SAFEGUARDING CHILDREN and - CHILD PROTECTION

 
SAFEGUARDING CHILDREN and - CHILD PROTECTION
SAFEGUARDING CHILDREN and
                                     CHILD PROTECTION

    1. Policy Statement
Bournemouth Collegiate School (BCS) fully recognises its moral and statutory responsibilities for child
protection and is committed to promoting the safeguarding of children.
This policy has regard to the following guidance and advice:

▪   Keeping Children Safe In Education (September 2019
          o Disqualification under the Childcare Act 2006 (July 2018)
          o What to do if you're worried a child is being abused: advice for practitioners (March
              2015)
          o Sexual violence and sexual harassment between children in schools and colleges (May
              2018)
          o Criminal Exploitation of Children and Vulnerable Adults (September 2018
          o Multi Agency Guidance on female genital mutilation (April 2016)
          o Teaching online safety in school (DfE 2019)

▪   Working Together to Safeguard Children (July 2018)
          o Information sharing: advice for practitioners providing safeguarding services (July 2018)

▪   Revised Prevent Duty Guidance for England and Wales (July 2015)
           o The Prevent Duty: Departmental advice for schools and childminders (June 2015)
           o The use of social media for on-line radicalisation (July 2015)

It is also in accordance with locally agreed inter-agency procedures and Teacher Standards 2012.
All documents listed above can be found on sharepoint- BCS Staff/Admin/Compliance
documents/Policy documents whole school/Supporting Documentation for safeguarding
Definitions of Safeguarding, Types of abuse and Child Protection
Safeguarding and promoting the welfare of children refers to the process of protecting children from
abuse or neglect, preventing the impairment of health or development, ensuring that children grow up
in circumstances consistent with the provision of safe and effective care and undertaking that role so
as to enable those children to have optimum life chances and to enter adulthood successfully. This
may require inter agency assessment using local processes, including CAF, TAC approaches or Early
Help.

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Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm
or by failing to act to prevent harm. Children may be abused in a family or in an institutional or
community setting by those known to them or, more rarely, by others (e.g. via the internet). Abuse can
take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by
an adult or adults or by another child or children. Abuse can be:

▪   physical abuse
▪   emotional abuse
▪   sexual abuse; and/or
▪   neglect.

Child Protection refers to the processes undertaken to protect children who have been identified as
suffering, or being at risk of suffering significant harm or abuse. These should be reported to

support from one or more agencies through using inter-agency assessment processes including use of
the Common Assessment Framework and Team Around the Child approaches.
BCS understands that the safeguarding is intrinsic to all that we do and requires a consistent whole
school ethos and approach.
The welfare of children is paramount:

▪   All children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation
    or identity have the right to equal protection from all types of harm or abuse.
▪   Some children are additionally vulnerable because of the impact of previous experiences, their
    level of dependency, communication needs or other issues.
▪   Working in partnership with children/young people, their parents/carers/guardians and other

Bournemouth Collegiate School strives to keep children/young people safe by valuing them, listening
to and respecting them, and through our policies, procedures and practices.

▪   Adopting child protection practices through procedures and a Staff Behaviour Policy/Code of
    Conduct for staff and volunteers.
▪   Developing and implementing an Online Safety (e-safety) Policy and related procedures.
▪   Providing effective management for staff and volunteers through supervision, support and training.
▪   Recruiting staff and volunteers safely, ensuring all necessary checks are made.
▪   Sharing information about child protection and good practice with children, parents/carers, staff
    and volunteers.
▪   Sharing concerns with agencies that need to know, and involving parents/carers/guardians and
    children/young people appropriately.
▪   Ensuring that safeguarding responsibilities are appropriately addressed in all related policies and
    procedures.
BCS operates safe recruitment procedures (including DBS checks and compliance with Independent
School Standards Regulations) and follows the policy on Recruitment and Appointment Policy and
procedures in line with KCSIE Part 3.
Designated Safeguarding leads (DSL) are required to undertake training in child protection and inter-
agency working on appointment and updated every two years to include local inter-agency working
                                                              . This training is provided by the local
social services department or an external welfare agency acceptable to the local Safeguarding
Children Boards.
All staff including the Head, part-time, volunteers, temporary staff and college/university pupils,
Members of the LGB receive Child Protection training on appointment as part of their induction and this
is updated annually. This training may be provided by the designated safeguarding lead provided their
interagency training is up-to-date.
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This training includes: The Child Protection Policy, the Staff Code of Conduct, knowing the identity of
the DSL, Part 1 and Annexe A of Keeping Children Safe in Education (2016), the Whistleblowing policy,
Staff-Pupil Relationship Guidance document, Acceptable Usage of ICT for Staff policy
The school is aware of the Department for Education advice on the implications of the Prevent Duty, to
have due regard to the need to prevent pupils from being drawn into terrorism, under section 26 of the
Counter terrorism and Security Act 2015.
by providing a safe environment for debating controversial issues through its PSHCE programme,
SMSC development and through promoting fundamental British values.
Opportunities to teach safeguarding - Pupils are taught about safeguarding, including online, and
how they can reduce risks to their own personal safety, through Sex and relationships education, the
curriculum, Internet safety talks and through PSHE./Personal Development programme (Prep).
The                              s knowledge and resilience to online risks including radicalisation
and grooming in order to reduce any risks and who to speak to if they have any concerns. Staff,
parents and pupils are encouraged to explore the resources promoted by the DFE in the document
                                ( June 2019) and also at:
The UK Safer Internet Centre (www.saferinternet.org.uk)
                                 www.thinkuknow.co.uk) The school has a link to CEOP via the website.
The school will keep a record of all child protection allegations or concerns in accordance with
Education (pupil information) (England) Regulations 2005 and (NMSB,Appendix 2, item 1)
Multi Agency Working New safeguarding partners and child death review partner arrangements
came into place in September 2019. These comprise of the local authority, a clinical commissioning
group and the chief officer for police equally sharing responsibilities for working together to safeguard
and promote the welfare of local children within each area. The school will work in partnership with the
new safeguarding partners that have come into place in Bournemouth Christchurch andPoole
Domestic Violence The school is registered with MARAC and receives DV1 alerts from Dorset Police.
A Multi Agency Risk Assessment Conference (MARAC) is a local, multi-agency victim-focused meeting
where information is shared on the highest risk cases of domestic violence and abuse between
different statutory and voluntary sector agencies.
DV1 alerts are sent to BCS school to alert them of a child involved in a Domestic Abuse Incident when
Police have been called. The Designated Safeguarding Lead is informed by secure e-mail that an
incident has occurred. The email will not contain any details of the offence, only the names of the
child/parents involved in the incident.
The school will always make every effort to maintain confidentiality and guard against any unwanted
publicity in relation to child protection and safeguarding.
Our policy applies to all staff, governors and volunteers working in the school. This policy is in
accordance with the procedures set out by the Bournemouth and Poole Local Safeguarding Children
Board and Inter-agency Committee Procedures. All information provided by Bournemouth and Poole
Pan Dorset Safeguarding Children Partnership Plan can be found at: http://www.bournemouth-poole-
lscb.org.uk/home.
BCS is fully committed to ensuring that the application of this Child Protection (Safeguarding) policy is
non-
Equal Opportunity Policy document.
This policy is applicable to all pupils in both senior and prep schools, including those in boarding and
EYFS and BCS seek to implement this policy through adherence to the procedures set out in the rest
of this document.
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In line with our Provision of Information policy, this document is available to all interested parties on our
website and on request from the Senior school and Prep school offices and should be read in
conjunction with the following documents: Behaviour, Missing Pupils, Uncollected pupil, Mobile Digital
Devices, Physical Restraint, Internet and Email, Anti-Bullying, Staff Code of Conduct, Whistleblowing,
Self-Harm, Admissions (Child Missing in Education), SEND, E-Safety, Attendance, First Aid, Alcohol and
substance abuse, Trips and Visits.
Effective implementation of this policy document will be supported by the following policies and
procedures

▪     Safer recruitment procedures
▪     Staff appointment checks
▪     SCR (Single Central Register)
▪     Dealing with Allegations of Abuse against Teachers and other staff following (KCSIE Part 4
      guidance
This document is reviewed annually or as events or legislation change requires, by the Designated
Safeguarding Leads, Kay Smith, Prep School and Alison Davies, Senior School.

protection (safeguarding) policy and procedures and of the efficiency with which the related duties
have been discharged. The policy is also reviewed and ratified annually by Bright Scholar.

Any deficiencies or weaknesses in child protection arrangements once noted will be remedied without
delay.
    Date of Policy:                                    September 2015
    Presented to governors:                            November 2015
    Ratified by the United Learning Board:             February 2016
    Policy amended:                                    October 2016
    Presented to governors:                            November 2016
    Ratified by the United Learning Board:             December 2016
    Date for review:                                   October 2017
    Policy Amended                                     October 2017
    Presented to Governors                             November 2017
    Ratified by the United Learning Board              December 2017
    Date for review                                    October 2018
    Presented to Governors                             November 2018
    Policy amended                                     October 2019
    Presented to Governors                             October 2019
    Ratified by Bright Scholar                         October 2019

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2.Contents
   1.   Policy Statement                                                                    1
   2. Contents                                                                              5
   3. Key Personnel                                                                         7
   4. Terminology                                                                           10
   5. Policy Aims                                                                           10
   6. Roles and responsibilities                                                            10

        •   The Designated Safeguarding Lead (DSL)                                          10

        •   The Deputy DSL:                                                                 12

        •   The Head:                                                                       12

        •   The Business Manager:                                                           12

        •   The designated member of the LGB with oversight for Safeguarding issues         13

        •   The Head of Boarding                                                            13

        •   All BCS staff                                                                   14

        •   Visitors                                                                        15

        •   Action by the school                                                            15

   7. Procedures                                                                            15

        •   Early Help                                                                      16

        •   If a child makes a disclosure about abuse                                       17

        •   Allegation of abuse is against members of staff/volunteers/Head                 18

        •   Allegation of peer-on-peer abuse                                                20

        •   Reports concerning harmful sexual behaviour                                     21

        •   Notifying parents of an allegation of abuse                                     22

        •                                                                                   23

        •   Confidentiality and sharing information                                         23

        •   Safeguarding Children with SEND/EAL                                             24

        •   Support for Vulnerable Children                                                 24

        •   Support for those involved in a Child Protection issue                          24

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8. Boarding                                                                                       24
   9. Staff Training                                                                                 26
   10.                                                                                               26
   11. Complaints Procedure                                                                          26
   12. Recruitment                                                                                   27
   13. Staff Training                                                                                28
   14. Photography and Images                                                                        29
   15.                                                                                               29
   16. Appendices                                                                                    32

         •   Appendix 1 - Recognising Abuse and Children at Risk                                     32
                      Physical abuse                                                                       32
                        Emotional abuse                                                                    32
                        Sexual abuse                                                                       32
                        Neglect                                                                            32
                        Bullying                                                                           33
                        Honour - based Violence HBV                                                        33
                        Female Genital Mutilation (FGM)                                                    33
                        Forced marriage                                                                    33
                        Serious Crime                                                                      34
                        Gangs                                                                             33

                        Child sexual exploitation (CSE)                                                    34
                        Children missing from education                                                    34
                        Radicalisation                                                                     35
                        Prevent                                                                            35
                        Domestic Violence                                                                  35
                        Indicators of abuse                                                                36
                        Impact of abuse                                                                    36
                        Children who may be particularly vulnerable and at risk of abuse                   36

         •   Appendix 2 - BCS Notes of Guidance for Staff-Pupil Relationships                        38

         •   Appendix 3 - Boarding House Helpline guidance                                           51

         •   Appendix 4 - Action when a child has suffered or is likely to suffer harm               52

         •   Appendix 5 - School Staff Disqualification Guidance and Declaration                     53

         •   Appendix 6 - Staff member of Concern         BCS referral form                          56

         •   Appendix 7 - Record of a safeguarding allegation or concern or a disclosure             58

         •   Appendix 8 - Meet the Safeguarding team                                                 59

         •   Appendix 9     Checklist/Risk assessment for visiting speakers                          60

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3. Key Personnel
Designated Safeguarding Leads
For photographs of the Designated Safeguarding Leads see Appendix 7

 Designated     The Designated Safeguarding Lead at the Senior site for Day and Boarding
 Safeguarding   pupils is Alison Davies (Deputy Head with responsibility for Pastoral Care)
 Lead (DSL)     Member of the SLT
 Deputy         Contact: alison.davies@bcschool.co.uk
 Designed
 Safeguarding   Tel. 01202 436550
 Leads          Date of next update training: Sept 2021
 (DDSLs)
                The Designated Deputy Safeguarding Lead at the Senior Site is Maria
                Coulter, member of the SLT
                Contact maria.coulter@bcschool.co.uk
                Tel: 01202 436601
                Date of next update training: December 2019

                The Designated Safeguarding Lead at the Prep School is Kay Smith Head of
                Prep
                Contact kay.smith@bcschool.co.uk
                Tel: 01202 714110
                Date of next update training: November 2020

                The Designated Safeguarding Lead with specific responsibility for EYFS at the
                Prep School is Kay Smith, Head of Prep
                Contact kay.smith@bcschool.co.uk
                Tel: 01202 714110
                Date of next update training: November 2020
                The Designated Deputy Safeguarding Lead at the Prep School also with
                specific responsibility for EYFS is Charlotte Martin, member of the SLT
                Contact Charlotte.Martin@bcschool.co.uk
                Tel: 01202 714110
                Date of next update training is: November 2020

                The Designated Deputy Safeguarding Lead for After School and Holiday Club
                is Tara Hart.
                Contact Tara.Hart@bcschool.co.uk
                Tel: 07813899841
                Date of next update training is: February 2020

                The member of the LGB with nominated oversight of Safeguarding Children
                and Child Protection and E Safety is Sam Kilgour.
                Date of last training March 2019

 Designated     Kay Smith (Prep)
 Teachers for   Alison Davies (Senior)
 Looked After
 Children

 Local          The Chair of the Local Governing Body is Ian Terry
 Governing      Date of last training March 2019:
 Body (LGB)
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E Safety Lead     Senior School - Alison Davies
                   Prep School - David Smith

 Head              Russell Slatford
                   Tel: 01202 436550
                   Contact: russell.slatford@bcschool.co.uk
                   Date of next update training Dec 2019

Details of the local procedures for safeguarding can be found on the website of the
Bournemouth and Poole Local Safeguarding Children Board.

http://www.bournemouth-poole-lscb.org.uk/home

 Local Authority              Contact details for LADOs (Local Authority Designated
 Designated Officer           Officers)

 Please be reminded that      The overall management of the service is with Jill Aiken. The
 only allegations against     service will be staffed by Laura Baldwin and John McLaughlin
 a person working with
 children should be           The main contact number for the service is 01202 456744.
 directed to the LADO         The secure email address for the service is:
 service                      lado@bournemouth.gov.uk
                              Individual contact details are:
                                  • Laura Baldwin 01202
                                      456708 Laura.Baldwin@bournemouth.gov.uk
                                  • John McLaughlin 01202 453992
                                      John.McLaughlin@bournemouth.gov.uk

 Contact for Virtual School   Bournemouth Collegiate School recognises its responsibilities to
                              work with local authority professionals to support the needs of
                              Looked After Children to help to facilitate the best outcome and
                              life chances for these children with specific regard to attendance
                              and achievement. The local contact for Head of the Virtual
                              School is:
                              Tammie Lewis
                              T.Lewis@poole.gov.uk
                              Tel: 01202 262736

                              See MASH below
 Social Services
 Local Police                 Local Police Child Protection: 01202 222777
                                                                    999 (Emergency)

 Multi-Agency                 BCP Pan Dorset Safeguarding Children Partnership
 Safeguarding Hub             Multi Agency Safeguarding Hub
                              During Office hours (Mon Thurs 8.30am 5.15pm/Friday
                              8.30am- 4.45pm)
                              Telephone 01202 735 046
                              Email MASH@bcpcouncil.gov.uk
                              Visit Bournemouth & Poole Local Safeguarding Children Board
                              Out of hours (5.00pm 9.00am)
                              Telephone 01202 738 256
                              Email ChildrensOOHS@bcpcouncil.gov.uk
                              Out of Hours Guide for Professionals
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Child Missing Education    Cathy Lindsay 01202 458996
                            Cathy.Lindsay@bcpcouncil.gov.uk
 Early Help                 Bournemouth 01202 456884
                            Poole 01202 262626
 Support and Advice         Referrals should be made to:
 about Extremism            Safeguarding referral unit of the police:
                            sru@dorset.pnn.police.uk
                            01202 222229
                            For discussions for about appropriate referrals:
                            ssct@dorset.pnn.police.uk
                            01202 222844
                            The Prevent Leads:
                            Bournemouth Andrew Williams
                            Andrew.williams@bournemouth.gov.uk
                            01202 458240 07500 975396(mobile)

                            Poole Anthi Minhinnick
                            a.minhinnick@poole.gov.uk
                            01202 223320
                            DFE dedicated helpline for non-emergency advice for staff
                            and governors:
                            0202 7340 7264
                            counter-extremism@education.gsi.gov.uk
                            Department for Education
                            NON EMERGENCY NUMBER: 020 7340 7264
                            EMAIL: counter.extremism@education.gsi.gov.uk

 NSPCC whistleblowing       ADDRESS: Weston House, 42 Curtain Road London
 advice line                EC2A 3NH
                            TEL: 0800 028 0285
                            EMAIL: help@nspcc.org.uk

 Disclosure and Barring     ADDRESS: PO Box 181, Darlington, DL1 9FA
 Service                    TEL: 01325 953795
                            EMAIL: dbsdispatch@dbs.gsi.gov.uk

 Teaching Regulation        ADDRESS: 53-55 Butts Road, Earlsdon Park, Coventry, CV1 3BH
 Agency                     TEL: 0207 593 5393
                            EMAIL: misconduct.teacher@education.gov.uk

 OFSTED Safeguarding        TEL: 0300 123 4666 (Monday to Friday from 8am to 6pm)
 Children                   EMAIL: Whistleblowing@ofsted.gov.uk
                            02077838330, email
                            Info.request@childrenscommissioner.gsi.gov.uk

 Child line UK              0800 1111
                            www.childline.org.uk
                            02077838330, email
 Commissioner               Info.request@childrenscommissioner.gsi.gov.uk

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4. Terminology
Staff refers to all those working for or on behalf of BCS full time, part time and regular visiting staff, in
either a paid or voluntary capacity.

Child refers to all young people who have not yet reached their 18th birthday, and all pupils on BCS
roll, including those who remain on BCS roll after their 18th birthday.

Parent refers to birth parents and other adults who are in a parenting role, for example step-parents,
foster carers and adoptive parents.

    5. Policy Aims
The main aims of our Child Protection (Safeguarding) Policy are:

▪   To ensure that we practice safe recruitment in checking the suitability of staff and volunteers to
    work with children in compliance with Independent Schools Standards Regulations
▪   To establish a safe environment in which children can learn and develop in ways that will foster
    security, confidence and independence
▪   to provide all BCS staff, (full time, part time, teaching, support, regular school visitors, volunteers)
    with the necessary information to enable them to meet their child protection responsibilities
▪   to ensure that all staff have the skills, knowledge and understanding to keep children safe who are
    looked after by the local authority
▪   to ensure consistent good practice
▪   to demonstrate to pupils, staff and parents BC
    (safeguarding)
▪   To raise awareness of child protection issues and equip children with the skills needed to keep
    them safe
▪   To develop and implement procedures for identifying and reporting cases, or suspected cases, of
    abuse
▪   To support pupils who have been abused in accordance with his/her agreed child protection plan
▪   to support other BCS policies and procedures relating to the safeguarding and welfare of all pupils
    and staff at BCS

    6. Roles and responsibilities
The Designated Safeguarding Lead (DSL)
BCS has a DSL at both sites, supported by a Deputy DSL, who act as a source of support and expertise
to the school community and who will act upon any reported concerns relating to Safeguarding and
Child Protection. The DSL ensures
Child Protection Policy and Procedures and is the first point of contact for issues of child protection,
both internally, and for members of the public and other external contacts. The DSL and deputies on
either site can cover any absence. In addition, the Head and Head of Boarding have Child Protection
Level 3 training.

        The DSL will:

▪
▪                                                                                                    o
   ensure that it reflects local procedures and that the policy is also reviewed and approved annually
   by Bright Scholar.
▪ ensure any deficiencies or weaknesses in child protection arrangements are remedied
   immediately and advise the Designated Child Protection Lead in the LGB if an incident or new
   legislation or guidance has required the need for an interim review of the policy or procedures
▪ ensure that the policy is available to all interested parties on the school website and on request
   from the school offices
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▪   provide an annual report to Designated Child Protection Lead in the LGB
▪   keep written records of concerns about children even where there is no need to refer the matter
    immediately. If there is ANY doubt contact the relevant outside authorities
▪   compile any reports, risk assessments, care plans as required in liaison with other agencies
    involved
▪   maintain records of all cases and ensure that these records are kept securely; separate from the
    main pupil file, and in locked locations
▪   ensure that when a pupil with a child protection plan or a safeguarding file leaves BCS Senior /Prep
    worker is informed
▪   ensure the Child Protection (Safeguarding) policy is published on an unrestricted part of the
    office
▪   develop effective links with relevant agencies and co-operate as required with their enquiries
    regarding child protection matters including attendance at Child in Need meetings and TAC
    meetings
▪   where there is an allegation or suspicion of abuse, make a telephone referral immediately and a
    written                                                                               the case of
    serious harm inform the Police from the outset
▪   use local agencies for informal advice on Early Help
▪
    has a Child Protection Plan
▪   contribute to inter agency assessment using local processes, including the use of Common
    Assessment Framework and Team Around the Child approaches
▪   attend and/or contribute to child protection conferences and other meetings
▪   c                                                 ep or EYFS), as appropriate to the child
    protection plan
▪
▪   develop effective links with relevant statutory and voluntary agencies
▪   ensure that all staff sign to indicate that they have re
    Protection policy and the Notes of Guidance for Staff-Pupil Relationships Guidance Letter (see
    Appendix 2 of this document) and that they have signed the Self-Declaration of Disqualification
    (Childcare Regulations 2009)
▪   ensure that all pupil
    Protection policies and procedures and are aware of the name and contact details of the
    Designated Child Protection Officers in the school
▪   ensure that all relevant information is communicated to the appropriate members of staff who need
    to be informed
▪   ensure that staff have the skills, knowledge and understanding to keep pupils safe who are looked
    after by the local authority; providing them with all current assessment information from the LA and
    care plans and contact arrangements
▪   keep a record of staff attendance at child protection training and follow up absences to ensure all
    staff are up to date with such training
▪   ensure senior pupils (mentors) with responsibilities over other pupils are briefed on the CP policy,
    receive a copy of the policy and know the appropriate action to take if they receive any allegations
    or disclosures of abuse
▪   ensure the PSHE curriculum and assembly programmes include teaching to help all pupils respond
    positively to the rights of children to be safe and to know how to protect themselves and others
▪   ensure teaching in ICT includes training and information about the safe use of the internet and
    other technologies. The DSL has overall responsibility for online safety.
▪

▪   ensure that all staff, including those in the boarding houses, are aware of the policy and

▪   Where possible ensure that where a pupil at BCS is educated on another site or in another
    institution, a written statement will be obtained that states that appropriate DBS checks have been
    carried out on the staff employed at that institution
▪   Follow Appendix 4 when considering making a referral
▪   Liaise with relevant staff to ensure pupils are safeguarded whilst on educational visits, work
    experience or activities off site
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▪   Liaise with the Joanne Brickell, HR regarding the Single Central Record

       In addition, the DSL for EYFS will

▪   liaise with the local statutory agencies
▪   will inform Ofsted as soon as reasonably practicable, but at least within 14 days, of any allegations
    of serious harm or abuse by any person living, working, or looking after children at BCS (whether
    the allegation relates to harm or abuse committed on the premises or elsewhere), or any other
    abuse which is alleged to have taken place on the premises, and of the action taken in respect of
    these allegations. (Ofsted :Telephone: 0300 123 3155)
▪   attend the appropriate Designated Persons training in Safeguarding and Child Protection and inter-
    agency working on appointment and every two years thereafter
▪   attend relevant additional training offered by the LSCB or other local safeguarding organisations
    including Prevent
▪   keep up-to-date with changes in legislation and current reports published on Child Protection and
    Safeguarding
▪   In cases of allegations against someone working in the school the DSL will make prompt contact
    with the LADO
▪   ensure all allegations are reported to the LADO immediately and within one working day at the
    latest.
▪   Keep staff informed of relevant information e.g. NSPCC CASPAR updates
The Deputy DSL:
▪   The Deputy DSL in both schools is appropriately trained and, in the absence of any one of the
    designated persons, carries out those functions necessary to ensure the on-going safety and
    protection of all pupils (day and boarding). In the event of the long-term absence of one of the
    designated person, the deputy will assume all of the functions above.
The Head:
▪   ensure that the Policy and procedures are implemented and followed by all BCS staff
▪   ensure cover is provided for any absence of DSL or deputy
▪   allocate sufficient time and resources to enable the DSLs and deputy to carry out their roles
    effectively, including the assessment of pupils and attendance at strategy discussions and other
    necessary meetings
▪   ensure that all BCS staff feel able to raise concerns about poor or unsafe practice and that such
    concerns are handled sensitively and in accordance with the whistle-blowing procedures
▪   ensure
▪   ensure records - objective, clear and accurate and based on evidence of Safeguarding and Child
    Protection issues are securely kept whilst the child is in the school
    school when they leave. The school does not hold records on a child once they have left the
    school
▪   Follow the employers duties as outlined in KCSIE Part 4 in relation to allegations made against
    teachers and other staff
▪   report to the Disclosure and Barring Service (DBS) within one month of leaving the school any
    person (whether employed, contracted, a volunteer or pupil) whose services are no longer used
    because s/he is considered unsuitable to work with children. Failure to do so constitutes an
    offence
▪   ensure
    (Safeguarding) issues
▪   liaise and informs Ofsted and/or ISI and/or DfE of incidents as appropriate
▪   ensure those who in good faith report their concerns that a child is at risk are supported
    appropriately
▪   makes certain that staff will suffer no recrimination or victimisation as a result of raising a genuine
    concern about safeguarding issues - whistleblowing
The Business Manager:
▪   ensure that safe recruitment practices are followed by checking the suitability of staff and others
    working with our children and is responsible for ensuring enhanced DBS checks are made on all
    employees.

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▪   ensure that a Self-declaration of disqualification document is completed as part of the pre-
    employment checks they undertake on appointing new staff
▪   ensure that all Local Governing Body Members are subject to an enhanced check with the
    Disclosure and Barring Service to confirm their suitability to work with children.
▪   ensure, in liaison with the DSLs and other members of staff organising events, that all staff not
    directly employed by the school (employees of other organisations), and in contact with our pupils
    on the school site, have had the necessary and appropriate child protection checks.
▪
    Recruitment and appointments. This is done in accordance with relevant legislation.
▪   Issues the Staff-Pupil Relationships letter each year, which explains how staff should ensure that
    their behaviours and actions do not place children or themselves at risk of harm or of allegations of
    harm to a child (for example, in one-to-one tuition, sports coaching or engaging in inappropriate
    electronic communication with a child), and ensures all staff sign and return confirmation that they
    have read the document.
The designated member of the LGB with oversight for Safeguarding issues
The designated member of the LGB with oversight for Child Protection (Safeguarding) ensures that the
Local Governing
and Procedures and organises update training for all LGB members. Most recent training took place
on 24/11/2016

 This person also leads a monthly review of Safeguarding with the Heads, and the Safeguarding Lead
for each school. The review includes:

▪   Spot check of the SCR
▪   Any policy amendments or legislation updates
▪   Any staffing allegations/contact with the LADO
▪   Number of pupils on plan, having CYPS or CAMHS involvement, on the Child protection register
▪   Any specific incidents
▪   Boarding
▪   School events that require specific safeguarding arrangements
▪   Safeguarding training
▪   Attendance/exclusions
This person will                                                              the following:

▪   DSLs for child protection are members of the senior leadership team and have undertaken the
    required training in inter-agency working, in addition to basic child protection training
▪   the school has a Child Protection (Safeguarding) Policy and procedures that are consistent with
    requirements which is published on an                                                             om
    the school office on request
▪   the school has adequate procedures for dealing with allegations of abuse made against members
    of staff including allegations made against the Head
▪   that safer recruitment procedures are being followed including the requirement for appropriate
    checks
▪   the school has a training programme that ensures all staff, including the Head, receive child
    protection training on appointment, with refresher training at three-yearly intervals, and the DSLs
    receive refresher training at two-yearly intervals
▪   arrangements are in place to ensure that all temporary staff and volunteers are made aware of
    B
▪   arrangements are in place for all new staff, full and part time, and all volunteers to be given
    safeguarding training as part of their induction process.
They are nominated to liaise with the local authority on issues of child protection and they will liaise in
cases of allegations against the Head or member of the Governing Body.

The Head of Boarding
The Head of Boarding ensures that to comply with the National Minimum Standard for Boarding
Standard NMS 11 Child Protection:

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▪   this policy is published to staff, any adults working (including parents or parents of prospective
    pupils) in the boarding school and older pupils in positions of responsibility
▪   Senior Pupils and those with positions of responsibilities in the Boarding House are briefed on
    appropriate action to take if they receive allegations or disclosures of abuse.
▪   the policy and procedures for searching for and if necessary reporting any boarder missing from
    BCS is known by the boarding staff.
▪   that parents, guardians and /or carers of boarding pupils are aware of the procedures by which
    they are able to report concerns of allegations directly to Ofsted (for contact details, see page 4 of
    this document)

All BCS staff
To meet and maintain our safeguarding responsibilities towards BCS pupils all members of staff and
those who come into contact with our pupils (including temporary, supply staff and volunteers) are
expected to adhere to the following good practice:

▪   treat all BCS pupils with respect
▪   encourage positive and safe behaviour among pupils
▪   establish a safe and supportive environment in which children can learn and develop and where
    they feel secure and able to talk and are listened to
▪   ensure that children know there are adults in the school whom they can approach if they are
    worried about anything
▪   set a good example to children by conducting themselves appropriately
▪   know                                                                    , and other documents
    relating to wider safeguarding issues, for example DfE Keeping Children Safe in Education;
    Statutory Guidance, (2016               orking Together to Safeguard Children 2015) and the DfES
▪   know the names of the DSLs at the school and reporting any concerns immediately to them
▪   be aware of the details in the Mobile Digital Devices policy, available on the X Drive and the
    website, about the use of mobile phone and cameras
▪   be alert to the signs of abuse as detailed in Appendix 1 of this document
▪   raise concerns about poor or unsafe practice with the DSL
▪   follow the advice given in this document in relation to how to handle disclosures
▪   read and understand the Staff-Pupil Relationships letter which provides guidance to staff to ensure
    that their behaviour and actions do not place pupils or themselves at risk of harm or allegations of
    harm to pupils (for example, in one to one tuition, sports coaching, conveying a pupil by car,
    engaging in inappropriate electronic communication with a pupil, etc.). This is issued to all staff at
    the start of each academic year and is also to be found in Appendix 2 of this document
▪   complete and sign a Self-declaration of disqualification document
▪   gain assurance that appropriate child protection checks and procedures apply to any staff

▪   participate in organised training in child protection on appointment and updated annually and
    recorded on staff training cards.
▪                                                                                     ur may be an
    indicator of abuse
▪   understand the need to guard against unwanted publicity
▪
    with dressing, physical support during PE or administering first aid
▪   maintain appropriate standards of conversation and interaction with and between pupils and avoid
    the use of sexualised or derogatory language
▪   being aware that the personal and family circumstances and lifestyles of some pupils lead to an
    increased risk of abuse
▪   understand that inappropriate behaviour towards pupils is unacceptable and that their conduct
    towards pupils must be beyond reproach
▪   Note: under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have
    a sexual relationship with a person under the age of 18, where that person is in a position of trust,
    even if the relationship is consensual. This means that any sexual activity between a member of the
    school staff and a pupil under 18 may be a criminal offence, even if that pupil is over the age of
    consent.

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All staff must be aware of their duty to raise concerns, where they exist, about safeguarding children
and child protection and this may include the attitude or actions of colleagues. We recognise that
children cannot be expected to raise concerns in an environment where staff fail to do so. If any
member of staff is dissatisfied with the way that a DSL has dealt with their concern over the welfare of a
pupil, they may contact the Head or the nominated LGB member with oversight for safeguarding
issues. Anybody can make a referral although it is advisable for the DSL or deputy to undertake this. If

reconsideration.

Staff have the skills knowledge and understanding to keep safe children who are looked after by the
local authority and will have access to current assessment information from the LA, the most recent
care plan and contact arrangements with parents, and delegated authority to carers, and information
available to the delegated person.

Visitors
School signs clearly indicate to visitors that they must report to reception whereupon they sign in and

deputy DSL.

It is a requirement that all staff wear their identity badges in school.

Action by the school
The school would not undertake their own investigations of any allegations without prior consultation
with the LADO (Local Authority Designated Officer)

The school will obtain informal advice from local agencies concerning borderline cases.

Staff Code of Conduct and guidance

All staff should read, sign and act in accordance with the annual Notes of Guidance for Staff-Pupil
Relationships and Staff Code of Conduct issued annually. (Appendix 2 and 2a)

Staff should also adhere to the Staff Code of Conduct document available on the Sharepoint BCS
Staff/Admin/Compliance documents/Policy documents whole school and the guidance in the Staff
Handbook.

    7. Procedures
If a member of staff suspects or hears of an allegation of abuse

Everyone has a role to play in identifying concerns, sharing information and taking prompt action in
accordance with this policy. To ensure that pupils are protected from harm, all those who come into
contact with them need to understand what types of behaviour constitute abuse and neglect. Any
member of staff can make a referral to MASH or to the police.

Abuse and neglect are forms of maltreatment. Somebody may abuse or neglect a child by inflicting
harm or by failing to act to prevent harm.

Appendix 1 of this document outlines the different types of abuse: physical abuse, emotional abuse,
sexual abuse, neglect, Female Genital Mutilation, Child Sexual exploitation, Domestic violence,
Bullying, Radicalisation and gives guidance on how to recognise signs of abuse and children at risk. It
also outlines the PREVENT procedures in school. Abuse can take place wholly online or facilitate
abuse offline.

There will be occasions when a member of staff suspect that a pupil may be at risk, but has
evidence. All cases of suspected child abuse, neglect or other safeguarding issues should be given
the highest priority and should be reported to the DSL.

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If at any point there is a risk of immediate, serious harm to a child, the DSL or deputy should be
informed and a referral will be made immediately to MASH
                                      . The following course of action should be adhered to where you
think there might be reasonable grounds for suspecting abuse:

LISTEN        to what the child has to say, but remember that you must not ask leading questions or
promise confidentiality. Reassure the individual that the allegation/complaint will be taken seriously

REPORT         all suspicions immediately to the member of staff in charge of child protection. This is
Alison Davies (Senior) and Kay Smith (Prep) and in their absence Maria Coulter (senior), Charlotte
Martin. (Prep)

RECORD          in detail the circumstances (including the nature and extent of injuries) and the action
taken.

REMEMBER        that speed is essential.

All concerns, discussions and decisions (together with reasons) made under these procedures should
be recorded in writing. The record should include

▪   the date,
▪   time and
▪   place of the conversation and detail of what was said and done by whom
▪   who was present and
▪   signature by the person making it.
Where a report includes online elements, staff are reminded not to view or forward any illegal
images of a child but note what has been reported.

Pro forma forms are to be used . Appendix 7.

Where there is a safeguarding concern, The DSL will consider the appropriate action to take in
accordance with the threshold document published by Dorset Safeguarding Children Board. Options
will include:

            processes;
            making an early help assessment; or
            making a referral for statutory services.

          situation does not appear to be improving, the DSL (or the person that made the referral)
should consider following local escalation procedures to ensure their concerns have been addressed

Staff should not assume a colleague or another professional will take action and share information that
might be critical in keeping children safe. Staff should challenge any inaction and follow this up with the
                                                           ns, discussions and decisions made and the
reasons for those decisions should be recorded in writing.

Early Help

Any child may benefit from early help but all staff should be particularly alert to the potential need for
early help for a child who:

▪   Is disabled and has specific additional needs;
▪   Has special educational needs (whether or not they have a statutory education, health and care
    plan);

BCS_Safeguarding Children and Child Protection Policy_111219                                16 of 60
▪   Is a young carer;
▪   Is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement
    and association with organised crime groups;
▪   Is frequently missing/goes missing from care or from home;
▪   Is misusing drugs or alcohol themselves;
▪   Is at risk of modern slavery, trafficking or exploitation;
▪   Is in a family circumstance presenting challenges for the child, such as substance abuse, adult
    mental health problems or domestic abuse;
▪   Has returned home to their family from care;
▪   Is showing early signs of abuse and/or neglect;
▪   Is at risk of being radicalised or exploited;
▪   Is a privately fostered child.

Early help means providing support as soon as a problem emerges at any point in a child's life, from
the foundation years through to the teenage years.

In the first instance, staff who consider that a pupil may benefit from early help should discuss this with

relevant agencies and setting up inter-agency assessment as appropriate. Staff may be required to
support other agencies and professionals in an early help assessment, in some cases acting as the
lead professional. The DSL will support staff in liaising with external agencies and professionals in an
inter-agency assessment, as appropriate. If early help is appropriate, the matter will be kept under
constant review and consideration given to a referral to children's social care if the pupil's situation
does not appear to be improving or is getting worse.

When dealing with a safeguarding concern                                                      ings are
taken into account wherever possible and will work with them (and their families where appropriate)
when determining what action to take and what services to provide. This is particularly important in the
context of harmful sexual behaviours, such as sexual harassment and violence. The School manages
this through individual conversations between pupil and DSL and/or Deputies where the pupil can
express their views, give and receive feedback. Pupils with specific communication difficulties or
vulnerabilities may be supported by another appropriate adult as necessary.

Safeguarding information will often be special category personal data and the School will have due
regard to its data protection obligations when sharing such data. Whilst the School aims to get consent
to share information, relevant personal information may be shared without consent if there is a lawful

shared without consent. Any decision to share or withhold information will be recorded together with
the reasons for it and who the information has been given to. The School operates its processes with
the best interests of the pupil at their heart.

Child abuse occurs in families from all classes, cultures and religions.

If a child makes a disclosure about abuse
A child may tell you that he/she has been abused or you may have good reason to suspect that abuse
is taking place. Where a child feels able to disclose abuse to a teacher, it is generally a sign of a strong
and trusting relationship. Such a disclosure may, however, come as a great shock to the teacher
concerned, but it is, of course important not to let any sign of distress or repugnance become obvious
to the pupil.

The member of staff who has been approached should:

▪   talk quietly with the child.
▪   hold the conversation in a quiet area where there are not likely to be any interruptions
▪   adopt a supportive and listening role

BCS_Safeguarding Children and Child Protection Policy_111219                                17 of 60
▪   reassure the individual that the allegation/complaint will be taken seriously
▪   not ask leading questions,
▪   make any attempts at cross-questioning or, where physical abuse is concerned, undress the child.
▪   not guarantee absolute confidentiality (as this may ultimately not be in the best interests of the
    child) and explain to the child that staff will only share the information with those who need to know
    to help the child. All staff should explain next steps and who the information will be passed to.}
It is also important to remember that it is a difficult subject for a child to discuss and, in addition, they
ma

The member of staff should then always complete a Record of concern/disclosure form (Appendix 7)
and then discuss the matter immediately with one of the DSLs listed at the front of this policy.

In cases of a disclosure or suspicion of abuse the DSL will make a referral to the local social services
department to make them aware within 24 hours (In writing or with written confirmation of a telephone
referral) The Head will be kept fully informed.

In cases of serious harm, the police will be informed from the outset.

If the injury is so serious that immediate medical treatment is required, the child will be taken to
                                                      staff. The parent(s) will be informed that this action
has been taken.

It is important to record in detail all available information since legal proceedings may arise from the
investigation which follows a referral. This should include the sequence and time of events, the
personnel involved, sketches to show the position of any physical injuries and a description of the
                                               by the child or parents/guardians should be noted accurately
as soon as possible.

It is essential that children who are known to be at risk or about whom there has been concern in the
past, are observed closely in school and that the appropriate Social Services Office is alerted
immediately if there are any further concerns.

Information relating to individual cases is strictly confidential and child abuse records are therefore
kept separately from the school records by the Deputy Head (Pastoral)/Head of Prep in their office in a
locked drawer.

When a child known to be at risk transfers to another school, the Head will contact the new Head
urgently to give details of the current situation and past concerns. All confidential records will be sent
under separate cover.

Allegation of abuse is against members of staff/volunteers/Head

                          for managing concerns/ allegations against staff who are currently working in
the School follows Department for Education statutory guidance and LCSB arrangements and applies
when staff (including volunteers) have (or are alleged to have)

▪   Behaved in a way that has harmed a pupil, or may have harmed a pupil;
▪   Possibly committed a criminal offence against or related to apupil; or
▪   Behaved towards a pupil in a way that indicated that they may pose a risk of harm if they were to
    work regularly or closely with children.
Allegations against a teacher who is no longer teaching should be referred to the Police. Historical
(non-recent) allegations of abuse should be referred to the Police and also the LADO.

If an allegation is made against anyone working with pupils in the School, the School should not
undertake their own investigation of allegations without prior consultation with the LADO or, in the

BCS_Safeguarding Children and Child Protection Policy_111219                                   18 of 60
most serious cases, the Police, so as not to jeopardise statutory investigations. In borderline cases, the
School may discuss informally with the LADO on a no-names basis.

All allegations should be investigated as a priority to avoid any delay.

All allegations which appear to meet the above reporting criteria are to be reported straight away to

concern, reports should be made to the Chair of the LGB, Head of Safeguarding and Chair of the BS
Executive Committee. Where the Head is the subject of the allegation or concern, the Head must not
be informed of the allegation prior to contact with the Chair of the LGB, Head of Safeguarding and
Chair of the BS Executive Committee.

 The case manager should immediately discuss the allegation with the designated officer and consider
the nature, content and context of the allegation and agree a course of action including any
involvement of the Police. (Where the case manager deems there to be an immediate risk to children
or there is evidence of a possible criminal offence, the case manager may involve the Police
immediately.) All discussions should be recorded in writing, and any communication with both the
individual and the parents of the child(ren) agreed. The designated officer should be informed within

or that are made directly to the Police and/or child

The case manager will ensure that the individual who is subject of the allegation is informed as soon as
possible and given an explanation of the likely course or action, unless there is an objection by
                                ice. The case manager will appoint a named representative to keep the
individual informed of the progress of the case and will consider what other support is appropriate for
the individual.

The case manager should give careful consideration as to whether the circumstances of the case
warrant suspension or whether alternative arrangements should be put in place until the allegation is
resolved. The case manager will give due weight to the views of the designated officer and KCSIE
when making a decision about suspension. Where the individual is suspended, the case manager will
ensure they know who their point of contact is in the School and shall provide them with their contact
details.

Where a member of boarding staff is suspended pending an investigation, the case manager may
make available alternative accommodation away from children.

The case manager will ensure that parents are informed as soon as possible and kept informed about
                                                                       the Police.

The case manager will discuss with the designated officer whether a referral to the Disclosure and
Barring Service or Teaching Regulation Agency should be made where an allegation is substantiated
and the person is dismissed or the School ceases to use their services, or the person resigns or
otherwise ceases to provide their services. The School has a legal obligation to report promptly to the
Disclosure and Barring Service any person (whether employed, contracted, a volunteer or a pupil) who
has harmed, or poses a risk of harm, to a child, or if there is reason to believe the member of staff has
committed one of a number of listed offences, and who has been removed from working (paid or
unpaid) in regulated activity, or would have been removed had they not left. Further, or in the
alternative, if an investigation leads to the dismissal or resignation prior to dismissal of a member of
teaching staff specifically, the School must consider making a referral to the Teaching Regulation
Agency and a prohibition order may be appropriate (because that teacher has displayed unacceptable
professional conduct, conduct that may bring the profession into disrepute or a conviction at any time
for a relevant offence).

BCS_Safeguarding Children and Child Protection Policy_111219                              19 of 60
On conclusion of the case, the case manager should review the circumstances of the case with the

safeguarding procedures or practices to help prevent similar events in the future.

The School will make every reasonable effort to maintain confidentiality and guard against unwanted
publicity whilst an allegation is being investigated or considered.

Allegations found to be malicious will be removed from the individual's personnel records. In all other
circumstances a written record will be made of the decision and retained on the individual's personnel
file in accordance with KCSIE and a copy will only be provided to the individual concerned.

Allegations proven to be false, unfounded or malicious will not be included in employer references.
With unsubstantiated allegations it would depend on the circumstances. If an allegation is shown to
be deliberately invented or malicious, the Head will consider whether any disciplinary action is
appropriate against a pupil who made it; or whether the Police should be asked to consider if action
might be appropriate against the person responsible even if they are not a pupil.

Allegation of Peer-on-peer abuse

It is essential that any allegation of abuse made by a pupil against another pupil/pupils in the school is
dealt with fairly, quickly, and consistently, in a way that provides effective protection for all the children
involved.

Types of Peer on Peer Abuse:

    •   bullying (including cyberbullying);
    •   physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing
        physical harm; sexual violence, such as rape, assault by penetration and sexual assault;
    •   sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment,
        which may be stand-alone or part of a broader pattern of abuse;
    •
        knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or
        cause the victim humiliation, distress or alarm
    •   sexting (also known as youth produced sexual imagery)
    •   initiation/hazing type violence and rituals.

In order to reduce peer on peer abuse, pupils are educated on anti-bullying strategies through PSHE,
tutor time and through SSCT delivery of education sessions for Y7-13 appropriate for their age. Staff
are on duty at break/lunch. Pupils are encouraged to speak to any member of staff whether teaching
or non-teaching about any concerns they have.

Any allegation of peer on peer abuse will be taken seriously and will not be passed off as banter or as
part of growing up. The school will follow the Pan Dorset Safeguarding Partnership Plan Levels of
Need and Continuum of Support to ascertain the level of intervention necessary.

Allegations against another pupil must be reported to the designated person with responsibility for
safeguarding (who will inform the Head and the LSCB in accordance with local procedures

The DSL and/or Head will:

▪   Ascertain if the incident is abuse
▪   Determine the frequency, nature and severity of the incident
▪   Ascertain if the victim was coerced by physical force, fear or by a pupil or pupils significantly older
    than himself/herself or with power or authority over him
▪   Ascertain whether the incident involved a potentially criminal act

BCS_Safeguarding Children and Child Protection Policy_111219                                  20 of 60
If it is established that there is reasonable cause to suspect that a child is suffering, or likely to suffer,
significant harm the school will report its concerns to social care. The Head will inform the parents of all
children involved.

In the event of disclosures about peer-on-peer abuse, all children involved will be treated as being at

                                                                                           whatever
reason that a child may be at risk of or experiencing abuse by their peer(s), or that a child may be at
risk of abusing or may be abusing their peer(s), they should discuss their concern with the DSL without
delay so that a course of action can be agreed.

The School will take into account the views of the child/children affected. Unless it is considered
unsafe to do so, the DSL should discuss the proposed action with the child/children and their parents
                                            social care. The School should manage the child/children's
expectations about information sharing, and keep them and their parents informed of developments,
where appropriate and safe to do so.

All children affected by peer-on-peer abuse will be supported by the DSL or a staff member that the
child feels comfortable with and support from external agencies will be sought, as appropriate.

safe. The School recognises that children with special educational needs and disabilities can be more
prone to peer on peer group isolation than other children and will consider extra pastoral support for
those children such as Head of Year, School Counsellor or SENCO.

A pupil against whom an allegation of abuse has been made may be suspended from the School
during the investigation. The School will take advice from the LCSB on the investigation of such
allegations and will take all appropriate action to ensure the safety and welfare of all pupils involved

Police in relation to allegations of abuse, the School will ensure that, subject to the advice of the Pan
Dorset Safeguarding Children Partnership Plan

Parents are informed as soon as possible and that the pupils involved are supported during the
interview by an appropriate adult and until the investigation is completed. Confidentiality will be an
important consideration for the School and advice will be sought as necessary from the Pan Dorset
Safeguarding Children Partnership Plan and/ or the Police as appropriate.}

Reports concerning harmful sexual behaviour

Where a report concerns an allegation of sexual violence and/or sexual harassment, if possible two
members of staff should be present when managing a report (preferably one of them being the DSL
DDSL. The DSL or DDSL should be informed as soon as practically possible if they were not involved in
the initial report.

Consideration of safeguarding all those pupils involved in the safeguarding report will be immediate.
Following a report of sexual violence and/or sexual harassment the DSL will therefore consider the
appropriate response. This will include:

▪   The wishes of the victim,
▪   The nature of the alleged incident,
▪   The ages of the pupils involved,
▪   The developmental stages of the pupils involved,
▪   Any power imbalance between the pupils,
▪   If the alleged incident is a one-off or sustained pattern,
▪   Any ongoing risks,
▪   Other related issues and context.

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