Review Date: September 2017

Next Review Date: September 2018


Our Commitment

Free2Learn Ltd (Free2Learn) is committed to practices that protect children and vulnerable adults from harm and creating a ‘safer’ learning environment that promotes well-being and security.
Staff in this organisation recognise and accept our responsibilities to develop awareness of the issues that may cause harm to young people or to vulnerable adults and promote the concept of the ‘safe learner’.

For the purposes of this policy young people are any learners under the age of 18 and those whom are considered vulnerable. The Safeguarding Vulnerable Groups Act 2006 defines a ‘vulnerable adult’ as:

A person aged 18 and over who is or may be in need of:

• receiving a social care service
receiving a health service
living in sheltered accommodation
detained in custody or under a probation order
requiring assistance in the conduct of his/her affairs
receiving a service or participating in an activity targeted at older people, people with disabilities or with physical or mental health conditions

Purpose of this Policy
The purpose of this policy is to provide advice for staff and associates working with us on helping us to meet our commitment of ensuring that any child or vulnerable adult receiving any form of training, advice or guidance through us is protected from all forms of exploitation and abuse.

We have interpreted and acted on substantial guidance to take preventative measures to protect young people and vulnerable adults from abuse: physical; sexual; psychological/emotional; financial or material; neglect and acts of omission and impairment to their personal and social development.

Our policy is to ensure so far as is possible that all who work with us maintain a proper focus on safeguarding. Our policy is also based on the notion that “It is unlawful for the body responsible for an educational institution to discriminate against a disabled person” (Disability Discrimination Act 1995, 2005).
The Education Act (2002) was used to prepare the Policy.

Our Responsibilities
• Promote the health and welfare of young people and vulnerable adults by providing opportunities for them to take part in our programmes safely (Children Act, 2004).
• Respect and promote the rights, wishes and feelings of young people and vulnerable adults.
• Promote and implement appropriate procedures to safeguard the well-being of young people and vulnerable adults and protect them from abuse.
Support staff and associates to adopt best practice to safeguard and protect young people and vulnerable adults from abuse and to minimise risk to themselves.
• Require staff and associates to adopt and abide by this Young People and Vulnerable Adult Protection Policy.
• Respond to any allegations of misconduct or abuse of young people or vulnerable adults in line with this policy.
• Conduct DBS checks with all the staff who are in contact with learners

The welfare of young people and vulnerable adults is everyone’s responsibility, particularly when it comes to protecting them from abuse. Young people and vulnerable adults have a lot to gain from us. Our programmes provide an excellent opportunity for participants to learn new skills, grow in confidence and maximise their potential.

This policy is based on the following principles:
• The welfare of young people and vulnerable adults is the primary concern.
• All young people and vulnerable adults, whatever their age, culture, disability, gender, language, racial origin, socio-economic status, religious belief and/or sexual identity have the right to protection from abuse.
• It is everyone’s responsibility to report any concerns about abuse and the responsibility of the Social Services Department and the Police to conduct, where appropriate, a joint investigation.
• All incidents of alleged poor practice, misconduct and abuse will be taken seriously and responded to swiftly and appropriately (Dealing with Allegations of Abuse against Teachers and other staff. Department for Education, 2011)
• All personal data will be processed in accordance with the requirements of the Data Protection Act 1998.
• All staff in contact with children and vulnerable adults will have DBS clearance Local (Safeguarding Children’s Board Minimum Standard for Safer Recruitment, 2010).

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Code of Behaviour – for all Staff and Associates
• Staff and associates must respect a young person’s/vulnerable adult’s rights to privacy and encourage them to feel comfortable enough to report attitudes or behaviour they do not like.
• Our staff and associates are expected to act with discretion with regard to their personal relationships. They should ensure their personal relationships do not affect their professional role within the organisation.
• All staff and associates should be aware of the procedures for reporting concerns or incidents, and should familiarise themselves with the contact details of the designated safeguarding officers.
• If a member of staff or associate finds himself or herself the subject of inappropriate affection or attention from a young person/vulnerable adult, they should make others aware of this.
• If a member of staff or associate has any concerns relating to the welfare of a young person/vulnerable adult, be it concerns about actions or behaviour of another staff member or associate or concerns based on any conversation with the young person/vulnerable adult, particularly if an allegation is made, they should report this to the designated safeguarding officers.
• Staff and associates should not start an investigation or question anyone after an allegation or concern has been raised. Staff or associates should just record the facts and report these to the designated safeguarding officers.
The designated safeguarding officers for matters concerning safeguarding are Louise Norwood (London) (Training Development Manager: 0208 525 9430 Ext. 1010), Louise Manion (Doncaster) (HR Manager) , Andrew Hibbitt (Doncaster) (CCO) , Kerry Broadbent (Doncaster) (Apprenticeships) and Dave Ellis (Doncaster) (Unemployed Provision) in the first instance.

They all have an up to date safeguarding qualification and relevant experience. In circumstances where it is not possible or inappropriate to raise with either Louise or Kerry, matters should be referred to the Director.
All allegations of abuse or harm will be treated seriously and consistently. This may lead to an investigation of a possible criminal offence by the police, involvement of an appropriate social care worker or an investigation of our provision and consideration of disciplinary action on staff or learners.

Our commitment to reviewing our Safeguarding Practices
We will work in partnership with local safeguarding partnerships and committees, to include the Safeguarding Children’s Boards and the Safeguarding Adults Boards, to seek guidance on developing our safeguarding practices and dealing with allegations of harm that may have occurred at home or in other situations outside of our remit.

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All policies and practices are reviewed annually to ensure that we have we have sound systems in place to minimise abuse of vulnerable adults and young people and to take action where abuse is suspected.
This guidance will be reviewed annually as part of our routine review of quality policies and procedures.
Primary responsibility in our organisation lies with the Director, to whom requests for additional information may be made.

Definitions of abuse (NIACE)
Physical abuse
This may include ‘hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions’

Some of the recognised signs of physical abuse are:
• unexplained burns;
• scratches;
• bruising and abrasions;
• drowsiness from misuse of medication; and
• anxiety in the presence of an abuser.

Sexual abuse
This may include ‘rape and sexual assault or sexual acts to which the vulnerable adult has not consented, or could not consent or was pressured into consenting’

Some of the recognised signs of sexual abuse are:
• changes in behaviour;
• bruising
• sexually transmitted diseases;
sexualised behaviour.

Psychological/emotional abuse
There is a strong similarity between the descriptions of these. Emotional abuse is generally described as an element of psychological abuse.
Psychological abuse may include emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks.

Some of the recognised signs of psychological or emotional abuse are:
• fear;
• passivity;

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• confusion;
• apathy;
• lack of eye contact;
• low self-esteem;
• disturbed sleep patterns; and
• reluctance to talk openly.

Financial or material abuse
This may include ‘theft, fraud, exploitation or the misuse or misappropriation of property, possessions or benefits’

Some of the recognised signs of financial or material abuse are:
• loss of jewellery and personal property;
• lack of money to purchase basic items;
• a bill not being paid when money is entrusted to a third party;
• inadequate clothing;
• unexplained withdrawal of cash; and
• loss of money from a wallet or purse.

Cyber Abuse
Whilst modern technology is embraced at Free2Learn, we are mindful of the potential for bullying to occur. In alignment with our general policies on anti-bullying, we stand by the belief that:
a) all learners have a right not to be bullied and
b) Bullying is always unacceptable.

Definition of Cyber-Bullying
Whilst there is no legal definition of cyberbullying within UK law, in accordance with the Department for Education it can be described as: ‘The use of Information and Communications Technology, particularly mobile phones and the internet, deliberately to upset someone else.’ Adding that: “Upsetting someone can take a variety of forms. It can involve threatening, distressing or humiliating a target, and, as such, encompasses a wide range of behaviours”.

The following categories are considered as cyber-bullying:
• Bullying by texts or messages or calls on mobile phones
• The use of mobile phone cameras to cause distress, fear or humiliation
• Posting threatening, abusive, defamatory or humiliating material on websites, to include blogs, personal websites, social networking sites
• Using e-mail to message others
• Hijacking/cloning e-mail accounts
• Making threatening, abusive, defamatory or humiliating remarks in chat rooms

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Free2Learn uses appropriate security systems to restrict access to harmful or explicit material including firewalls and anti-virus software. Where appropriate, Free2Learn audits ICT communications and regularly reviews the security arrangements in place.
All cases of Cyber Abuse and Cyber-Bulling should be reported to the Designated Safeguarding person.

Neglect and Acts of Omission
This may include ‘ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate heating and nutrition’

Some of the recognised signs of neglect and acts of omission are:
• dehydration;
• infections;
• malnutrition; and
• hypothermia.

Discriminatory Abuse
This may include abuse, bullying and harassment based on the individual’s age, sex, disability, religion, race or ethnicity or sexual orientation.
Some of the recognised signs of discriminatory abuse might be very similar to psychological and emotional abuse. Although all these forms of abuse are now better analysed and documented not all have been fully recognised by education and training provision in the past. These guidelines recommend that education and training providers should formally recognise all six areas of abuse as identified by the DoH (2000).

Female Genital Mutilation
Female Genital Mutilation (FGM) occurs mainly in Africa and to a lesser extent, in the Middle East and Asia. Although it is believed by many to be a religious issue, it is a cultural practice.
Reasons given for this cultural practice include: Cultural identity, Gender identity, sexual control, hygiene/cleanliness. However, there are no health benefits. Communities particularly affected by FGM in the UK include girls from: Somalia, Kenya, Ethiopia, Sierra Leone, Sudan, Egypt, Nigeria, Eritrea, Yemen, Indonesia and Afghanistan.

In the UK, FGM tends to occur in areas with larger communities who practice FGM such as first generation immigrants, refugees and asylum seekers. In England and Wales, 23,000 girls under 15 could be at risk of FGM.

Risk factors include:

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• Low level of integration into UK society; mother or sister who has undergone FGM
• girls who are withdrawn from PSHE
• Being taken on a long holiday to family’s country of origin
• talking about a special event or procedure to ‘become a woman’.

Highest risk time is the summer holidays.
Post-FGM symptoms include:
• difficulty walking, sitting, standing
• spending longer than normal in the bathroom or toilet
• unusual behaviour after a long absence
• reluctance to undergo normal medical examinations

It is illegal in the UK to allow girls to undergo FGM either in this country or abroad. People guilty of allowing FGM to take place are punished by fines and up to 14 years in prison.
At Free2learn, we have a duty to report concerns we have about girls at risk of FGM to the police and social services.

Child Exploitation
There are many forms of child exploitation. Child exploitation includes child domestic work, child soldiers, the recruitment and involvement of children in armed conflict, sexual exploitation and pornography, the use of children for criminal activities including the sale and distribution of narcotics and the involvement of children in harmful or hazardous work. Children are considered to be exploited whenever a profit is made from their vulnerability and lack of power, whenever children are abused to somebody else’s benefit and whenever they start working despite being too young or for long hours. Exploitation also occurs when children work in dangerous or unhealthy conditions, when they are underpaid or when they are coerced into forced labour, debt bondage or slavery.
Honour Based Violence

There is no specific offence of “honour based crime”. It is an umbrella term to encompass various offences covered by existing legislation. Honour based violence (HBV) can be described as a collection of practices, which are used to control behaviour within families or other social groups to protect perceived cultural and religious beliefs and/or honour. Such violence can occur when perpetrators perceive that a relative has shamed the family and/or community by breaking their honour code.
Related acts:
The Children Act 1989, 2004
Data Protection Act 1998

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Human Rights Act 1998
Disability Discrimination Act 1998, 2005
The Education Act 2002
Sexual Offences Act 2003
The Protection of Vulnerable Adults Scheme 2004
Data Protection Act 1998.
Mental Capacity Act 2005
Safeguarding Vulnerable Groups Act 2006
Mental Health Act 2007
Local Safeguarding Children’s Board Minimum Standard for Safer Recruitment 2010
Dealing with Allegations of Abuse against Teachers and other staff. Department for Education 2011
Department for Education document entitled: Cyberbullying: Advice for head teachers and school staff (2014)
Keeping Children Safe in Education July 2015, Sept 2016

Signed: Gabriella Gherscovic
Position: Director