass the child.

Confidential information should never be used casually in conversation or shared with any person other than on a need-to-know basis.

In circumstances where the pupil’s identity does not need to be disclosed the information should be used anonymously. There are some circumstances in which a member of staff may be expected to share information about a pupil, for example when abuse is alleged or suspected. In such cases, individuals have a responsibility to pass information on without delay, but only to those with designated safeguarding responsibilities.

Oxford Education Staff should not promise confidentiality to a child or parent, but should give reassurance that the information will be treated sensitively. All safeguarding records will be kept in the students’ files and locked away in the director’s office. Only the director has the key to access the files. Any digital records will be stored securely with a password in the director’s computer. Only the director can have access to these data. All staff have to gain the permission from the director to access the data.

If a member of staff is in any doubt about whether to share information or keep it confidential he or she should seek guidance from the Designated Safeguarding Lead. Any media or legal enquiries should be passed to senior management

Enquiries or complaints in relation to misuse of data should be directed to Dr. Helen Wu, Director. If further advice needs to be sought, contact can be made with the Information Commissioner’s Office (ICO) – ICO Helpline Telephone 0303 123 1113. The ICO can investigate claims and take action against anyone who’s misused personal data (https://ico.org.uk/concerns/)

Local Agency Contact

The company is aware of how to access local agency contacts; this includes Local Safeguarding Partnerships across the country.

Oxfordshire Local Authority Designated Officer team - 01865 810603 / LADO.SafeguardingChildren@oxfordshire.gov.uk. (For all allegations and concerns made against a person who works with children.)

Local Authority Designated Officer (LADO) and schools safeguarding team manager, Alison Beasley: Email: Alison.Beasley@Oxfordshire.gov.uk or 01865 815956/ 07833 436649.

ChildLine：ChildLine is free helpline for children and youn people in the UK. The contact number is 0800 1111.

In addition, the company is aware of the non-emergency reporting procedures via the Local Authority’s Children’s Services relevant to the area (e.g., LCSS for Oxfordshire)  https://www.oxfordshire.gov.uk/residents/children-education-and-families/childrens-services/integrated-childrens-services/locality-and-community-support.

If you have a concern about a child, please call Multi-Agency Safeguarding Hub (MASH) on 0345 050 7666 (OSCB for Oxfordshire) or by telephoning the non-emergency Police number 101.

For emergency situations, the company is aware of the need to contact the relevant police force for the area by dialling 999.

Oxford Education Services Ltd Contact

The Designated Safeguarding Leads (DSL) and Prevent Lead for the Company is:

Dr. Iling Lee, Manager, who can be contacted on 01865 240616 or iling.lee@englongeducation.com

Concerns in relation to the Manager should be addressed to the Director, Dr. Helen Wu (helen.wu@englongeducation.co.uk).

Concerns in relation to the Director should be addressed to Dr. Iling Lee (iling.lee@englongeducation.com).

Concerns about any of the above can be directed to Crimestoppers which will remain confidential.

Emergency contact number: 07714145162

For general enquiries and concerns please contact:

Office Contact number: 01865 240616

Email: oes@englongeducation.com

Appendix 1: Incident Form

CHILD PROTECTION RECORD – Report of a Concern

For DSL/ DDSL use:

Appendix 2: Low Level Concern Form

HIGHLY CONFIDENTIAL

 Record of low-level concern

 Summary of low-level concern(s):

(Including date(s) and contextual information) 

Initial action taken and decisions reached:

How low-level concern was followed up and by whom:

(Including date and those in attendance when any consultations / meetings were held) 

Outcome of investigation: *

(Including rationale) 

If applicable, outcome of any formal disciplinary hearing (including date of outcome letter sent to employee/host family/other): 

If applicable outcome of any formal appeal hearing (including date of outcome letter sent to employee/ host family/other). 

For low-level concerns, if the concern(s) relate to misconduct or poor performance, is the individual aware this information will be referred to in any future reference?       Yes / No   (NB references must be factual and not contain opinion) 

Employee / Host family / Other - Comments: 

Signed / Dated: 

Guardianship Organisation Director / named person in policy 

……………….………………………              Date:………………………………….. 

Employee/Host/Other : 

………………….……………..…………                                Date: …………………………………. 

A copy of this form should be retained confidentially on the personnel file for the individual at least until they leave employment.

Review

We are committed to reviewing our policy and good practice annually.

This policy was last reviewed on: …11/11/2022…………………………(date)

Signed: ….……………………………………………………………………

Date: ……11/11/2022……………………………………………………………………