Are you worried about online sexual abuse or the way someone has been communicating with you online? Make a report to one of CEOP’s Child Protection Advisors.

VTC Safeguarding and Child Protection Policy

Child Protection Policy

Based on guidance issued by the Secretary of State, the latest of which is Keeping Children Safe in Education, Department for Education (DfE), September 2019 and the updates from October 2019..

This policy includes our schools’ procedures for dealing with allegations of abuse against staff. This policy should be considered in conjunction with our anti-bullying, equalities, online safety, whistleblowing, attendance, healthy schools, first aid & medication, health & safety including risk assessment policies.

      In this policy:

        ‘The VTC School’ means This VTC Independent  School and all educational and training programs.



Designated Safeguarding Lead

(VTC School)


Paul Thompson

Deputy Designated Safeguarding Lead (VTC School)




Safeguarding Advisor


Kerry Jones



The phone number for

Kent County Council LADO





Formal policy review and validation by our Advisory team


September 2020

The VTC School understands that our work in safeguarding and protecting children must always have regard for the national guidance issued by the Secretary of State and should be in line with local guidance and procedures. This policy is therefore written with due regard to national guidance, the latest of which is Keeping Children Safe in Education (September, 2019) and Working Together to Safeguard Children (DfE, February 2019) and the updated October 2019 amendments. Our schools’ procedures for safeguarding children are also compliant with the Swale Child Protection Procedures produced by the Swale Safeguarding Children Board.

This policy is available to everybody, in hard copy from our schools or from our website:

All staff at The VTC School know that a range of other school policies are central to many aspects of the schools’ child protection policy, and this document should therefore be read in conjunction with our policies for:

§  Anti-Bullying

§  Attendance

§  Online safety

§  Equalities

§  First Aid & Medication

§  Health & Safety

§  Healthy Schools

§  Risk Assessment

§  Whistleblowing

All adults working with, or on behalf of, our schools must always follow all of our procedures.

Our policy is regularly updated (as identified on page 1) by the designated safeguarding lead and updates are disseminated to all staff via emails and safeguarding briefings and updates, which are provided on most of staff training days.

All staff must be clear about their own role and that of others in providing a caring and safe environment for all children and must know how they should respond to any concerns about an individual child that may arise. To this end, The VTC School will ensure that all staff know that Paul Thompson, is our Designated Safeguarding Lead (DSL) and has overall responsibility for child protection and safeguarding. Though some of the duties inherent to this role can and will be delegated to the deputy DSLs in order that work is completed most efficiently, the ultimate responsibility remains with the DSL. In the absence of the DSL, the deputy DSLs are, responsible and will undertake the DSLs duties.

All safeguarding leads have received advanced level training in order to undertake their roles and are also safer recruitment trained. All safeguarding leads receive updated training at least once every year; and in addition, keep up-to-date with safeguarding developments at annually.
All staff must also have read, and signed to acknowledge their understanding of, Keeping Children Safe inEducation, September 2019. At The VTC School, we ensure that a range of sophisticate and rigorous mechanisms are in place to assist staff to understand and discharge their roles and responsibilities as set out in part one of this policy.
Full safeguarding training, drawing upon the latest national and local guidance, is provided to all staff on an annual basis. Regular safeguarding updates are provided throughout the year to ensure that staff have the most up to date relevant skills and knowledge to safeguard children effectively. The training program focuses on topics such as the ‘Prevent’ duty, equality, online safety, child criminal exploitation and sexual violence and sexual harassment. Staff who are employed during the school year will receive safeguarding training at the very beginning of their induction period, and at least annually thereafter. Staff will sign an induction form agreeing that they are aware of their roles and responsibilities, and have read and understood all relevant safeguarding guidance, policies and procedures and agree to implement them.
Highly effective mechanisms are in place to ensure that staff have a clear understanding of the child protection policy and procedures in place, and that these are applied consistently across all three sites.
Mechanisms include:
§  safeguarding induction
§  whole school annual safeguarding training
§  online safeguarding training
§  weekly safeguarding and therapy refreshers and/or quizzes
§  safeguarding emails to staff regarding key issues, updates and individual early help plans
§  safeguarding refresher workshops, which are held on the vast majority of training days
§  twice-termly link meetings between the proprietor and designated safeguarding director
The child protection register is maintained by the DSL and all staff working with pupils are informed of all matters relating to children in their classes. In addition to our child protection register, the DSL keeps a live safeguarding log which records any and all concerns raised, and the actions taken.
The DSL provides regular feedback to the governing body, via the Head of Centre and Executive Director of Education on all safeguarding issues. This is through termly written updates and regular meetings.
Regular contact is maintained with the proprietor, who is also the Designated Safeguarding Director. 
The VTC School will always follow safer recruitment procedures so that we can be confident that all adults working in our school are safe to do so. All interviews are undertaken by senior leaders.
Supervision is made available to those staff who are involved in the management of allegations of child abuse.
All persons who carry out regulated activity with children have an Enhanced DBS check prior to working at the school. An individual may commence work with a DBS check that is pending as long as the school have received two satisfactory references and a cleared barred list check, the individual will also always be supervised when working with pupils.  The DSL and head of centre will, if informed in advance by the staff member undergoing the DBS check, risk assess the member of staff if the check includes a record of anything that could potentially be cause for concern including any police caution, conviction, reprimand or warning. Whether this risk assessment supports the appointment of the staff member or not, this risk assessment with any supporting investigative documentation will be kept securely and confidentially on file. If a member of staff does not declare anything that could potentially be cause for concern, including any relevant police caution, conviction, reprimand or warning, the applicant will not be appointed to the school.
All children deserve the opportunity to achieve their full potential and the purpose of all intervention is to safeguard and promote the welfare of the child. For those staff who engage with children who experience discrimination in their daily lives or who are from cultures different to those of the professionals, assumption and stereotyping must not be part of our practice. Every effort must be made to ensure that cultural issues are understood and that each individual case is dealt with on its own merits. Teachers and those working in school have daily contact with children in their classes and around the school buildings, and as a result have first- hand knowledge of child development and behavioural norms. This places these professionals in a unique position to identify children who would benefit from ‘early help’ and who are/ or are at risk of abuse. However, teachers, therapists and support workers do not decide if something is or is not a child protection issue. Any concerns MUST be passed onto the designated safeguarding lead and/or a member of the senior leadership team and referred using the correct safeguarding form (or directly to the LADO, local authority or Channel, ifappropriate).
Staff must follow The VTC School safeguarding and child protection procedure if they have any concern regarding a child. However, staff should also be aware that if there is a risk of immediate serious harm to a child, a referral can and should be made to children’s social care immediately and that anybody can make a referral. If the child’s situation does not appear to be improving the staff member with concerns should press forre-consideration.
Any visitors to the school will be accompanied at all times by a member of staff, including social workers, inspectors and external therapists to ensure the safety and well-being of pupils. We have a clear vetting procedure, including risk assessment to ensure that any visiting speaker is suitable and appropriate. The head of Centre will be aware of any arrangements and will have a clear understanding as to why they will be coming in to speak. Key staff will always try to select visiting speakers from an established organisation’s, and appropriate checks should be undertaken to establish the suitability of the person, such as internet searches and/or contacting other schools where the person has spoken previously. All visitors will read key safeguarding information on arrival, while being required to bring appropriate identification. Although viewing DBS certificates may be appropriate, most visiting speakers will not be in ‘regulated activity’ and so will not necessarily have a DBS certificate to present. Visitors must be supervised at all times and not left alone with pupils. Visiting speakers should understand that their presentation will be brought to an early end, if the content proves unsuitable. All information about the visiting speaker and the booking process is recorded on a suitable proforma. After the presentation, feedback from staff should be gathered to note any contentious subject areas or comments, and state whether the speaker could be booked again in the future. Once a person has visited a school, future checks should be proportionate.
All children at The VTC School must be able to place their trust and confidence in any adult working in the school. They must feel sure that they can speak about any worries or concerns they may have and that they will be listened to, taken seriously and responded to appropriately. All staff must therefore know what to do if a child chooses to talk to them about any matter which raises child protection concerns.
All staff must:
§  Listen to what the child is saying without interruption and without asking leading questions
§  Respect the child’s right to privacy but not promise confidentiality
§  Reassure the child that he/she has done the right thing in sharing
§  Explain to the child that in order to keep him/her safe from harm the information that has been shared must be passed on
§  Report what has been disclosed to the DSL as soon as possible, or in their absence, one of the DDSLs
§  Record, as soon as is practicable, but within 24 hours what was said using the child’s actual words.
§  Remember that if there is a risk of immediate serious harm to a child a referral can and should be made to children’s social care immediately and that anybody can make a referral. If the child’s situation does not appear to be improving the staff member with concerns should press for re-consideration.
The DSL will:
§  Assess any urgent medical needs of the child
§  Consider whether the child has suffered, or is likely to suffer significant harm
§  Check whether the child is currently subject to a Child Protection Plan or has been previously subject to aPlan
§  Confirm whether any previous concerns have been raised by staff
§  Only inform the family of the child of any concerns once the duty team leader at social care services has been consulted and their advice sought
§  Consider whether the matter should be discussed with the child’s family or whether to do so may put the child at further risk of harm because of delay or the family’s possible actions or reactions
§  Seek advice if unsure that a child protection referral should be made
If the child discloses sexual abuse or sexual abuse is suspected, the child must not be questioned and the parents must not be informed until social care services and the police child abuse investigation team has been informed and advice given.
Information will be shared on a ‘need to know’ basis and must be treated in absolute confidence. Staff must not discuss allegations with the child, family members or colleagues.
The DSL will either make a referral to the child’s local authority children’s services duty or referral and assessment team or, if a referral is not considered appropriate at that stage, make full written records of the information that they have received, detailing the reasons for the judgement that the matter was not referred to the local authority. The DSL keeps a written record of all contact with other agencies. All paperwork relating to child abuse is kept securely.
All children who are subject to a child protection plan will have core group meetings and case conferences organised by social care services. A member of the safeguarding leadership team (DSL or one of the DDSLs) will attend these on behalf of the school. Children are aware that these meetings take place and that the school will be presenting a report at the meetings. The head of Centre will act as the school’s ‘designated teacher’ and is responsible for Children Looked After (CLA), they will liaise accordingly with Virtual School headteachers. They will provide update information that will be collated for their Pupil Education Plan (PEP).
All staff, including teachers, therapists and our school nurse monitors children who are subject to a social care services Child Protection (CP) or Child In Need (CIN) Plan.
Owing to the nature of the day-to-day relationship children at The VTC School have with staff, all adults working in the school are particularly well placed to notice any physical, emotional or behavioural signs that a child may be suffering significant harm. We understand that harm means the ill-treatment or impairment of a child’s health and/or development, including that caused as a result of witnessing the ill- treatment of another person.
All staff must therefore be alert to any possible indicators that a child is suffering harm and report any concerns to the DSL.
All adults working in the schools will receive at least annual whole-school child protection training in order that their awareness to the possibility of a child suffering remains high.
All families of children attending The VTC School must feel secure in the knowledge that they are entrusting their children to adults who will strive to keep them safe at school. We will do this by:
§  Promoting a caring, safe and positive environment within the school
§  Ensuring that our staff are appropriately trained in safeguarding and child protection according to their role and responsibilities and keep an up to date record of all training undertaken
§  Encouraging the self-esteem and self-assertiveness of all children through the curriculum so that the children themselves become aware of danger and risk and what is acceptable behaviour and what is not
§  Working in partnership with all other services and agencies involved in the safeguarding of children
§  Displaying appropriate posters that detail contact numbers for child protection help-lines (ChildLine)
§  Always following Safer Recruitment procedures when appointing staff
§  Welcoming visitors in a safe and secure manner (all visitors must sign in, read key safeguarding information and wear a visitor’s badge)
§  Undertaking risk assessments when planning out-of-school activities or trips
§  Parents and carers are also able to make direct referrals to the local authority children’s service duty team if they have a concern about a child or the local authority designated officer (LADO) if they have a concern about a member of staff working at The VTC School.
The Medway duty team number
01634 331 307 or 01634 331 126

The Kent County Council duty team number
 03000 410 888

All children deserve the opportunity to achieve their full potential and the purpose of all intervention is to safeguard and promote the welfare of the child. We are aware that our pupils, some of whom have special educational needs and/or disability are more vulnerable to be subject to abuse and neglect. For example, there could be a reluctance to believe children with special educational needs and/or disability are being abused, limited opportunities for these children to seek help from someone else or a lack of access to support services. Staff have an awareness that behaviour, mood and injury may relate to possible abuse and not just their SEN or disability. Our pupils may have a higher risk of being isolated from their peers, left out of group activities or bullied. As a school, we strive to help safeguard these pupils by ensuring that they are heard, receive unlimited support and liaise with external support services on the family’s behalf.

 We know that a child’s unexplained absence from school could mean that they are at risk of harm and that a child going missing from education is a potential indicator of abuse or neglect. We have a clear attendance policy, and:
§  our classes are small, and thus attendance is easy to track closely. Any child going missing from education will always get immediate attention from the DSL. Staff are trained to be alert to signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns such as travelling to conflict zones, FGM and forced marriage
§  we will always seek to clarify the reason for a child’s absence from school  with the child’s parent or carer as soon as is practicable on the first day, the reason for absence will be recorded on the register. If we are unable to obtain the reason for a pupil being absent, we will attempt to contact the pupil’s emergency contacts. We ask for at least two emergency contacts for every pupil. At this stage, if we have been unable to contact the family or emergency contacts, a home visit will be carried out. As a last resort, if the school has not been able to ascertain where a pupil is after following the steps above, the pupil will be classed as a ‘missing child’ and they will be reported to the police
§  we will also always report an unexplained absence of a child with a Child Protection Plan to the child’s social worker within one day
§  we will always report a continued absence (10 or more school days) about which we have not been notified by the parent or carer to the Local Authority’s SEN Team and Education Welfare Service
§  we will always report to the local authority the name of any child who has been newly registered to attend our school but does not arrive on the expected day
§  we will always report to the Education Welfare Service the continued absence of a child known or thought to have been taken overseas if the child does not return to school on the expected return date
§  we maintain accurate attendance and admissions registers (all pupils are on both), in line with statutory requirements. This includes paying careful attention to off-rolling pupils in association with the local authority and knowing, and recording, pupil destinations consistently on the admissions register. Where a pupil destination is unknown, and unable to be sought after significant follow-up, the local authority, education welfare service and/or social care services will be informed
§  we do not ‘delete’ pupils from the admissions register. We alert the child’s local authority immediately if:
–       the pupil has been taken out of school by their parents and are being educated outside the school system e.g. home education
–       the pupil has ceased to attend school
–       the pupil has been certified as medically unfit to attend school
–       the pupil is in custody.

Keeping local authorities up to date is crucial so that they can check if children of compulsory school age are missing education, and therefore might be in danger of not receiving an education and be at risk of abuse or neglect.
On the rare occasions that we exclude pupils for a fixed-term (usually a day), we put this in writing to both the family and the placing local authority. While we provide the pupil with work to complete during their external exclusion (and mark it), we are not responsible for the pupil’s safety and welfare during their time at home.
Since 2010, when the Government published the ‘’Prevent’ strategy (the key prevention aspect of Contest), there has been an awareness of the specific need to safeguard children, young people and families from extremism. There have been several occasions, both locally and nationally, in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.
The VTC School values freedom of speech and the expression of beliefs and ideology as fundamental rights underpinning our society’s values. Both children and teachers have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.
The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism. The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. The VTC School is clear that exploitation and radicalisation is viewed as a safeguarding concern and must be dealt with accordingly.
ALL staff at The VTC School must complete Prevent and Channel training as part of their induction and will receive regular briefings and update training.

A ‘forced’ marriage is distinct from a consensual ‘arranged’ marriage because it is without the valid consent of both parties and where duress is a factor. A child who is forced into marriage is at risk of significant harm through physical, sexual and emotional abuse. Information about a forced marriage may come from the child themselves, of the child’s peer group, a relative or member of the child’s local community or from another professional. Forced marriage may also become apparent when other family issues are addressed, e.g. domestic violence, self-harm, child abuse or neglect. Forced marriage may involve the child being taken out of the country for the ceremony, is likely to involve non-consensual/under-age sex and refusal to go through with a forced marriage has sometimes been linked to ‘honour killing’. Honour-based violence is an ancient cultural tradition that encourages violence towards family members who are considered to have dishonoured their family. It is rooted in domestic violence and is often a conspiracy of family members and associates, meaning victims are a risk for their parents and families.
School staff should respond to suspicions of a forced marriage or honour- based violence by alerting the DSL who will make a referral to Children’s Social Care and if the risk is acute, to the Police Child Abuse Investigation Team. School staff should not treat any allegations of forced marriage or honour- based violence as a domestic issue and send the child back to the family home. It is not unusual for families to deny that forced marriage is intended, and once aware of professional concern, they may move the child and bring forward both travel arrangements and the marriage. For this reason, staff should not approach the family or family friends, or attempt to mediate between the child and family, as this will alert them to agency involvement. Further information and advice can be obtained from the Forced Marriage Unit or 02070080151 and the Honour Based Violence Helpline 0800 599 9247. Again, as with all concerns, please alert the DSL as soon as possible.

Female genital mutilation (sometimes referred to as female circumcision) refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. Female Genital Mutilation affects girls particularly from North African countries, including Egypt, Sudan, Somalia and Sierra Leone. Although our school has no children from these backgrounds and consider our tiny number of girls in our school to be safe from FGM, we will continue to review our policy annually and to include it in annual update training for all staff.
School staff should be alert to the following indicators:
§  The family comes from a community that is known to practice FGM
§  A child may talk about a long holiday to a country where the practice is prevalent
§  A child may confide that she is to have a ‘special procedure’ or to attend a special occasion
§  A child may request help from a teacher or another adult
§  Any female child born to a woman or has a sister who has been subjected to FGM must be considered to be at risk, as must other female children in the extended family
It is illegal in the UK to allow girls to undergo FGM either in this country or abroad. It is important to note that all staff have a duty to report personally any concerns they may have about girls at risk of FGM to the police. Any concerns must be immediately shared with the DSL and teachers are aware that they have a mandatory duty to report known cases of FGM.

We understand that bullying, including cyber-bullying, is harmful to children. We have an anti-bullying policy that sets out our aim of ensuring no child becomes a victim of any form of bullying and the work that we carry out in school to foster an environment where bullying behaviour is known to be unacceptable. We will always take seriously any reports of bullying and respond appropriately.  We understand that bullying may take different forms and may include, as examples, racist, sexist, homophobic, transphobic and biphobic behaviours. All staff are clear about the Protected Characteristics, as prescribed in the Equality Act 2010 (see our equality policy).
Any such reported or observed incident will be dealt with in accordance with our anti-bullying policy.
We recognise that children’s use of the internet is an important part of their education but that there are risks of harm associated with its use. We have an online safety policy that addresses how we seek to minimise those risks in school and teach children how to stay safe when using the internet in their lives outside of school. We also recognise that all members of staff must always be mindful of the need to follow our policy of acceptable use of our IT equipment.
New technologies have become integral to the lives of children and young people in today’s society, both within schools and in their lives outside of school. The requirement to ensure that children and young people are able to use the internet and related communications technologies appropriately and safely is addressed as part of our wider duty of care to which all who work in schools are bound. The use of these exciting and innovative tools in school and at home has been shown to raise educational standards and promote achievement.
Unfortunately, the use of these new technologies can put pupils at risk within and outside the school; pupils are not allowed to have any mobile device on them during the school day, this helps to safeguard pupils and ensure they are not accessing any inappropriate material on their personal devices. We also have a pro-active monitoring regime which allows us to monitor all internet use. While filters should not over block, as it may place unreasonable restrictions on what pupils can be taught, it is also fundamental to be aware of some of the potential dangers that the internet can pose, including:
§  Access to illegal, harmful or inappropriate images, video games or other content
§  Unauthorised access to/loss of/sharing of personal information
§  The risk of being subject to grooming
§  The sharing/distribution of personal images without an individual’s consent or knowledge
§  Inappropriate communication/contact with others, including strangers
§  Sexting
§  Implications of geolocation
§  Cyber-bullying
§  An inability to evaluate the quality, accuracy and relevance of information on the internet
§  The potential for excessive use which may have a negative impact on the social and emotional development and learning of the young person.
Material published by children and staff in a social context which is considered to bring the schools reputation into disrepute or considered harmful to, or harassment of, another child or member of the organisation will be considered a safeguarding issue and a breach of conduct and behaviour and treated accordingly as per behaviour, equality anti-bullying and/or staff conduct policies/procedures.

The UK Council for Child Internet Safety (UKCCIS) have produced guidance for schools on how to tackle sexting and ‘youth produced sexual imagery’ as sharing photos and videos online is part of daily life for many people, enabling them to share their experiences, connect with friends and record their lives.
This increase in the speed and ease of sharing imagery has brought concerns about young people producing and sharing sexual imagery of themselves. This can expose them to risks, particularly if the imagery is shared further, including embarrassment, bullying and increased vulnerability to child sexual exploitation.
Making, possessing and distributing any imagery of someone under 18 which is ‘indecent’ is illegal. The relevant legislation is contained in the Protection of Children Act 1978 (England and Wales) as amended in the Sexual Offences Act 2003 (England and Wales). Specifically, it is an offence to possess, distribute, show and make indecent images of children. The Sexual Offences Act 2003 (England and Wales) defines a child, for the purposes of indecent images, as anyone under the age of 18.
Although the production of such imagery will likely take place outside of school, these issues often manifest in schools working with children and young people. Staff respond swiftly and confidently to ensure that children are safeguarded, supported and educated.
The response to these incidents should be guided by the principle of proportionality and the primary concern at all times should be the welfare and protection of the young people involved.
§  All incidents involving sexting and youth produced sexual imagery should be responded to in line with the school’s safeguarding system.
§  The DSL should hold an initial review meeting with appropriate school staff
§  There should be subsequent interviews with the young people involved (if appropriate)
§  Parents should be informed at an early stage and involved in the process unless there is good reason to believe that involving parents would put the young person at risk of harm
§  At any point in the process if there is a concern a young person has been harmed or is at risk of harm a referral should be made to children’s social care and/or the police immediately.

Sexual exploitation can take many forms from the seemingly ‘consensual’ relationship where sex is exchanged for attention/affection, accommodation or gifts, to serious organised crime and child trafficking. What marks out exploitation is an imbalance of power within the relationship. The perpetrator always holds some kind of power over the victim, increasing the dependence of the victim as the exploitative relationship develops. The VTC School attempts to identify young people who are vulnerable to, or at risk of, sexual exploitation and who need services and interventions to keep them safe. We will pass on any information about CSE issues affecting the schools, for example concerns about adults hanging around the school, to the police.

Sexual violence and sexual harassment can occur between two children of any age and sex. It may occur though a single child or group of children sexually harassing or being sexually violent towards another child or group of children, it may happen both physically or verbally, online or offline. Evidence suggests that girls, children with Special Education Needs and Disability (SEND) and LGBT children are at greater risk. It is important that all disclosures are taken seriously, victims are supported and there is a clear message that it is never acceptable.
Any experience of sexual violence and sexual harassment is likely to have a significant impact on a pupil’s emotional wellbeing and adversely affect their educational attainment. Staff are to report any concerns about a pupil to the designated safeguarding lead.

In most instances, negative conduct of pupils towards each other will be covered by our behaviour and anti-bullying policies. However, some allegations and peer on peer abuse may be of a more serious nature and raise safeguarding concerns. Allegations made against another pupil may include physical abuse (for example violence, particularly pre-planned; forcing the use of drugs or alcohol), emotional abuse (for example bullying, blackmail, extortion, threats, intimidation), sexual abuse (for example indecent exposure, touching, sexual violence and sexual harassment, sexting, forcing the watching of pornography) and/or sexual exploitation (for example photographing or videoing indecent acts).
In our schools’ localities of Swale and Medway, gangs are prevalent and our pupils (some with gang membership pasts) are vulnerable to gang membership or re- membership. Older pupils may also attempt to recruit younger pupils using any or all of the above methods. It is also well documented that pupils suffering from sexual exploitation themselves may be forced to recruit other young people, under threat of violence.
It is inevitable in our school that some pupils will present a safeguarding risk to other pupils. A robust induction system ensures that we are informed as to whether a pupil arrives or re-joins presenting a safeguarding concern, for example after coming back into school following a period in custody or having experienced serious abuse themselves. Intelligent timetabling, groupings, supervision and personalised risk assessments, including daily dynamic risk assessments, are central to the effective management of safety in our schools. In itself, this dramatically reduces the possibility of negative conduct against other pupils, and therefore of allegations.
All staff members treat this abuse very seriously and never consider it as ‘banter’ or part of growing up. When an allegation is made by a pupil against another pupil, members of staff should consider whether the complaint raises a safeguarding concern. If there is a safeguarding concern:
§  The DSL should be informed
§  A factual record should be made of the allegation, but no attempt at this stage should be made to investigate the circumstances
§  The DSL will contact social care services to discuss the case. It is possible that social care services are already aware of safeguarding concerns around the pupil. The DSL will follow through the outcomes of the discussion and make a social care services referral where appropriate
§  The DSL will make a record of the concern, the discussion and any outcome and keep a copy in both pupils’files
§  If the allegation indicates a potential criminal offence has taken place, the police will be contacted at the earliest opportunity and parents informed (of both the pupil being complained about and the allegedvictim)
§  It may be appropriate to exclude the pupil being complained about for a period of time, as per our anti-bullying policies
§  Where neither social care services nor the police accept the complaint, a thorough school investigation will take place in any case, using our internal procedures
§  In situations where the DSL considers a safeguarding risk is present, a risk assessment should be prepared along with a preventative, supervision plan which will be monitored and evaluated with all adults working with the pupil. Individual risk assessments will also be amended accordingly.
§  Both the victim(s) and perpetrator(s) will be supported by the school, what this looks like may vary depending on the case, however it may include: additional therapeutic support, home visits, personalised timetable, family support and ongoing communication with external agencies.

The 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 to carry drugs and money from urban areas to suburban and areal areas, market and seaside towns. Staff are aware that a key indicator to look out for is missing episodes; if a child has periods of going missing it is possible that they have been trafficked for the purpose of transporting drugs. This is another reason as to why our absence procedure is so important; we inform the police if we have been unable to obtain a reason for a child’s absence as the pupil is classed as a ‘missing child’.
Like other forms of abuse and exploitation, child criminal exploitation can affect any child under the age of 18. It can still be exploitation even if the activity appears consensual, there is usually some form of power imbalance in favour of those perpetrating the exploitation. It can also involve force and/or enticement-cased methods of compliance and is often accompanied by violence or threats of violence. Staff should raise the concern with the DSL as soon as possible and log any information relating to child criminal exploitation.

Children can abuse other children. This is generally referred to as peer on peer abuse and can take many forms. This can include (but is not limited to): bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals.
Sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children
Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support.
Staff should be aware of the importance of: 
• making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up;
• not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”; and • challenging behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, flicking bras and lifting up skirts.
Dismissing or tolerating such behaviours risks normalising them. Staff should be aware that some groups are potentially more at risk.
Evidence shows girls, children with SEND and LGBT children are at greater risk.

It is important that school and college staff are aware of sexual violence and the fact children can, and sometimes do, abuse their peers in this way. When referring to sexual violence we are referring to sexual violence offences under the Sexual Offences Act 2003. 
Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents. 
Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents.
Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents.
What is consent?  Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if she/he agrees by choice to that penetration and has the freedom and capacity to make that choice.

When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of child on child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. Whilst not intended to be an exhaustive list, sexual harassment can include:

  • sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names; • sexual “jokes” or taunting; • physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (schools and colleges should be considering when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature; and  • online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence.


 It may include:


  • non-consensual sharing of sexual images and videos;
  • sexualised online bullying;
  • unwanted sexual comments and messages, including, on social media;
  • sexual exploitation; coercion and threats; and
  • 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. 

A pupil’s welfare can be affected if they are homeless or at risk of becoming homeless. The DSL will be able to assist families in getting them support; in addition to discussions and supporting letters that can be provided to the Local Housing Authority, it may be deemed necessary to make a referral to children’s social care if the child has been harmed or is at risk of harm.
It should also be recognised in some cases 16 and 17-year olds could be living independently from their parents or carers, for example through their exclusion from the family home, and will require a different level of intervention and support. Children’s services will be the lead agency for these young people and the DSL will ensure appropriate referrals are made based on the child’s circumstances.
Indicators that a family may be at risk of homelessness includes household debt, rent arrears, domestic abuse and anti-social behaviours as well as the family being asked to leave a property.
The Homelessness Reduction Act 2017 places a new legal duty on English councils so that everyone who is homeless or at risk of homelessness will have access to meaningful help including an assessment of their needs and circumstances, the development of a personalised housing plan, and work to help them retain their accommodation or find a new place to live.

The VTC School recognises that young people are at risk from a range of both legal and illegal substances and that substance misuse is an increasing social problem that can have devastating consequences for individuals, their families and the community as a whole. The school is committed to the health, safety and welfare of children and will take action to help safeguard their well-being as well as providing support, advice and education about drugs and substance misuse as appropriate. The schools will never condone the misuse of substances, and the possession or supply of illegal drugs, and it will be viewed as a safeguarding concern.

Children are sometimes required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed. There is guidance available on the government website that explains the process and support that are available for children.
Making child arrangements via the family courts following a relationship breakdown can be an extremely stressful time for the whole family. The Ministry of Justice has launched an online child arrangements information tool which parent/carer(s) may find helpful as it offers clear information in the dispute resolution service. Further information on the court system can be found at:

Only children over the age of 13 may be employed to do light work. Regulations determine the type of work and restrict the hours a child may be employed for. Children working in the UK who are still of compulsory school age are required to have a work permit in all cases; it is illegal for a child to work and not have a work permit, even if this is in a family business. Different regulations apply to children in entertainment, where children under thirteen may be licensed to perform in commercial performances under strict guidelines and controls. Further information on children in employment can be found at employment

A private fostering arrangement is one that is made privately, without the involvement of a Local Authority, for the care of a child under the age of 16 years of age by someone other than a parent or close relative, in their own home, with the intention that it should last for 28 days or more. Each party involved in the private fostering arrangement has a duty to refer it to the Local Authority at least six weeks before the arrangement is due to begin, and not to do so would be an offence. The school has a duty to inform social services if we become aware of a private fostering arrangement that has not been shared with the Local Authority. Although there is no duty for the school to be informed of private fostering arrangements it would be helpful if the family could pass on the information to ensure support can be put in place. Further information on private fostering can be found at

We have a risk assessment policy and health & safety policy which demonstrate the consideration we give to minimising any risk to the children when on the school premises and when undertaking activities out of school under the supervision of our staff. This also includes alternate provisions, where the school is responsible forthe safeguarding of pupils; risk assessments, site visits and a written statement is obtained from the provider stating that they have completed all the required vetting and barring checks that are necessary on their staff.
The school acknowledges its responsibility to safeguard all pupils in potentially vulnerable situations such as changing rooms, while also acknowledging the child’s right to privacy. A professional judgement is made based on the age and the developmental needs of the pupils; appropriate supervision is achieved by staff being in close proximity to the changing room and pupils should be aware of this, knowing that adults will enter the room if necessary. Risk assessments are in place to ensure the safety of both pupils and staff members.
To ensure that the safety of our pupils there are procedures in place that allow staff to search pupils using a metal detector wand, this is to make sure that pupils are not bringing inappropriate materials or dangerous weapons into school. There will normally be two members of staff present during the search, and a member of staff who is of the same sex as the pupil will carry out the search. In exceptional circumstances, if there is a risk of serious harm to a person if the search is not carried out straight away, a pupil may be searched by a person of the opposite sex and without another member of staff present.

We recognise the importance of keeping up-to-date and accurate information about children. We will regularly ask all families to provide us with the following information and to notify us of any changes that occur:
§  Names and contact details of persons with whom the child normally lives
§  Names and contact details of all persons with parental responsibility
§  Emergency contact details
§  Details of any persons authorised to collect the child from school (if different from above)
§  Any relevant court orders in place including those which affect any person’s access to the child (for example Residence Order, Contact Order, Care Order, Injunctions etc.)
§  Name and contact detail of the child’s general practitioner
Any other factors which may impact on the safety and welfare of the child

Information about children given to us by the children themselves, their parents or carers, or by other agencies will remain confidential. Staff will be given relevant information only on a “need to know” basis in order to support the child if that is necessary and appropriate.
We are, however, under a duty to share any information which is of a child protection nature. We understand that this is in the best interests of the child and overrides any other duties we have regarding confidentiality and information sharing.
We have a duty to keep any records which relate to child protection work undertaken by us or our partner agencies and to ensure that these are kept apart from the main child record, stored securely and only accessible to key members of staff. We also have a duty to send copies of these records to any school to which the child transfers.

If we have a reason to be concerned about the welfare of a child we will always seek to discuss this with the child’s family in the first instance. On occasion, according to the nature of our concern, it may be necessary for us to make an immediate referral to social care services when to do otherwise may put the child at risk of further harm either because of delay, or because of the actions of the parents or carers.

 Everyone working at The VTC School is a permanent, contracted staff member. We rarely       use agency, supply or cover staff of any description, at any time. We do not use volunteers, students on placements or any form of temporary worker.
We will always consider the vacancy that has arisen within the context of safeguarding children and ensure that we include the responsibility to safeguard children within the requirements of the role. We always consider carefully the knowledge, skills and experience required to safeguard children and include these within a person specification.
All vacancies that are open to external applicants are advertised on our website. When using the services of a third-party advertising site/agency, we endeavour to advertise our vacancies in a manner that is likely to attract a wide range of applicants (for example on a nationally recognised website, such as the TES). The advertisement will always include a statement about our commitment to safeguarding children and our expectation that all applicants will share that commitment. The advertisement will state that the post is subject to all relevant statutory vetting checks.
Through whichever route an employee joins us, they must complete an application form. Our application form enables us to gather information about a candidate’s suitability to work with children by asking specific and direct questions. We scrutinise all completed application forms and do not accept CVs alone. The candidates indicate that they understand that they will be subject to vetting checks, including an enhanced DBS check, the prohibition from teaching check and, if appropriate, the s128 management check.
The recruitment process for leadership roles follows the typical structure; once a pre-determined closing date has passed, leaders shortlist candidates on the basis of the application forms submitted and invite successful applicants to attend interviews. Non-leadership vacancies, however, are far more frequent and usually recruited for within a shorter time-frame; as a result, it is not practical to adhere to the same recruitment protocol. For teaching, support and administration roles, therefore, candidates are invited to an initial meeting with the head of centre on the strength of their CV, as and when we receive them. After a successful initial meeting, a candidate will be invited to complete an application form before attending a trial day, followed by a formalinterview.
§  We will always conduct a face-to-face interview
§  Our interview panel will always contain at least two leaders and all interviewers are safer recruitmenttrained. We also use School Personnel Services as our preferred HR team.
§  Interview questions will seek to ensure that we understand the candidate’s
values and beliefs that relate to children
§  All candidates will be asked to bring original documents, which confirm their identity, qualifications, right to work in the UK and any overseas checks
§  An interview pack which consists of a set of general interview questions (including on safeguarding), interviewers’ grades and the decision to appoint/not to appoint, is kept in the employee’s file
The interview panel will consider all the evidence gathered before making its choice, whereupon a verbal offer of the post will be made to the successful candidate. On acceptance of the post, candidates are given a formal offer letter which states that their appointment is subject to the school’s receipt of two satisfactory professional references, the completion and return of all relevant paperwork and successful completion of all the relevant statutory vetting checks. Unsuccessful candidates are informed and offered feedback on their performance.
§  We do not accept open references, letters of recommendation or testimonials
§  We always take up at least two references; these must be completed on our own reference form and signed off by the Head of Centre before employment commences
§  Our reference form includes questions specifically intended to reveal safeguarding concerns, such as enquiring about the candidate’s previous competency when working with children, asking if the candidate was ever subject to disciplinary action and if the referee knows of any reason why the candidate should not be given substantial access to children.
§  Verification checks are performed at random on at least 1 in every 4 references we receive. This includes confirming the identity of the referee, by phone, as well as the validity of the reference they have submitted. These checks are also carried out in every instance in which the referee is deemed to have given insufficient, ambiguous or concerning information. Similarly, verification checks are performed whenever a reference is returned from an email address that is not recognisably professional or that does not obviously belong to the person from whom we are expecting to receive the reference.
§  We verify previous employment history, where necessary
§  We arrange for a DBS check to be processed for all new staff, unless they are able to evidence an original DBS certificate that is subscribed to the DBS update service and which we can confirm remains current and accurate. Though we are not obliged to, we believe it to be good practice to re-check staff members’ DBS every three years, with their permission.
§  All staff working in regulated activity require an Enhanced DBS check.
§  Staff are always supervised while the DBS check is being processed (if relevant), and a DBS barred list check is always undertaken before staff commence their duties at The VTC School.
§  All our Advisors will be DBS checked.
§  If a candidate declares at the interview stage that his/her DBS certificate will or might not be clear (particularly if it includes or might include a police caution, conviction, reprimand or warning), the DSL and the Head of Centre will assess whether or not the disclosure should preclude the candidate from working at The VTC School. If the candidate’s application is allowed to proceed, the DSL will complete a risk assessment for the individual, which will be kept securely and confidentially in their personnel file.
§  If a candidate fails to declare at the interview stage that his/her DBS certificate will or might not be clear, and this proves to be the case, the candidate will not be appointed as a member of staff.
§  We verify, where necessary, that the successful applicant has all the academic or work-relatedqualifications claimed and request the original academic
&    professional        qualifications        and     certificates,        including     proof    of qualified teacher status (QTS); we do not accept photocopies.
§  We verify the successful candidate’s identity and right to work in the UK; again, only original documents are accepted.
§  We verify that the candidate has the health and physical capacity for the job using a standard medical questionnaire. This form is completed after the interview process, so does not affect the appointment decision. It is, however, possible that a medical condition or health complaint could prevent an otherwise successful candidate from being able to meet the requirements of our conditional offer of employment. This will only apply if the health issue/concern renders the candidate unable to fulfil the requirements of the role, as laid out in the job description.
§  Any candidate who has lived or worked in a foreign country (anywhere outside of the United Kingdom) for longer than three months, will be required to undertake overseas checks. The nature, accessibility and speed of these checks may vary from country to country, but no candidate will be able to commence work until these checks are underway.
§  Though it is not a statutory requirement, all staff who will have regular access to children will have a ‘prohibition from teaching’ check undertaken before they can commence employment.
§  A S.128 prohibition from management check will be carried out if a member of staff joins the leadership team or advisory body.
The successful candidate will be given a formal offer letter and issued with a contract in due course.
All offers of employment are dependent on the satisfactory completion and return/clearance of all requested forms and checks.
§  Newly appointed staff are issued with a copy of our staff handbook and shown where to find our key policies; they must sign to confirm they have read and understood these documents.
§  All new staff complete an induction with their line manager and a safeguarding induction with the DSL or one of the DDSLs, which includes familiarisation with Keeping Children Safe in Education (September2019). All staff have access to KCSIE on our website and must read it and sign to say they have done so. Similarly, staff must sign to declare that they have received a safeguarding induction, have read, understood and agree to adhere to our policies and procedures and have sought clarity on anything that remains unclear to them. This is recorded and retained in the employee’s personnel file.
§  We will refer to the Disclosure & Barring Service any person whose checks reveal that they have sought work when barred from working with children.

We will always supervise staff and act on any concerns that relate to the safeguarding of children. Our school is covered by CCTV in some areas and staff are closely monitored at all times, within reason.
Our procedures for managing allegations of abuse against members of staff are simple and clear – the quick resolution of any allegation is an absolute priority. Put simply, allegations made should be reported straight away, normally to the designated safeguarding lead, head of Centre, chair of governors or the proprietor. The school must then involve the Local Authority Designated Officer (LADO) if the allegations require investigation.
In response to an allegation, suspending the member of staff is not the default response, unless there is no reasonable alternative. If suspension is deemed appropriate, the reasons and justification will be recorded by the school’s leaders (or proprietor) and the individual notified of the reasons.
Allegations that are found to have been malicious will be removed from personnel records and any that are not substantiated, are unfounded or malicious will not be referred to in employer references.
Pupils who have made malicious allegations are likely to have breached the schools’
behaviour policy and will receive an appropriate sanction which is likely to be a fixed-term exclusion.
The procedures for dealing with allegations should be applied with common sense. However, it is important that even allegations that appear less serious are followed-up.
Our procedure is:
1.        The recipient of an allegation must report it to the designated safeguarding lead, head of Centre or chair of governors as soon as possible and never try to investigate it themselves. If the designated safeguarding lead is implicated, it must be reported to a head of centre or the chair of governors. If the head of centre/education is implicated, it must be reported to the chair of our Advisory Board . If the chair of our advisory board is implicated, it must be reported to the proprietor, and if the proprietor is implicated, it must be reported to the LADO.
2.        A record of the report must be made by the designated safeguarding lead, head of centre, chair of our advisory board or proprietor (depending on point 1) which must be timed, dated and include a clearly written name and signature.
3.        If the allegation is serious and credible and alleges that a member of staff has
a)  behaved in a way that has harmed or may have harmed a child, b) possibly committed a criminaloffence against or related to a child, or c) behaved towards a child/ren in a way that indicated he/she is unsuitable to work with children, the Local Authority Designated Officer (LADO) should be informed on the same day
4.        If unsure, call the LADO in any case to discuss the allegation
5.        Such consultation in point 3/4 will enable the LADO and the school leader to consider the nature, content and context of the allegation and agree a course of action
6.        If this leads to a decision that no further action is to be taken this decision and the reasons for it should be recorded by both the schools’ senior leader and the LADO. They should agree between them the information that should be put in writing to the individual about whom the allegation was made. Both should then consider the action that should follow in respect of that individual and also the person (or persons) who made the allegation
7.        If it is decided that the allegation warrants further action the LADO will take this forward
8.        The head of centre or proprietor should inform the accused person about the allegation as soon as possible, but only after consulting the LADO about whether this is appropriate at this stage and what information can be given to the person
9.        Consideration must be given as to whether it is necessary to remove the subject of the allegations from contact with children at the schools, pending investigations and procedures arising from the allegation. Suspension should not be automatic, but should be considered if: a) there is cause to suspect a child is at risk of significant harm, b) the allegation warrants investigation by the police, or c) the allegation is so serious that it might be grounds for dismissal
10.  Any decision to suspend shall be taken only after consultation with the LADO. It will take into account the safety of the child or children involved and the impact on any enquiry
11.  Where it has been deemed appropriate to suspend the person, written confirmation should be dispatched within 24 hours, giving the reasons for the suspension. The person should be informed at that point who their named contact is within the organisation and provided with their contact details
12.  The subject of the allegations (whether suspended or not) shall be: a) advised to contact her/his trade union or professional association, b) treated fairly and honestly and helped to understand the concerns expressed, processes involved and possible outcomes, c) kept informed of the progress of the case andof the investigation, d) clearly informed of the outcome of any investigation and the implications for disciplinary or related processes and e) provided with appropriate support
13. A school leader, usually the designated safeguarding lead, head of centre or chair of our advisory board (or the schools’ proprietor should the chair of our advisory board be the subject of the investigation), shall be responsible for continuing liaison with Sittingbourne or Medway’s LADOs and all communication between the schools and other agencies that may be involved in processes following an allegation
14.  Confidentiality is essential and information about an allegation must be restricted to those who have aneed to know in order to: a) protect children,
b) facilitate enquiries, c) avoid victimisation, d) safeguard the rights of the person about whom the allegation has been made and others who might be affected and e) manage disciplinary/complaints aspects
15.  If, following the conclusion of child protection processes, further enquiries are pursued for the purpose of disciplinary, regulatory or complaint investigation, they should be arranged in a way that avoids the repeated interviewing of children or other vulnerable witnesses


Concern about…

Who will investigate?

About any member or members of staff below Head of Centre

The designated safeguarding lead, Paul Thompson, or the Head of Centre

About the DSL

The Head of Centre or Head teacher

About the Head of Centre

The Chair of our advisory board

About the Chair of our Advisory Board

The Head of Centre and the proprietor

About the proprietor

Local Authority Designated Officer (LADO)


The Medway LADO is…

 The Kent County Council LADO is…


01634 331 307 or 01634 331 126



For further information on the management of allegations against staff, please see our whistleblowing policy.

The VTC School is clear about its duty to refer a person who is deemed unsuitable to work with children to the Disclosure & Barring Service (DBS).
Specifically, we refer to the DBS any member of staff who:
§  has harmed, or poses a risk of harm, to a child
§  has received a caution or conviction for a relevant offence, or if there is reason to believe that the individual has committed a listed relevant offence
§  is dismissed or receives disciplinary action because of misconduct relating to a child
§  leaves their employment during an investigation related to misconduct relating  to a             child

The DBS will then consider whether to bar the person. Referrals will be made as soon as possible after the resignation or removal of the individual.
We ensure that all staff are clear about the expectations we have of their behaviour towards all children and that any incident that falls below our expected standards will be dealt with appropriately, as per our staff conduct and disciplinary procedures.
All staff are Team-Teach trained (see our Team-Teach physical intervention policy) and receive very regular training on working with our pupils who have severe and complex social, emotional & mental health difficulties.

The VTC School is fully aware of the legislation relating to childcare disqualification which can be (for example) for inclusion on the Children’s Barred List, being cautioned for specific offences against children/adults, grounds related to the care of children, having childcare/children’s home registration refused or cancelled and/or for being disqualified from private fostering. It can also be ‘disqualification by association’ which is when an employee lives in the same household as somebody who is disqualified. However, as we do not offer early or later years (no children who are aged 8), no childcare provision and no employees at The VTC School undertake childcare in their roles, it is unlawful for us to ask employees about childcare disqualification or disqualification by association.

The Education (Independent School Standards) Regulations apply a duty to proprietors of independent schools to ensure that arrangements are made to safeguard and promote the welfare of children.

The body of governance at The VTC School consists of a proprietor and a Advisory body.

The proprietor and advisory body ensure that they comply with their duties under legislation and fulfil their duty to remedy any weaknesses that are identified.

Duties and responsibilities include ensuring that:

§  Policies and procedures are effective and comply with the law

§  High quality training is provided to all staff, at all levels. This includes induction training, annual whole school safeguarding training, and regular safeguarding training throughout the year

§  All staff have read and understood the child protection and safeguarding policy, code of conduct policy,and part one of the Keeping Children Safe in Education, DfE September 2019 statutory guidance

§  Paul Thompson has been appointed to the role of Designated Safeguarding Lead (DSL), who has overall responsibility for safeguarding and child protection, with deputy designated safeguarding leads in place

§  The DSL will continually monitor our child protection and safeguarding practices and bring to the notice of the advisory body any weaknesses or deficiencies at the half termly governing body meetings, via an oral report which is minuted

§  The DSL has a termly meeting with the chair of the proprietorial board, who is also the Designated Safeguarding Director (DSD)

§  The school works very closely with external agencies such as social care services, the police and health services to promote the welfare of pupils, and to protect them from harm

§  Positive relationships are built with all of our families, and appropriate support is put in place

§  The proprietor and advisors will ensure that appropriate filters and monitoring systems are in place, to ensure that pupils are safeguarded from potentially harmful and inappropriate material

§  The proprietor and advisory body will ensure that children are taught about safeguarding, including online, through teaching and learning opportunities, as part of providing a broad and balancedcurriculum

§  The proprietor and advisory body will utilise the experiences of the staff team when shaping safeguarding policies and provide regular opportunities for staff to contribute to and shape the safeguarding arrangements and policy

This policy and all policies at The VTC School will be reviewed and updated by the leadership team & Advisory body as per our policy review cycle.


Below is a set of guidelines that staff should take on board when dealing with individual/small groups of children. It is important to be mindful at all times of your behaviour in relationship to individual/small groups of children and of the potential risk of an allegation.
Staff should take necessary precautions in order to minimise the opportunity for an allegation to be made against them. This is generally about exercising common sense, but all staff should specifically take note of the following:
§  Whenever possible try not to be alone in a room with a child, regardless of gender. If you are on your own with a child, leave the door open and inform a colleague if possible. Always keep an appropriate distance between you and the child
§  Do not engage in conversations about your personal life with children
§  Keep boundaries very clear between you and children, particularly if the conversation involves relationships, emotions, and sexual content
§  Do not exchange mobile phone numbers with children. If possible, do not have your mobile phone out when dealing with an individual child
§  Do not accept children (or their family members) as ‘friends’ or links on social networking websites or mobile phone apps
If a child wishes to disclose personal information to you, ensure that they understand that you cannot guarantee confidentiality. Do not probe a child about their personal life unless they approach you. Avoid giving advice to children about their relationships


All children have certain basic needs, which include:
§  Physical care and protection
§  Affection and approval
§  Stimulation and approval
§  Discipline and control that is consistent and appropriate to age
§  The opportunity to gradually acquire self-esteem, confidence, independence and responsibility that are ageappropriate
Individual cases must always be treated on their own merits however in general terms the following definition should provide the bases for action under these guidelines: “A child is considered to be in need of protection when the basic needs of that child are not being met through avoidable acts of either commission or omission”.

Before a child is placed on a Child Protection Plan a conference must decide that there is, or                       is a likelihood of, significant harm leading to the need for a plan. The following are used for the     plan. They are intended to provide definitions as a guide; in some instances more than one   category may be appropriate.
The persistent or severe neglect of a child or the failure to protect a child from exposure to any kind of danger, including cold or starvation, or extreme failure to carry out an important aspect of care, resulting in the significant impairment of the child’s health or development, including non-organic failure to thrive.

Physical injury to a child including deliberately poisoning, where there is definite knowledge, or a reasonable suspicion, that the injury was inflicted or knowingly not prevented.

The involvement of dependent, developmentally immature children and adolescents in sexual activities they do not truly comprehend and to which they are unable to give informed consent, or that violate the social taboos of family roles.

Actual or likely severe adverse effect on the emotional and behavioural development of a child caused by persistent or sever emotional ill treatment or rejection. All forms of abuse involve some emotional ill treatment.


Severe neglect is associated with major retardation of cognitive functioning as well as growth. It is recognised through a typical pattern of poor growth, poor hygiene, withdrawal and in extreme cases a pseudo-autistic state, all of which can rapidly reverse in alternative care.
Although neglect has one of the most pervasive effects on development and is one of the most frequent forms of abuse, it is an area which is frequently neglected by professionals. Like parents, professionals can feel overwhelmed and hopeless by large families living in squalid conditions.
Signs to look out for:
§  Dirty unkempt appearance of child, in overall poor condition
§  Thin wispy hair. Underweight child, diarrhoea may indicate poor nutrition
§  An undernourished child may be unduly solemn or unresponsive, or may be overeager to obtain food
§  An under-stimulated child may not reach expected milestones
§  Behaviour and developmental difficulties that cannot be explained by clinical factors
Associated factors
Neglected children frequently come from homes where there is:
§  A parent who is lonely, isolated, unsupported or depressed
§  Poor inter-parental relationship / domestic violence
§  A parent who is abusing drugs or alcohol
§  A large number of children living in cramped or very poor conditions

It should not be assumed that an injury to a part of the body normally vulnerable to accidental injury has necessarily been caused accidentally – it could be non- accidental. All injuries to children, which do not easily come into the category of normal bumps and scrapes, should be seen by a doctor.
Certain parts of the body are more commonly subjected to non-accidental injury. These include the upper arm, where a child may be gripped or shaken, the back, and the buttocks. Multiple injuries of various types, ages and location are common features of physical abuse.
Most non-accidental injuries leave marks on the body. PE teachers are therefore often key people in the identification of this form of abuse, as they regularly see the children partially dressed.
Signs to look out for:
§  Children who show a reluctance to undress or to expose parts of their bodies should be monitored as children who may have suffered physical injury
§  Unexplained absences
§  Physical signs of injury
§  Unexplained or confused accounts of how an injury occurred
§  Explanation of an injury which appears to be inappropriate to the nature and age of the injury
Common medical/physical factors associated with physical abuse BRUISING
§  Facial bruising around the mouth and ears
§  Groups of small bruises
§  Black eyes without a forehead injury, particularly if both eyes are affected
§  Weal marks or outline of bruising (e.g. hand mark)
§  Bruising of soft tissue with no obvious explanation (most bruises occur on bony protuberances such as the temple or shin)
§  Bruises on the back, back of legs, stomach, chest or neck
§  Bruises or cuts to mouth or tongue (e.g. split frenulum)
§  Pinch marks are found in pairs and may be seen on the back, buttocks, arms or cheeks
§  Bites leave clear impressions of teeth and some bruising – they are never accidental
§  Parents sometimes claim that bites have been made by other children or animals. It is therefore important to check the size and shape of the injury. If the impression is more than 3cms across it will have been caused by an adult or adolescent
§  Bites can be inflicted almost anywhere on the body
§  Children will sometimes suffer minor burns through hot irons etc., but it is uncommon for multiple burns to be caused accidentally
§  A cigarette burn is characteristically round, but may have a tail when dragged against the skin, and is surrounded by an area of inflamed skin
§  Cigarette burns can be found in groups and can be found on any part of the body
§  Scalds from boiling water may result from lack of supervision, or non- accidentally
§  A child is very unlikely to sit down willingly in very hot water; therefore he cannot scald a bottom accidentally without also scalding the feet
§  Burns and / or scalds are particularly worrying as a degree of sadism nay be involved when such injuries areinflicted
§  Injuries not consistent with explanation given by parent (even if agreed by the child)
§  Circumstances where parent delays seeking medical advice
§  A history of repeated injuries or presentation to A&E
§  Consent for a medical refused by parent
§  Desire of a parent to attribute blame elsewhere
§  Distant or mechanical handling of the child by the parent

The traumatic effects of child sexual abuse can be far-reaching and enduring, impacting on a child’s cognitive, behavioural and social development. The earlier the abuse occurs, the more adversely subsequent stages of development may be affected. The longer the abuse continues, the more extensive it is e.g. involving penetrative abuse, the greater the number of developmental stages that abuse continues through, the more disturbed the child is likely to be. Children who have suffered chronic long-term sexual abuse tend to have very negative feelings about themselves and all aspects of their relationships.
What is sexual abuse?
Sexual abuse can be one or more of the following:
§  Rape – genital and / or oral intercourse
§  Digital penetration or penetration with an object
§  Mutual masturbation
§  Inappropriate fondling
§  Taking pornographic photographs or exposing the child to pornographic materials
§  Forcing the child to observe others involved in sexual activities
§  Sadomasochistic activities
Both boys and girls can suffer from sexual abuse. Both men and women can be perpetrators – boys and girls who disclose sexual abuse from a female perpetrator are often met with disbelief. It is therefore important to listen to what a child says without being judge mental. Abusers can be parents, friends, teachers, childcare workers, clergymen or strangers. Warning children about Stranger Danger should therefore only form part of any child protection programme.
Signs to look out for:
§  A child who demonstrates inappropriate sexual interest and activity, through play or drawings
§  Sexualised behaviour, masturbation and sex play which often leaves the peer group confused orembarrassed
§  A child having excessive preoccupation with, or precocious knowledge of adult sexual behaviours
§  A child who shows a marked fear of adults, usually men, but occasionally men and women
§  A child who presents as depressed and where there may be instances of drug or alcohol abuse, suicide attempts or running away
§  A child who suddenly starts to wet or soil
§  A child who takes over the role of wife / mother within the family
§  A child whose concentration and academic performance suddenly deteriorates
§  A child who avoids medical examination or is reluctant to change for PE
§  A child who has low self-esteem and few friends
§  Aggressive behaviour from a normally quiet child, or withdrawn behaviour from a normally boisterous child
§  Frequent unexplained absences or lateness
§  A child who talks of nightmares and being unable to sleep; a child who may be excessively tired
§  Arson

§  Pregnancy in young teenagers where the identity of the father is vague or unknown
§  Recurrent urinary tract infections
§  Signs of sexually transmitted infections and overall dishevelled appearance

Emotional or psychological abuse can be defined as the destruction of the child’s competence to be able to function in a social situation. The child may be denied appropriate contact with peers within or outside of school, and be forced to take on a particular role in relation to parents, which is detrimental to the child’s ability to function appropriately in social contexts. This type of abuse is very difficult to identify as there are no physical signs – symptoms are usually apparent via a child’s behaviour and demeanour.
It is important to note that the emotional / psychological abuse is present in all other forms of abuse, but this category is only used when it is the sole form of abuse.
Signs to look out for:
§  A child may be inducted into a parental care-taking role and not be encouraged to be involved with appropriate play
§  A child may be used as a parent’s confidant to a degree that is harmful to the child’s psychologicaldevelopment
§  A child may be ignored, rejected or denigrated by a parent
§  A child may be terrorised by a parent or others so that she / he is overly fearful and watchful
§  A parent who is unable to be responsive to a child’s emotional needs, who may be emotionally distant and / or excessively negative and hostile
§  A child (usually of a mentally ill or disturbed parent) who is inducted into a parent’s delusionary state or paranoid beliefs
§  A child who is cripplingly over-protected and not given freedom to act at an age appropriate level
§  A parent who provides only conditional love with threats of withdrawal of love
Behavioural definitions are very difficult to quantify because a) most children experience some of these acts from time to time, and b) because the impact of a single or seldom occurring act of abuse will not have severe and harmful effects. The harm of emotional maltreatment results from the cumulative effects of repeated acts of psychological abuse.
Associated Factors
Children who suffer from emotional abuse frequently come from homes where there is:
§  A mentally ill or disturbed parent
§  Drug or alcohol abuse
§  A parent who is socially isolated, unsupported or depressed, or conversely, a parent who has a very active social life with very little time or energy to give to child care
§  A parent who has poor social skills, who may have learning difficulties and lack of knowledge about children’s age appropriate needs
§  A parent who has suffered severe abuse within her / his own childhood
§  A household where there is ‘adult on adult’ domestic violence
Many parents who emotionally abuse their children are unaware that what they are doing is harmful. Because of their own life experiences they may have a distorted view of parenting and their role as a mother / father.


Nothing is more important than the safety and wellbeing of our pupils. We ask that you take some time to familiarise yourself with some key safeguarding points.
§  The VTC School is committed to safeguarding and promoting the welfare of all our especially vulnerable pupils and expects all staff and visitors to share this commitment.
§  Our philosophy is to always ‘think the unthinkable’.
§  Any visitor to the school will be accompanied at all times by a member of staff to ensure the safety and wellbeing of pupils.
§  Be aware that we have fobbed entrances/doors to ensure the safety of our pupils; please be vigilant when walking through.
§  We have CCTV recording in some areas of the school site for the safety of pupils and staff.
§  All of our staff have Team-Teach accreditation, which includes positive handling techniques and de-escalationskills.
§  If you have a safeguarding or child protection concern please report what has been disclosed to one of our designated safeguarding leads below as soon as possible, who will record and act, if appropriate, on theinformation.
Remember that if there is a risk of immediate serious harm to a child a referral can and should be made to children’s social care services immediately and that anybody can make a referral.


Paul Thompson
Designated safeguarding lead
01795 899240
Deputy designated safeguarding lead
Deputy designated safeguarding lead