1. Jack Edwards is the Swift Designated Safeguarding Lead (DSL) delegating to Jodi Feerick in the role of Deputy Designated Safeguarding Lead (DDSL) who will carry out the role of DSL, reporting to Jack Edwards.
Safeguarding will be a shared responsibility between both the DSL and DDSL.
2. The DDSL, DSL & Safeguarding Board Representative have overall accountabilities for all policies and procedures relating to safeguarding, welfare, Prevent Duty, and British Values. Specific duties are highlighted within this policy, but the DDSLs will implement all necessary measures to develop and maintain a culture of safeguarding and welfare.
3. There are 8 Designated Safeguarding Officers (DSO’s): Jemma Jones, Jessica Jones, Amy Langwith, Rachel Howard, Jayne Hipkiss, Stuart Beer, Sara Lewis and Lisa Merricks. These 8 officers will deputise for the DSL/DDSL in their absence. They will have responsibility for upholding and promoting the aims and purpose of this policy, supporting the DSL/DDSL & Board Representative to develop and maintain a culture of safeguarding and to complete the specific tasks referred to in this policy.
Introduction and Scope
This policy relates to all activities of Swift ACI (referred to as “Swift” from herein).
All stakeholders working with, working for, or in learning with Swift are expected to comply with this policy, including employers. For the avoidance of doubt, all contracts entered into by Swift will be covered by this policy, including those for contract, volunteers and contractors.
This policy will apply from the initial engagement of all relationships with stakeholders. This includes the recruitment process for Learners and apprentices, employees, volunteers and contractors.
Swift is fully committed to safeguarding the welfare of all stakeholders. Swift will take all reasonable steps to safeguard the welfare, health, safety and well-being of all stakeholders, including and particularly children, young people and vulnerable adults.
The company commits to creating an environment for employees, Learners and apprentices that:
• Promotes British Values.
• Safeguards welfare.
• Reduces the risk of exposure to violence.
• Reduces the risk of exposure to abuse.
• Reduces the risk of exposure to extremism.
• Reduces the risk of exposure to discrimination.
• Reduces the risk of exposure to victimisation.
• Reduces the risk of exposure to exploitation.
All stakeholders, by working with Swift confirm that they will conduct themselves in a manner that upholds Swift’s commitment to safeguarding individuals and in accordance with this policy.
Swift embeds the principles of the 5 R’s; Recognition, Response, Reporting, Recording, Referral.
Swift adopts a multi-level approach to Safeguarding to ensure that Safeguarding is dealt with effectively at an operational level, as well as strategically throughout the organisation (see Appendix 1 – The Swift Approach to Safeguarding)
Policy Aims and Objectives
Swift believes it is unacceptable for any person to experience abuse, violence, discrimination etc. of any kind. This is particularly abhorrent if it involves a vulnerable group, such as children, young people or vulnerable adults.
This policy has been developed to outline the responsibilities of employees, volunteers, contractors, sub-contractors, employers, learners and apprentices and other stakeholders for the recognition, reporting and prevention of abuse.
This policy provides the overarching principles of the organisation concerning Safeguarding.
This policy should be read in conjunction with The Safeguarding Processes, The Equality and Diversity Policy, Learner Code of Conduct and Employee Code of Conduct.
The Safeguarding Processes provide a detailed framework within which all staff should operate when dealing with safeguarding concerns.
Swift is committed to the following objectives:
• To recognise that all children and vulnerable adults regardless of gender, religion, age, ethnic origin, disability, and sexuality, learning difficulties or any other grounds have a right of equal protection from all types of harm or abuse.
• To ensure that all reported concerns, issues or incidents are dealt with in an appropriate and timely fashion.
• To ensure that all personnel have a comprehensive induction that provides them with the knowledge and skills needed to support the aims of this policy, and our adjoined Prevent Duty Policy; and to be confident in identifying Learners and apprentices at risk of becoming vulnerable to abuse.
• To provide regular refresher training to all personnel around Safeguarding and Prevent Duty.
• To comprehensively support our Learners and apprentices to understand British Values, Prevent Duty and ways they and others may become vulnerable throughout their lives. To support their understanding of how to support themselves and others and how to raise a concern.
• To ensure that all Learners and apprentices and others within scope of this policy understand their obligations pursuant to this policy and are committed to its implementation. This includes the parents of children and young people as part of our workforce or cohorts of Learners and apprentices.
• To promoting this policy to and gaining commitment from, employers.
• To promoting the right of all persons to be free from abuse of any kind.
Swift is committed to reviewing all its policies regularly, including the Safeguarding Policy. This will be conducted every year as a minimum but also in the following circumstances:
• A change to legislation.
• An external incident that is publicised.
• A serious occurrence within the business that requires further consideration.
• A trend analysis identifies an increase in reports of a specific type of vulnerability.
• Recommendations made by an Awarding Body, OFSTED or the EFSA.
Promotion of this Policy
All personnel will receive a comprehensive induction that provides them with the knowledge and skills needed to support the aims of this policy, and our adjoined Prevent Duty Policy, and be confident in identifying Learners and apprentices at risk of becoming vulnerable to abuse.
All Learners and apprentices will receive a comprehensive induction that ensures they understand how to access this policy, how to report concerns and provides a broad understanding of Equality and Diversity, Safeguarding, Prevent Duty and British Values. Personnel undergo regular continuous professional development to refresh these skills.
Employers are engaged at the very start of the relationship, to develop their understanding of the concepts and aims of this policy and to support them to support the protection of all individuals against abuse.
Regular progress reviews are utilised to provide further support and refreshers to employers around the concept of this policy. Supportive materials such as welfare and wellbeing support resources are regularly provided via social media and direct connect routes.
The policy and its procedures are available to personnel via the company SharePoint system, and all other stakeholders via the company website.
Regular “Safeguarding Hot Topics” are promoted via assessors, SharePoint, local notice boards, the website and the learning platform. These are provided to all stakeholders, including employers.
Safeguarding, Prevent Duty and British Values are integrated into all curriculum plans and workbooks and are regular refreshed with Learners, apprentices and employers, by assessors.
A quarterly Safeguarding Focus Group Meeting is held involving all DSL/DDSLs & DSOs to identify trends, areas of concern and areas of improvement to shape, review and inform Safeguarding Policy & Process. Apprentice and employer voice mechanisms are considered during this process.
Statutory Obligations and Useful Guidance
In all cases, Swift will fully comply with its obligations when dealing with all individuals. When dealing with children, young persons or vulnerable adults, the following legislation is particularly pertinent:
• Keeping Children Safe in Education 2022
• Working Together to Safeguard Children 2018
• UK GDPR and Data Protection Act 2018
• The Protection of Children Act 1999
• The Safeguarding Vulnerable Groups Act 2006
• The Equality Act 2010
Disclosing Abuse: Staff Awareness
All staff should be aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experience as harmful. For example, children may feel embarrassed, humiliated, being threatened. This could be due to their vulnerability, disability, and/or sexual orientation or language barriers. This should not prevent staff from having a professional curiosity and speaking to the DDSL if they have concerns about a child. It is also important that staff determine how best to build trusted relationships with children and young people which facilitate communication.
For this policy, a child is defined as anyone under the age of 18 including unborn children right up to teenagers. The following guidance provides more clarity around this definition:
It should be noted that in the event of a learner having an Educational Health Care Plan (EHCP) they are classed as a “Young Person” until their 25th birthday, and will therefore be treated as such for the purposes of Safeguarding.
A vulnerable adult is defined as any person over the age of 18 and at risk of abuse or neglect because of their need for support or personal circumstance. (Care Act 2014 England)
A vulnerable adult may be a person who:
• Has physical or sensory disability
• Is physically frail or has chronic illness
• Has a learning difficulty
• Misuses drugs or alcohol
• Has social and emotional issues
• Exhibits challenging behaviour
Abuse is a form of mal- treatment that is inflicting either by causing harm or failing to prevent harm. Abuse can occur in many settings. Some common settings of occurrence are; familial, institutional, individual and in groups.
Harm can include ill treatment that is not physical, as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse.
Swift recognises that abuse can occur to anyone in any situation but identifies the following clear types of abuse that can occur:
Abuse does not need to fall solely into one of these categories. Often an individual suffering abuse may experience several different types of abuse.
Physical abuse means causing harm, or failing to prevent harm, to an individual’s person. Where individuals have specific care needs, this can include a failure to properly restrain or a misuse of medication.
This includes but is not limited to:
Signs that someone may be suffering physical abuse may be:
• Unexplained bruising
• Flinching when approached
• Withdrawal or a change in behaviour
• Aggressive behaviour and temper outbursts
• Injuries inconsistent with the explanation
Sexual abuse involves the forcing or enticement of an individual (child or adult), to take part in sexual activities. This can include violence, but equally can be an act of coercion that restricts the individual’s ability to provide informed consent.
Sexual abuse includes but is not limited to:
• Penetration with an object
• Oral intercourse
• Looking at pornographic material or sex acts.
Sexual abuse can be committed by persons of any gender and any age group towards any gender and any age group.
Swift recognises the rise in peer-on-peer sexual assault cases and advocates an “it can happen here” approach to addressing sexual abuse/ assault.
Swift also recognises that sexual abuse can be perpetrated by those with institutional power. Swift again advocates the “it can happen here”, approach and provides for many prevention measures referred to later in this policy.
Swift recognises that it can be difficult for individuals, particularly children, young people, and vulnerable adults to talk about sexual abuse. Swift provides effective training to its personnel and stakeholders and commits to removing all barriers to the reporting of issues, incidents, or concerns.
Swift works closely with a counselling service that can provide confidential and specialist advice and support around sexual abuse.
Signs that a person (adult or child) is being sexually abused:
• Avoidance of a specific person. In cases of familial child sex abuse, this can include a family member.
• Sexually inappropriate behaviour to their individual developmental stage.
• Physical problems include medical problems with their genitals or pregnancy.
• Clues. Children, young people and vulnerable adults, due to their development stage, may struggle to articulate the issue, but they drop clues that abuse is occurring.
Reflecting the changes in national guidance as a consequence of the publication of revisions to ‘Keeping Children Safe in Education’ which became statutory on 9 September 2022, Sexual Harassment is now included in this policy as a category in its’ own right.
Swift ACI is committed to providing a safe environment for all its learners and staff free from discrimination on any ground and from harassment at work including sexual harassment.
Swift ACI adopts the approach that “it happens here” in line with the findings of the OFSTED review of Sexual Harassment and Abuse in Schools & Colleges that took place in June 2021 and encourages those affected by Sexual Harassment to voice their concerns to us.
Swift ACI operates a zero-tolerance policy for any form of sexual harassment, treat all incidents seriously and promptly investigate all allegations of sexual harassment.
Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from their training programme or employment.
All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.
Definition of Sexual Harassment
Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated.
It includes situations which create an environment which is hostile, intimidating or humiliating for the recipient. Sexual harassment may be physical, verbal and non-verbal.
Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:
• Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
• Physical violence, including sexual assault
• Repeated or unwanted invitations for social dates or physical intimacy
• The use of threats or rewards to gain sexual favour
• Comments on an individual’s appearance, age, private life, etc.
• Sexual comments, stories and jokes
• Sexual advances Insults based on sex
• Sending sexually explicit messages (by phone or email or social media)
• Display of sexually explicit or suggestive material
• Sexually-suggestive gestures
Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser.
We recognise that sexual harassment may also occur between people of the same sex and age. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.
We recognise that sexual harassment can be a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and staff member or trainer and learner.
All sexual harassment is prohibited whether it takes place within our training environment or outside, including at social events or training sessions.
• To have substantial and current experience of leading staff and/or teams in relation to safeguarding.
What will happen following a complaint of Sexual Harassment
Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome.
We recognise that it may not be possible for the victim to inform the alleged harasser. If a victim cannot directly approach an alleged harasser, he/she can approach the Designated Safeguarding Lead or any staff member.
When a staff member receives a complaint of sexual harassment, he/she will:
• Reassure the victim that the complaint will be taken seriously
• Record the dates, times and facts of the incident(s) by following the Swift ACI Safeguarding Disclosures Process
• Ensure that the victim understands the company’s safeguarding procedures for dealing with the complaint
• Discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally may still result in pursuing a formal complaint if he/she is not satisfied with the outcome
We recognise that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. We understand the need to support victims in making complaints.
If the victim wishes to deal with the matter informally, the person receiving the complaint will give an opportunity to the alleged harasser to respond to the complaint and ensure that the alleged harasser understands the complaints mechanism.
• Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to the Designated Safeguarding Lead who will ensure that a confidential record is kept of what happens
• Ensure that the above is done speedily and within the timescales identified in the Swift Safeguarding Disclosures Process.
If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.
Sanctions and disciplinary measures
Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:
• verbal or written warning
The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence or actual abuse, will result in the immediate dismissal of the harasser.
Emotional abuse occurs where there is persistent emotional ill treatment or neglect or rejection. It causes severe and adverse effects on a person’s behaviour and emotional, resulting in low self-worth.
Some level of emotional abuse is usually present in all forms of abuse. Emotional abuse can involve, but is not limited to:
• Overprotectiveness that limits the individual to learn and experience
• Silencing them
• Inference of conveyance that the individual is unloved or worthless
• Bullying (face to face/ cyber)
• Causing fright to fear consequence
• Expectations placed on an individual beyond their understanding or developmental capability
Signs that an individual is being emotionally abused include, but are not limited to:
• Developmental delay
• Personally over-critical
• Socialisation issues
• Behaviour change
Is the persistent or severe failure to meet a vulnerable person basic physical and/or psychological needs. It will result in serious impairment of the person’s health or development.
Neglect may include, but is not limited to:
• Failure to provide sustenance
• Failure to provide care needs
• Failure to adhere to medical practitioners’ guidance
• Failure to provide housing or removal of housing
Signs that an individual is being neglected can be:
• Dishevelled and unkempt appearance
• Appears dirty or smelly
• Is hungry. Perhaps steals food
• Is constantly tired.
Psychological abuse involves the regular and deliberate use of a range of words and non-physical actions used with the purpose to manipulate, hurt, weaken, frighten a person mentally and emotionally, and influence a person’s thoughts within their everyday lives.
Psychological Abuse can include:
• Name calling
• Insulting the person
• Threats against the person or a threat to take something away from the person
• Isolating the person
• Ignoring the person
• Excluding the person.
Signs that an individual is being psychologically abused can be:
• Withdrawal from support networks
• Unexplained paranoia
• Ambivalence about care giver
• Excessive tiredness
• Low self esteem
It is a misconception that financial abuse always involves fraud or theft. In fact, financial abuse is often subtle and can be therefore very difficult to detect.
Financial abuse is often used as part of other forms of abuse including domestic violence and psychological abuse.
Financial abuse may look like:
• Denying access to personal finances
• Tricking someone into bad investments
• Borrowing money or property and not returning it
• Forcing the sale of assets
Signs of Financial abuse include:
• Inability to access bank accounts
• Lack of money to pay for essentials
• Unusual payments in bank statements
Respond: Variety of Concerns
Personnel will receive initial concerns, disclosures, reports or complaints from all stakeholders in the apprenticeship relationship, from time to time. This may include, children, young people and vulnerable adults, as well as employers, concerned third parties, members of the general public, medical practitioners and other educational institutions.
All personnel are trained to respond to an initial disclosure, complaint, incident etc. in an appropriate manner and in line with company Safeguarding Processes. An overview of these processes can be found in Appendix 2 below.
All personnel will:
• Make the disclosure/ complainer feel as comfortable as possible without crossing personal boundaries.
• Listen effectively to the situation. Any interviews etc will be completed by trained personnel at a later stage in this process.
• Remain calm.
• Explain the Safeguarding Process to the individual to reassure them of how things will be dealt with.
• Avoid making unrealistic promises around confidentiality.
Report and Record
Recording Initial Disclosures, Incidents, Issues, Concerns
All disclosures, incidents, issues and concerns need to be reported and recorded. This applies in all situations and remains important even where the eventual decision of the organisation is to take no further action.
When recording a disclosure, incident, issue or concern, the Safeguarding Officer or front-line personnel should:
• Record all conversations exactly as they are stated. This should use the exact language of the individual, including their turn of phrase, swear words and event descriptions.
• Include factual observations where appropriate. This is likely to be required when reporting concerns, issues or incidents, or in situations where a disclosure is made and there are concerns relating to self-harm or continued harm against that individual. Factual observations should be just that. Try to avoid including personal opinions. Include only symptoms, such as visible bruises or withdrawn behaviour. Avoid interpreting these symptoms as supporting the disclosure.
• Notify the Designated Safeguarding Lead immediately following the conversation.
• Provide the record by email to the Designated Safeguarding Lead. This information should be sent to the Designated Safeguarding Lead. This is discussed in more detail in The Safeguarding Processes.
• Do not update the learner’s file. The Designated Safeguarding Lead will determine the best course of action and will update any files as required.
The Role of the Designated Safeguarding Lead and Safeguarding Team
The Deputy Designated Safeguarding Lead (DDSL) will carry out the role of safeguarding lead, reporting to the DSL, and is accountable for the safeguarding practices and culture within the organisation. They are also the final decision maker regarding serious disclosure, issues, incidents or concerns and their external referral to Local Authority Designated Officer (LADO) or other relevant body.
The DDSL will ensure a minimum of 2 deputies are in place, who are trained and possess the skills and authority to take accountability for these final decisions, in their absence.
The DDSL will ensure processes are in place to record all disclosures, issues, incidents and concerns, are recorded in a central, confidential and GDPR compliant central location.
On receipt of a Safeguarding record, the DDSL will review the matter and determine the course of action to be taken. Actions can include, pastoral intervention, further investigation, no further action (monitoring) and serious external referral.
In all instances, the DDSL will ensure that all decisions will prioritise the need to safeguard the individual from harm. In serious situations, this may involve the referral to a third-party body, against the wishes of the disclosing individual.
The DDSL will ensure arrangements are considered when dealing with a child, young person and vulnerable adult.
The DDSL will never make a decision that stretches the organisational resources (including personnel) beyond their capacity or capability. This measure ensures that individuals are always provided with the best care and support, by experts and the organisation avoids detailed specific involvement in matters for which they have no expertise.
The DDSL will consider all the facts before making a decision on the appropriate course of action.
The DDSL may utilise the Welfare Board to make decisions regarding appropriate actions to take in each case.
Monitoring: Taking No Action
The DDSL may decide that no action is required. If no action is determined, the DSL will ensure that the Safeguarding Record is centrally recorded and will confirm whether further monitoring of the situation is required.
Where monitoring is required, the DDDSL will ensure the appropriate arrangements are in place.
Pastoral Intervention covers a wide range of actions and is the most common action taken.
Pastoral intervention offers individuals support for a situation or group of situations that is causing them to currently be vulnerable to abuse or harm. The intervention will assist them with; obtaining financial support, receiving education, obtaining help with welfare needs, obtaining counselling or other therapy, or receiving medical support.
Pastoral interventions are ordinarily completed via an external referral to an approved third party. The DDSL will make the appropriate arrangements with the individual (their parents if required) and the referring company.
The DDSL will ensure that a central record is kept of the intervention.
The DDSL may decide that further investigation of the situation is required. It should be noted that in cases where a serious referral is required, the referral body such as the Police or LADO will conduct an investigation independently. Before deciding whether further investigation is needed, the DDSL should give consideration to the seriousness of the situation, so has not to commence an investigation that could ultimately prejudice the investigation of a body with more authority.
Further investigation can be either formal or informal.
Informal investigation may be a chat with the individual or a review of a particular ILP or learning plan.
In the case of further formal investigation for potentially serious issues, the DDSL will ensure:
• A full record of the investigation is centrally stored.
• Confidentiality (where disclosure is not required by law) is maintained.
• All individuals are treated with respect and in accordance with The Equality and Diversity Policy and in within the aims of this policy.
• All statements made are recorded in the actual language of the speaker and that in no circumstance are the personal views of the investigation team considered as part of the decision-making process.
The DDSL will review the output of the investigation and consider the appropriate action to take.
In cases where referrals to LADO/Police are made, the DDSL will communicate this with the ESFA in line with statutory requirements.
In the most serious of cases, the DDSL may be required to make a serious external referral. These types of referrals are detailed below.
Allegations Relating to the Abuse of Position of Those in Authority
Swift may receive allegations that relate to the abuse of a position or power. These allegations can relate to positions such as medical practitioners, carers, educational professionals, policepersons etc.
Whilst every effort is made to safeguard Learners and apprentices in the care of Swift, it may be the case that allegations are made relating to the abuse of position of our personnel. In this instance, personnel refers to employees, associates, subcontracts and volunteers.
In all instances of Abuse of Power, the DDSL will make a referral to the Local Authority Designated Officer (LADO).
The LADO should be alerted in all instances of allegation that a person in a position of power has:
• Harmed, or behaved in a way that may have harmed a person in their care.
• Committed a criminal offence against a person in their care.
• Caused a person in their care to feel at risk.
The purpose of the LADO is to ensure effective recording of allegations of abuse against those in positions of power who work with children, young persons or vulnerable adults. They act as an effective conduit between the provider and other organisations such as the Police and medical professionals.
The LADO should be notified within 24 hours of an allegation being paid. The DDSL retains accountability for this notification. Whilst the LADO does not investigate the case, they should be notified of the allegation prior to the investigation commencing. Thereafter, LADO will seek to provide advice and guidance to Swift on the best way to commence investigations.
On referral, the LADO will determine whether the allegation meets the threshold for their involvement, so where there is doubt, Swift will refer the matter to LADO in the first instance.
The LADO may determine that the allegation requires investigation by the Police. If this is the case, they will provide this advice. No internal investigation should begin until the LADO has made this determination.
In cases concerning an allegation relating to Swift personnel, the alleged perpetrators resignation does not bring the matter to a close. A full investigation should still be carried out. Whilst matters relating to the alleged perpetrators contract of employment are for Swift to determine internally, no settlement agreement will remove the co-operation of Swift from any
investigation to determine allegations of abuse of power against its personnel.
Allegations of Abuse Against a Third Party
Swift is committed to upholding its obligations to the legislation detailed in this policy and to the moral obligations of providing education.
Swift may receive allegations of physical or sexual abuse from a child, young person, vulnerable adult.
In these circumstances, Swift has a legal obligation to protect them from harm. This obligation includes the involvement of Local Authorities, the Police, the Ambulance Service and Social Services.
The Designated Safeguarding Lead will decide on the whether the situation requires the involvement of a third-party authority and will fully co-operate with any third party notified thereafter.
Referrals Around Child on Child Abuse
Swift operates an “it can happen here” approach to child on child abuse and recognises that smaller disclosures of bullying, sexting, social media abuse etc. can be symptoms of a much bigger pattern of abuse between peers.
Swift personnel are effectively trained to appropriately encourage conversations around child on child abuse and support individuals following disclosure.
Swift understands that often the fear of formality can deter Learners and apprentices from reporting child on child abuse. Swift values the voice of the learner and will (where it is appropriate to do so i.e.) support their wishes in dealing with matters.
“Appropriateness” in this instance refers to the seriousness of the circumstance and the individual learner’s age and capacity to understand the nature of the abuse. For the avoidance of doubt, in all situations Swift will prioritise the need to protect Learners and apprentices from harm.
Given the range of situations of that could occur under this title, Swift acknowledges that methods of addressing abuses can range from informal discussions with Learners and apprentices to expulsion from programme, or even the referral to the police.
In all instances of child on child abuse, the reporting process should be followed. The DDSL will have accountability for deciding the best way to deal with the individual situation.
For all other cases, where the allegation concluded to be either, unfounded, false, malicious or unsubstantiated, the case manager (and if they have been involved the LADO) should consider the facts and determine whether any lessons can be learned and if improvements can be made.
Gaining Commitment - Swift’s Prevention and Support Framework
Swift has established several measures designed to protect children, young people and vulnerable adults from abuse occurring whilst in learning or employment with Swift.
Swift recognises that to safeguard all stakeholders from harm, it is required to thoroughly and continually vet all contractors including volunteers.
To safely recruit Swift will:
• Ensure that recruitment practice is fair and inclusive.
• Thoroughly screen and check prospective personnel qualifications and suitability to work, prior to their appointment.
• Undertake DBS checks at the appropriate level for all successful applicants. Personnel will not be permitted to commence work until a DBS status is determined and a Risk Assessment completed where appropriate.
• Maintain records of all DBS details on a single, central register and ensure this is refreshed with a minimum regularity of 3 years.
• Ensure that personnel involved in the recruitment and vetting of new personnel are fully trained and that this training is regularly refreshed.
• That a system of governance and monitoring is in place to ensure that the safer recruitment practice is being followed.
Employee, Contractor, and Volunteer Induction
Swift commits that no category of employee will be permitted to begin work with Learners and apprentices and potentially children, young people and vulnerable adults, until they have completed a thorough induction process which includes the organisational practices around safeguarding and Prevent Duty.
A record of the attendance of personnel will be maintained by the HR department.
A system of governance is in place to ensure that this induction is completed for all categories of employee.
All Learners and apprentices enrolled onto programmes with Swift will complete safeguarding awareness training as part of their learner induction. This training will be recorded as part of the portfolio evidence for the programme and evidenced in the ILP.
An effective system of quality assurance is in place that will periodically sample the quality of this induction process. Quality assurance processes also provide for the consistency of delivery and learner experience through the induction process.
This induction will provide:
• Understanding around what safeguarding is.
• Understanding of what the Prevent Duty is.
• Recognising situations that they could become vulnerable to harm.
• A code of conduct for their behaviour.
• Minimum expectations of behaviour for those in positions of power or authority and how to sport inappropriate behaviour.
• Clear identification of the Safeguarding Team
• How to raise a concern.
Swift recognises that knowledge and skills need to be periodically refreshed to ensure that all stakeholders are fully equipped to meet their obligations and responsibilities pursuant to this policy.
A matrix detailing the status of Safeguarding and Prevent training will be maintained as part of the central register and retained by the HR department.
Employee and Volunteer Continued Training
Swift has a comprehensive CPD policy which provides for the continued refresher training of employees and volunteers.
Safeguarding, Prevent and Health and Safety training will be refreshed every three years at a minimum or in accordance with change to practice, policy or provision.
Contractor Continued Training
Contractors will retain responsibility for refreshing their qualifications in this area.
A system of governance is in place to ensure that all refresher training is conducted.
Learner Continued Training
Learners and apprentices are provided an individual Safeguarding Workbook as part of their programme that provides for periodic refreshment on the topic during their programme of study.
Safeguarding, Prevent, Health and Safety and British Values are embedded into all curricula and contextualised to the subject matter. This keeps the topics refreshed in Learners and apprentices’ minds throughout the programmes.
Periodic “hot topics” are explored with Learners and apprentices’ spotlight specific topics within Safeguarding and Prevent.
Swift recognises that the increase in online learning and the benefits of this medium of learning, increases the risk of harm to all stakeholders but particularly children, young people and vulnerable adults.
Swift has Acceptable Use Policies covering the use of IT equipment by all categories of employee and Learners and apprentices.
Swift recognises its responsibility to educate Learners and apprentices to the risks online and to support the development of critical thinking skills to support Learners and apprentices to remain safe. Critical thinking skills are embedded into all programmes.
Swift is aware that concerns can occur both online and offline simultaneously.
Misogynistic and misandrist concerns can also occur and should be taken very seriously. Swift will investigate all concerns immediately, being vigilant in their approach to all forms of on line risk.
Swift has secure online systems, which filter and monitor internet access, along with excellent processes for identification and escalation.
Swift discourages the use of applications other than those platforms provided by Swift, for communication by personnel with Learners and apprentices. The exception to this is where there is a significant and material benefit to the quality of education delivered. Such contact should be pre-approved by the Directorship and full transcripts provided for the LMS.
Unapproved contact of Swift Learners and apprentices by Swift personnel outside of the approved, internal learning platforms will be dealt with as gross misconduct in accordance with the Disciplinary Policy. This type of contact will be considered as an “abuse of position” in accordance with this policy and may also result in a referral to a LADO.
Where inappropriate contact from personnel to Learners and apprentices via social media involves a child, young person or vulnerable adult, or contains explicit content, incitement to commit criminal acts, or achieves the definition of any form of abuse pursuant to this policy; Swift will immediately involve the police.
Swift however recognises that the use of these platforms by our Learners and apprentices and personnel is highly likely in their personal lives.
Swift recognises its role in educating these categories of persons around safety online.
Being safe online includes awareness of the risks associated with communicating via the internet.
References to social media include social networking sites (such as Instagram and Twitter), social communication applications (such as WhatsApp), blogging sites, vlogging sites, community sites (such as Pinterest), auction sites (such as eBay) and sales platforms (such as Facebook).
Swift acknowledges the difficulty in legislating for all these different platforms and consequently adopts overarching principles when using these platforms. These principles are embedded into the program curriculum.
• Careful Content. To always communicate on these platforms as if you were face to face. Avoid the use of ambiguous statements that could be misinterpreted. Do not swear or use inuendo. Be as careful in content online as you would be in person. Be polite and respectful.
• Maintain confidentiality. Do not disclose things that should not be in the public domain. For personnel this includes adopting GDPR principles and avoiding referencing Swift or any learner. Learners and apprentices should avoid disclosing personal information such as their address, bank details etc.
• Avoid the Secret. Certain applications allow communications to be completely anonymous. These situations represent a greater risk to children, young people and vulnerable adults.
• Email. Private communications are safer when they are easily traceable. Email is a safer way to make sure you are communicating with someone genuine with good intentions.
Board Representative – Jack Edwards
Designated Safeguarding Lead - Jack Edwards
Telephone: 0121 595 0610
Deputy Designated Safeguarding Lead – Jodi Feerick
Telephone: 07538 422 750
Designated Safeguarding Officer - Jessica Jones
Telephone: 07757 779 539
Designated Safeguarding Officer – Jemma Jones
Telephone: 07791 287 717
Designated Safeguarding Officer – Rachel Howard
Telephone: 07791 200 259
Designated Safeguarding Officer – Jayne Hipkiss
Telephone: 07791 539 814
Designated Safeguarding Officer – Lisa Merricks
Telephone: 07964 119 220
Designated Safeguarding Officer – Stuart Beer
Telephone: 07875 009 366
Designated Safeguarding Officer – Amy Langwith
Telephone: 07375 347 278
Designated Safeguarding Officer – Sara Lewis
Telephone: 07791 213 727
Managing Director Name: Gregory Morrall
Reviewed on 06/07/2022
Review Due: 06/07/2023
Reviewed by: Jayne Hipkiss
Approved by: Jack Edwards
Appendix 1: The Swift Approach to Safeguarding
Our guiding principles on Safeguarding
-Safeguarding Focus Groups
-Swift Safeguarding Action Plan
- Swift Safeguarding Risk Assessment
-Swift Staff Induction Training
-Training on internal Safeguarding Process
-Safeguarding Refresher Training
-DSL / DSO Training
-Targeted CPD training based on local / organisational trends
DAY TO DAY OPERATIONS
-Reporting and Recording Safeguarding Concerns Process
-DSL / DSO Process for dealing with Safeguarding Concerns
-Continuous Monitoring of Safeguarding Concerns
-Pastoral Concerns Monitoring
- Identifying Safeguarding Trends
Appendix 2: Flowchart – Safeguarding Process Steps Overview
(For full, detailed steps refer to the Swift Safeguarding Processes SP02 – Dealing with Safeguarding Disclosures for Staff & SP03 – Process for DSLs & DSOs – the below provides a simple summary of the steps across both processes)/.
Safeguarding Disclosure made / Safeguarding concern identified
Staff member to RECORD the concern / disclosure using form SG01 in line with Swift Safeguarding Process.
Staff Member to REFER to DSL/DDSL/DSO in line with Swift Safeguarding Processes.
DSL/DDSL/DSO to review concern and decide on appropriate course of action.
DSL/DDSL to make referral to appropriate agencies, or to arrange appropriate monitoring where referral is not required.
Where the disclosure relates to PREVENT, DSL/DDSL to make referral to the appropriate PREVENT authority. Where referral is made to the Police /LADO, DSL/DDSL to inform the ESFA.
DDSL to share information on a need to know basis, and record further actions required
DDSL to ensure Safeguarding folder is set up accurately, with all documentation stored securely, using dedicated file name templates as per Swift Safeguarding Processes.