Policy and Procedure for Safeguarding and PREVENT

What is the policy about?

The scope of our Safeguarding and Prevent policy and duties extend to Learners and Clients, Employees and Associates, Customers/Employers, Suppliers, Sub-contractors and External Stakeholders and visitors. By detailing the Safeguarding policy, KB also include the Prevent policy. A concern related to Prevent should be treated in the same way KB should treat a safeguarding concern. This means that any member of the groups is at risk of radicalisation regardless of whether they are classed as vulnerable or at-risk individuals.

Safeguarding is the term that describes the function of protecting all of our learners.

At present we have no learners who under the age of 18.

This includes the following:

• Ensuring that the wellbeing of adults is promoted. This includes taking the adults views, wishes, feelings and beliefs into account in deciding any action.
• Protecting the rights of adults to live in safety, free from abuse and neglect.
• Working together with organisations to prevent and stop the risks and experience of abuse or neglect.
• Recognising that adults sometimes have complex interpersonal relationships and as a result may be ambivalent, unclear or unrealistic about their personal circumstances and thusly puts their safety or well-being at risk.

It is an important priority and a key responsibility of KnowledgeBrief (KB) and its employees. All suspicions or allegations will be taken seriously. Employees should be aware that the needs of the those at risk are paramount.

Prevent is one element of the government’s counter-terrorism strategy. It aims to stop people from becoming terrorists or supporting terrorism. The Counter Terrorism and Security Act (2015) has placed a further statutory duty on all training providers to “have due regard to the need to prevent people from being drawn into terrorism”. It also aims to promote British Values which include democracy, rule of law, individual liberty and mutual respect and tolerance.

Why is it important?

KB’s mission is to deliver an outstanding experience to its learners and an excellent service to its clients.

As a provider of high-quality education, development, and qualification services, we have a clear duty of care to our clients and learners. As a provider of government funded schemes, we have an obligation to support the ethos and objectives of those schemes. In addition to these requirements, our research-based findings and insight confirm the importance of a psychologically safe environment to deliver high performances. We believe that a safe place for learning is essential for achieving the best possible results in business and in personal development.

For these reasons, the following principles are essential elements of KB’s culture:

• The welfare of all learners in general and adults at risk is KB’s primary concern.
• All learners have a right to safeguarding from abuse.
• It is everyone’s responsibility to report any concerns about abuse, neglect or radicalisation to the Designated Safeguarding Lead (DSL).
• All incidents of alleged poor practice, misconduct and abuse will be taken seriously and responded to promptly and appropriately.
• All data will be processed in accordance with the Data Protection Act.

Other Key Terms

What is abuse?

Abuse is any behaviour towards a learner that deliberately or unknowingly causes significant harm, endangers life or violates their rights. Abuse includes physical, sexual, emotional, psychological, financial, material, neglect, acts of omission, discriminatory and institutional abuse.

Significant harm is not only ill-treatment (including sexual abuse and forms of ill treatment which are not physical) but also the impairment of, or an avoidable deterioration in, physical or mental health, and the impairment of physical, intellectual, emotional, social or behavioural development.

Who is a vulnerable adult?

A vulnerable adult is defined as a person “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation” (Department of Health 2000).

What is meant by Radicalisation?

Radicalisation is a process which somebody goes through in order to support or become involved in extremist activities or terrorism. An individual’s initial beliefs are not the primary indicator of potential radicalization. Individuals who initially have strong, moderate or no particular opinions can be radicalized. It can be a process that happens online or in meeting people, and their conversations and their opinions are gradually changed over time.

British Values

Democracy is the culture built upon freedom and equality where all opinions matter and where all voices and opinions count.

Rule of Law is about agreed rules and responsibilities which are fair and clear to ensure a safe, happy and secure place to live and work.

Individual Liberty involves the protection of your rights and the rights of others you work with.

Respect and Tolerance for all with different faiths and backgrounds and celebrating diversity.

On our KBPro platform we have a technique on British Values and its application in todays business world. When learners join the programme they are asked the read this technique and complete the associated insight question.

These values are exemplified at KB, and all relate with the Equality Act 2010.

Please see APPENDIX A.

Safe Learning Environment

A safe learning environment is one:

• In which the health, safety and welfare of learners has been assessed and any special needs are identified and catered for.
• In which staff are alive and vigilant to the possibility of abuse and take measures to prevent that possibility howsoever observed.
• Where there is a sound and known reporting system for any incident.
• Where staff take reasonable and practical precautions to avoid any suspicions of abuse being brought against them.

Occasionally we will use external speakers at our training days. We have an external speaker’s policy which all of our external speakers are required to read and sign.

This policy ensures that:

• Speakers will not act in a manner of intolerance that demeans any individual or group based on their ethnicity, race, religion and/or belief, sexuality, gender, disability, age or lawful working practices and which give rise to an environment in which people will experience, or could reasonably, fear harassment, intimidation or violence.

If an incident occurs where these standards have not been met then we ask that you contact your Skills Coach or the safeguarding team – [email protected] .

How do I report a safeguarding concern?

If you have a question or concern regarding safeguarding or prevent you can contact your Professional Learning Advisor (PLA) or the KnowledgeBrief safeguarding team:  [email protected] .

If you have a question or concern regarding safeguarding or prevent you can contact your Skills Coach or the KnowledgeBrief safeguarding team: [email protected]

If you prefer to reach out to your Skills Coach, that is fine. They will then pass it onto KnowledgeBrief’s Designated Safeguarding Lead (DSL).

If you yourself are going through a challenging time we can provide you with a number of organisations who may be able to help you. Please contact [email protected] or your Skills Coach.

KB Application

Our approach is as follows: KB’s 5 Ps

• Prevention

  It is better to act before harm occurs. We help identify and report signs of concern, abuse (verbal or otherwise), radicalisation and extremism, and suspected criminal offences. In all our work, we consider how to make people safer. We prevent issues by utilising the onboarding calls and induction of learners to identify specific needs, safeguarding learner disclosure sheets allowing learners to disclose vulnerability so we can support them through their studies, informing clients and learners about KB Safeguarding services, having a KB Safeguarding area (Support Centre), and Support Teams and ongoing educating and training for KB employees to prevent issues from occurring.

• Proportionality

  Deliver a proportionate and least intrusive response appropriate to the risk presented in order to protect the welfare of any potential vulnerable adult. We discuss with the individual and where appropriate, with partner agencies what to do where there is risk of significant harm before we take a decision. Risks are an element of many situations and should be part of any wider assessment. An appropriate response involves the DSLs, risk assessments, action plans, links with external agencies and intervention strategies.

• Protection

  To provide support and representation for those in greatest need, we have effective ways of assessing and managing risk. Our complaints and reporting arrangements for abuse and suspected criminal offences operate effectively and we promote active dialogue with KB employees. Effective communication and dialogue, identify and report to DSLs, lock away files, storage of sensitive data (pastoral log system/ format).

• Partnership

  Finding local solutions through services working with communities. We encourage sharing information locally. Development of links and trust with the community and external agencies, e-bulletin, sharing of information and good practice from partners and KB.

• Personal Accountability

  Adopting accountability and transparency in delivering safeguarding. The roles of all employees are clear, together with the lines of accountability. Staff are trained to understand what is expected of them and others, and recognise their responsibilities to each other, act upon them and accept collective responsibility for safeguarding arrangements. Have transparency of the DSL’s roles and your roles as KB staff and ensure you all know the correct procedures when raising a safeguarding issue.

KB has a Designated Safeguarding Lead (DSL), whose role is to:

• Receive information from any employees/ learners who have safeguarding concerns and record it.
• Assess the information promptly and carefully, clarifying and obtaining more information about the matter appropriately with the relevant people.
• Make a formal referral to the police and/or other external agencies where required so to do.
• DSL has links with Counter Terrorism Regional Coordinators: Jake Butterworth and Jennie Fisher (London).
• Ongoing monitoring and assessment of learner welfare.
• Ongoing training of KB employees.
• Update learners about safeguarding and prevent.

All allegations against KB Employees will be immediately investigated by the DSL. If an allegation is made against the DSL then the Chief Executive will conduct the investigation.

What I need to do?

KB employees should be aware that the needs of the adult or child at risk are paramount and must always act in the best interests of the adult or child at risk. If in doubt consult the Designated Safeguarding Lead (DSL). Employees should always adhere to the Safeguarding policy and accept training offered to keep updated and informed. KB employees should work together to safeguard those they work with and know how to report a concern through the appropriate KB safeguarding reporting procedures. KB employees should remain aware about extremism and radicalisation threats on a local, national and international scale.

Procedures for Safeguarding

• It is important that you NOTICE the situation and do not ignore any identified concern/s. If a safeguarding issue is brought to your attention, this must be treated as a priority over all other work.
• Then you should CHECK the concern by getting information correctly from the individual, if the individual feels comfortable sharing. If in doubt speak to the DSL for guidance. For safeguarding cases it is better for the DSL to carry out the check.
• In case of disclosure or reasonable belief of a safeguarding issue, you should SHARE immediately, by sharing your concern with a member of the Safeguarding Team.
• An oral, then written report should be provided to the DSL who will keep a confidential record of any such information.
• Guidance about a specific incident may be obtained from the DSL
• The DSL will assess the situation and if considers that there has been or is reasonably likely to be an incident of abuse or neglect or there are radicalisation threats and concerns, they will report the matter to the relevant third parties.
• The matter will be reported with consent if the individual is over 18 unless there are concerns around immediate harm to life or to the harm of someone under 18.
• Always remember and apply the NOTICE; CHECK; SHARE method.

  Disclosure of Abuse

  • If an individual has disclosed an incident or prolonged period of abuse it is important that leading questions are not asked.
  • You should remain vigilant, making proper and accurate notes.
  • In the event the individual disclosing the abuse is over 18 and has mental capacity then disclosure of this abuse is based on their consent.
  • If you have any questions, please reach out to KB’s DSL or Deputy.

Learner and Client Outcomes

Safeguarding has an impact on learners and clients because such issues may affect our clients’ employees – i.e. learners on our courses. Therefore, any issues arising will be handled sensitively and effectively with our customers will value our proactive approach. Learners will be supported with their studies and all KB employees will know how to deal with safeguarding concerns/ issues.

Safer Recruitment

All staff who have substantial access to apprentices have been checked as to their suitability to work. This included verification of their identity and qualifications, satisfactory references, a satisfactory barred list check, an enhanced DBS check, a right to work in the UK check, and additional overseas checks for those who have lived or worked abroad.

Once the DBS checks are complete, the DBS will send a certificate (the DBS certificate) to the applicant. The applicant must show the original DBS certificate to their potential employer before they take up post or as soon as practicable afterwards. Where we allow an individual to start work in regulated activity before the DBS certificate is available, the College ensures that the individual is appropriately supervised and that all other checks, including a separate barred list check, have been completed.

A Single Central Record of employment checks is held by People Management and checked quarterly. The information that is recorded in respect of staff members is whether the following checks have been carried out or certificates obtained, and the date on which each check was completed/certificate obtained:

Induction and Safeguarding Training

All individuals will receive an induction into their learning/employment and working environment. KB will make all parties aware of our commitment to equality and diversity, and how to make us aware of any dissatisfaction or concern.

KB will ensure continual Safeguarding training and regular updates from the Safeguarding Team. Regular training and workshops regarding other areas of safeguarding will be organised to ensure that policies and procedures are embedded within the culture and practice of KB.

Whistleblowing

We recognize that learners cannot be expected to raise concerns in an environment where staff fail to do so.

All staff are aware of their duty to raise concerns about the attitude or actions of colleagues and are regularly reminded of this. Staff are aware how to raise concerns and who to share these with. This is detailed in our Whistleblowing Policy which should be viewed alongside this policy.

Whistleblowing concerns about the CEO or any other senior manager in relation to the abuse of apprentices should be in writing to the Board Director.

Where a staff member feels unable to raise an issue with their employer or feels their genuine concerns are not being addressed, other whistleblowing channels may be open to them.

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: [email protected].

Staying Safe Online

As a blended learning provider, the vast majority of our programme is administered and accessed online by both learners and staff. Therefore, it is important for all parties to understand how to stay safe online.

We recommend reading the NCSC Stay Safe Online Guidance created by the UK government. This detailed guidance and advice, as well as top tips, on how to stay safe online.

How does KB support learners in staying safe online?

Action	Results
Robust safeguarding policy.	Appropriate understanding and steps are taken with online safety by both apprentices, staff and the business more broadly.
Visible information, contact and reporting mechanisms on KBProfessional.	Learners can see information whilst online about how to recognise and report any issues.
Password protected and ringfenced learning platforms for each client.	Only learners form the specific client can access their individualised URL.
Password protected platforms.	No non-learners are able to access the platform.
Training sessions: Zoom links are only accessible through the KBProfessional platform.	Only learners with active passwords are able to attend sessions.
Training sessions on Zoom have a password and waiting room.	Access is only granted to recognised and registered attendees.
Training sessions undertaken and facilitated carefully by KnowledgeBrief staff with appropriate safeguarding training and knowledge.	Learners are guided through the sessions effectively and interactions are facilitated to ensure they are appropriate.
Learners are taught about the appropriate way to deal with data security, working from home and professional online interactions in their programme.	This ensures everyone regardless of previous experience understands what is required to keep themselves and others safe online.
Online discussion centres on platforms are checked regularly by KnowledgeBrief employees.	Any inappropriate language or sentiment is picked up and removed and relevant action taken with the apprentice.
Cyber essentials accredited.	Ensures we are meeting relevant online and data safety.

Protocol for online meetings and 1:1s with learners to keep everyone safe and interactions professional.

Do:

• Ensure your safeguarding training is up-to-date.
• Ensure you have agreed the protocols and timing of all 1:1 on-line activity with under 18s or vulnerable adults with parents/carers prior to the 1:1 taking place, including appropriate location, dress and conduct. The 1:1 must then take place only at the days/times agreed with parents. Parents and carers should be present in the home at the time. If at any time you feel uncomfortable with something done or said during a 1:1 call, you should end the call as soon as possible and report any concerns to your line manager and / or safeguarding officer.
• Test your audio and video before a scheduled call.
• Record any live classes so that the video can be reviewed if any issues arise.
• Be punctual and courteous. Introduce yourself and take note of other attendees’ names so you can address them by name. Turn off call tone on your phone. Treat this just like you would a face-to-face meeting with a student, colleague or other adult.
• Conduct yourself in a professional manner throughout the call - as an employee you represent the company and its professional values throughout the call.
• Conduct video calls to learners or colleagues from a desk or other appropriate location.
• Remind students that all audio/video may be recorded, to safeguard both parties and this wouldn’t routinely be shared.
• Make sure to have current version of any software and applications loaded before scheduled calls. Test your audio and/or video before a scheduled call.
• Look at your screen, pay attention to others and when speaking make sure to look at your camera.
• Use the ‘blur background option’ to hide any background, if needed.
• When you have your video on you can see yourself and your surroundings just as others on the call can, so check this.
• Make sure you have good light. Adjust lighting or use a portable light source to make sure you have good lighting on you from the front without having to look directly into a harsh light, e.g.: by pointing a strong desk lamp at the wall you’re facing.
• Ensure you are appropriately dressed; smart business attire or ‘business casual’ at all times.
• Mute your microphone when not needing to talk to avoid background noise.
• Keep sessions to a reasonable length to avoid interfering with family activity.
• Consider posting your comments/questions on completion of the on-line conversation, in the chat window.

Don't:

• Multi-task; your audience will be aware.
• Shout; the other participants will tell you if they cannot hear.
• Click your pen, tap on your desk or anything else annoying or distracting.
• Eat or drink, other than water, tea / coffee.
• Position yourself with other people or pets in view; what’s around and behind you can be seen.
• Leave multiple applications open during the call as it may affect the quality.
• Wear stripes or heavy patterns creating pixelation of images.

Useful further guidance:
https://www.tes.com/news/coronavirus-10-safeguarding-rules-teachers-home
https://learning.nspcc.org.uk/news/2020/march/undertaking-remote-teaching-safely/
https://www.nspcc.org.uk/keeping-children-safe/online-safety/internet-connected-devices/

Policy Links

Safeguarding Policy

https://www.gov.uk/government/publications/ofsted-safeguarding-policy

Safeguarding and Radicalisation

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/635262/Safeguarding_and_Radicalisation.pdf

Prevent guidance

https://www.gov.uk/government/publications/prevent-duty-guidance

Keeping Children Safe in Education (2020)

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/954314/Keeping_children_safe_in_education_2020_-_Update_-_January_2021.pdf

Approval

This policy has been remotely approved by our Board and is available on our website.

References and further reading

KB Techniques:

• Social Learning Theory
• Corporate Social Responsibility
• Emotional Intelligence
• Assessing Health and Safety
• British Values

See:

• SAFE (Safer Activities for Everyone) standards
  https://www.safecic.co.uk

Link to KB Business Processes (KB Business Process handbook in progress)

This policy links to the following policies which make up part of the KB Business Process Handbook:

Staff Safeguarding and Welfare Policy

Whistleblowing

Bullying and Harassment

Special Educational Needs

Health and Safety

Equality and Diversity Inclusion

Data Protection Policy

Social Media Policy

Complaints

APPENDIX

APPENDIX A

British Value	How does KB exemplify these?
Democracy	Freedom to choose which training days to attend. Learner feedback surveys Learners have freedom to express their thoughts at sessions through open and collective discussions The majority of level 5 learners select their own study units based on preference Discussion boards SCAN publications discussions ILJ flexibility and freedom Curriculum/ resources/ PLA equal opportunity Catered approach for special needs
The Rule of Law	Safeguarding GDPR Harassment and bullying SEN Health and safety Equality, Diversity and Inclusion Complaints Email privacy policy Conflict of interest policy Social media policy Working at home policy External Speakers Policy and Training day procedures Curriculum- Techniques on the platform
Individual Liberty	Working at home policy Flexible working SEN adjustments Safeguarding policy
Mutual Respect and Tolerance	KB employees come from different faiths and backgrounds Learners and clients come from different sectors, abilities, SEN learners are welcome on our programmes Support team assists learners with mental health, learning support needs.

KB Safeguarding Policy, 01/03/2021, VERSION 1.8