Safeguarding Policy and Procedure

Version and Document Control

Document Title	AECL Safeguarding Policy
Lead Officer	Sarah Johnson (Lead Officer for Adult Learning, Skills and Employability), Paul Burnett (Safeguarding and Support Officer)
Version	2.0
Status	Final
Approved by	Advisory Board
Date approved	July 2025
Last updated	July 2025
Review date	July 2026

Values

North Lincolnshire Council Adult Education and Community Learning (henceforth AECL) aims to provide all members of its community with the opportunities to engage with the highest quality of education and encouragement. We are committed to striving for excellence and ensuring that all learners and apprentices are known, valued and can achieve.

Our mission is to achieve better outcomes for the people and place of North Lincolnshire. Everyone is focussed on making a real difference to people’s lives and making North Lincolnshire the best place to live and learn.

AECL has a significant role in enabling our most vulnerable residents and communities to achieve better outcomes in terms of life skills, employment and life chances.

Introduction

The aim of this policy is:

to clarify roles and responsibilities of everyone within AECL in relation to safeguarding
to ensure that AECL creates a safe culture of respect
to have clear safeguarding procedures that are followed
to ensure that appropriate action is taken in a timely manner to safeguard and promote welfare
to ensure that all staff are aware of their statutory responsibilities with respect to safeguarding and trained in recognising and reporting safeguarding issues.

Service commitment

Safeguarding and promoting the welfare of learners and apprentices is everyone’s responsibility. Everyone who comes into contact with learners and apprentices has a role to play. To fulfil this responsibility effectively, all staff should make sure their approach is learner and apprentices-centred. This means that they should consider, at all times, what is in the best interests of the learner and apprentice.

This policy applies to all AECL staff, volunteers, visitors, and Advisory Board Members. Our policy and procedures also apply to off-site activities.

We aim to work in partnership and have an important role in inter-agency safeguarding arrangements as set out by the Care Act 2014 and Working Together to Safeguard Children 2023. Everyone working in or for AECL shares an objective to help keep adults, children and young people safe by contributing to:

protecting all learners and apprentices from maltreatment;
preventing the impairment of learners and apprentices ’mental and physical health or development.
taking action to enable all learners and apprentices to have the best outcomes.

AECL is committed to safeguarding and promoting the well-being of all of its learners and apprentices. Each learner’s and apprentice’s welfare is of paramount importance. We recognise that some learners or apprentices may be especially vulnerable to abuse. We recognise that learners and apprentices who are abused or neglected may find it difficult to develop a sense of self-worth and to view the world in a positive way.

We will establish an ethos where: –

learners and apprentices feel safe so that they can learn and develop
learners and apprentices are equipped with the skills needed to stay safe, providing opportunities for personal development and positive behaviours and attitudes throughout the curriculum.

AECL ensures that all appropriate health and safety measures are applied in relation to everyone who works for the service. We follow North Lincolnshire Council procedures around safer recruitment practice. It also includes undertaking interviews and all relevant safer recruitment checks, e.g. Disclosure and Barring Service and right to work in the UK checks etc.

HR will maintain a single central record (SCR) for all staff, in accordance with local authority procedures.

The details of an individual will be removed from the single central record once they no longer work at AECL.

All staff have a DBS check in line with local authority policies and procedures.

Equality statement / Equity statement

Some learners and apprentices have an increased risk of abuse, and additional barriers can exist for some with respect to recognising or disclosing it. We ensure that all learners and apprentices have the same protection, regardless of any barriers they may face. We give special consideration to learners and apprentices who:

have special educational needs (SEN) or disabilities or learning difficulties
may experience discrimination due to their race, ethnicity, religion, gender identification or sexuality
have English as an additional language
are known to be living in difficult situations
have issues such as substance abuse or domestic abuse
are at risk of FGM, sexual exploitation, forced marriage, or radicalisation
are refugees or asylum seekers
are at risk due to either their own or a family member’s mental health needs

Roles and Responsibilities

Our Safeguarding and Support Officer (DSL) will ensure that:

AECL has an effective Safeguarding policy and procedures in place that are in accordance with local authority guidance and locally agreed inter-agency procedures.
the local authority has a code of conduct and that this is provided to all staff and volunteers on induction.
The local authority has an acceptable use of IT policy, staff/learner/apprentice relationships and communications including the use of social media
The Local Authority will ensure that it operates safer recruitment procedures and makes sure that all appropriate checks are carried out on staff and volunteers who work with learners, apprentices; and that any panel involved in the recruitment of staff has at least one member who has undertaken the Safer Recruitment Training in line with local authority procedures
AECL has procedures for dealing with allegations against staff and volunteers that comply with guidance from the local authority and locally agreed inter-agency procedures (See Appendix 5: Allegations against staff – reporting procedures).
the local authority has appropriate electronic filtering and monitoring systems in place to ensure that learners and apprentices are safeguarded from potentially harmful and inappropriate online material; whilst recognising that “over blocking” should not lead to unreasonable restrictions as to what learners and apprentices can be taught
Our Lead Officer for Adult Learning, Employability and Skills will ensure that DSL will take lead responsibility for safeguarding and child protection.
the Lead Officer for Adult Learning, Skills and Employability is trained to the same standard as the DSL and the DSL reports directly to the Lead Officer for Adult Learning, Employability and Skills

Our AECL Manager will ensure that:

the policies and procedures adopted by the Advisory Board or local authority are fully implemented, and followed by all staff
sufficient resources and time are allocated to enable the DSL and other staff to discharge their responsibilities including taking part in strategy discussions and other inter-agency meetings and contributing to the assessments of learners and apprentices.
there are arrangements in place for safeguarding supervision for the DSL
all staff and volunteers feel able to raise concerns about poor or unsafe practice regarding learners, apprentices and such concerns are addressed sensitively and effectively in a timely manner in accordance with agreed whistle blowing policies.
North Lincolnshire Council’s Adult Protection Team is available as an alternative route for staff who do not feel able to raise concerns regarding safeguarding issues internally or have concerns about the way a concern is being handled by AECL. Staff can call 01724 297000 and ask for the Adult Protection Team. More information here.
Allegations regarding staff are referred to the Local Authority Designated Officer (LADO), as set out in the local authority’s Managing Allegations procedure
staff undertake appropriate safeguarding and Prevent training
individuals are referred to the Disclosure and Barring Service (cases where a person is dismissed or left due to risk/harm to a child)

Our DSL is a member of the SLT and takes lead responsibility for safeguarding and is expected to refer cases:

of suspected abuse and neglect to the Local Authority Adult Social Care team
to the Channel programme where there is a radicalisation concern as required and support staff who make referrals to the Channel programme
to the Disclosure and Barring Service as required where a person is dismissed or has left due to risk/harm to a learner or an apprentice.
where a crime may have been committed to the Police as required.

Working with others

The designated safeguarding lead is expected to:

provide monthly safeguarding reports to the Lead Officer for Adult Learning, Skills and Employability Chair of Advisory Board and Advisory Board member with the responsibility for Safeguarding
act as a source of support, advice and expertise for all staff
act as a point of contact with the safeguarding partners
liaise regularly with the Lead Officer for Adult Learning, Skills and Employability to inform him or her of the issues
as required, liaise with the Local Authority Designated Officer(s) (LADO) for concerns in cases which involve a staff member
liaise with staff (especially tutors, learning support staff and other appropriate professionals) on matters of safety and safeguarding and welfare (including online and digital safety) and when deciding whether to make a referral by liaising with relevant agencies so that learners and apprentices’ needs are considered holistically

Undertake training:

The DSL will undergo training to provide them with the knowledge and skills required to carry out their role. This training will be updated at least every two years. They will also undertake Prevent awareness training.

In addition to the formal training, their knowledge and skills will be refreshed at regular intervals, as required, but at least annually, to allow them to understand emerging themes. This will be done by attending appropriate external training, regional working parties and/or conference opportunities so they:

Understand the assessment process for providing intervention
Are alert to the specific needs of all learners and apprentices
Are able to keep and monitor detailed, accurate, secure written records of concerns and referrals
Encourage a culture of listening to learners, apprentices and taking account of their wishes and feelings among all staff.

Raise awareness

The designated safeguarding lead should:

Ensure each member of staff, especially new and part time staff, has access to and understands the safeguarding policy and procedure; (See Appendix 1 for procedure)
Ensure the safeguarding policy is reviewed annually, with any procedural changes implemented and reviewed regularly
Ensure all staff have an awareness of safeguarding issues that can put learners and apprentices at risk of harm. (See Appendix 3- Safeguarding concerns)

Supporting learners and apprentices

AECL recognises that the learner’s and apprentices welfare is paramount, however good safeguarding practice and outcomes rely on a positive, open and honest working partnership. Whilst we may, on occasion, need to make referrals without consultation with learners and apprentices, we will make every effort to maintain a positive working relationship with them whilst fulfilling our duties to protect them.

Learners and apprentices will be given a proper explanation of what action is being taken on their behalf and why, ensuring we will always hear and listen to their voice.

We will endeavour always to preserve the privacy, dignity and right to confidentiality of the learner or an apprentice. The DSL will determine which members of staff “need to know” personal information and what they “need to know” for the purpose of supporting and protecting the learner.

Information sharing and managing the safeguarding records

The DSL is responsible for ensuring that safeguarding records are kept up to date. Information should be kept confidential and stored securely. Records will include:

a clear and comprehensive summary of the concern
details of how the concern was followed up and resolved
a note of any action taken, decisions reached and the outcome

All staff and volunteers will:

attend mandatory safeguarding and Prevent training in each academic year and fully comply with the safeguarding policies and procedures
identify concerns as early as possible and provide help, to prevent concerns from escalating and identify learners and apprentices who may be in need of extra help or who are suffering or are likely to suffer significant harm
provide a safe environment in which learners and apprentices can learn
inform the DSL of any concerns about a learner or an apprentice. immediately or as soon as possible
inform the Lead Officer for Adult Learning, Skills and Employability of any concerns regarding a member of staff or volunteer within the service at the earliest opportunity
inform the The Lead Officer for Adult Learning, Employability and Skills line manager of any concerns regarding the Lead Officer for Adult Learning, Skills and Employability / Chair of Advisory Board at the earliest opportunity
act on the concern and make the referral themselves if they feel the concern is not being taken seriously or escalate concerns to the AECL Lead Officer for Adult Learning, Skills and Employability
ensure that timely information sharing is essential to effective safeguarding
ensure that fears about sharing information must not be allowed to stand in the way of the need to promote the welfare, and protect the safety, of learners and apprentices
ensure that the Data Protection Act (DPA) 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping learners and apprentices safe
never promise a learner that they will not tell anyone about a report of abuse, as this may not be in the learner’s or apprentice’s best interests
will speak to the DSL or Lead Officer for Adult Learning, Skills and Employability if they are in any doubt about sharing information

Child protection where children attend learning sessions as part of Family Learning programmes or an apprentice is aged 18 or below

Definitions (“Working Together 2023”)

A child: any person under the age of 18 years.

Harm means ill-treatment or impairment of health and development, including, for example, impairment suffered from seeing or hearing the ill-treatment of another.

Development means physical, intellectual, emotional, social or behavioural development.

Health includes physical and mental health; maltreatment includes sexual abuse and other forms of ill-treatment which are not physical.

For categories of abuse see Appendix 1 and further information on how to respond to disclosure.

All staff will also have an awareness of specific safeguarding issues, in particular Domestic Abuse, County Lines, Honour Based Abuse, Financial Abuse, Child Exploitation (CE), Radicalisation and the Prevent Duty, Female Genital Mutilation (FGM) and Risk of Abuse Outside The Home (ROTH). (See Section 5 for full information).

Staff will also be aware that behaviours linked to drug taking and alcohol abuse put learners and apprentices in danger. All staff will also be aware that safeguarding issues can manifest themselves via peer on peer abuse. This is most likely to include, but not limited to: bullying (including cyber bullying), gender-based violence/sexual harassment and sexting. Staff are clear as to the service’s policy and procedures with regards to peer on peer abuse.

Concerns staff must act on immediately and report:

any explanation given which appears inconsistent or suspicious
any behaviours which give rise to suspicions that a learner or an apprentice may have suffered harm (e.g. worrying behaviour)
any concerns that a learner or an apprentice may be suffering from inadequate care, ill treatment, or emotional maltreatment
any concerns that a learner or and apprentices is presenting signs or symptoms of abuse or neglect
any significant changes in a learner’s or apprentice’s presentation, including non-attendance
any hint or disclosure of abuse from any person
any concerns regarding person(s) who may pose a risk to learners and apprentices (e.g. living in a household with children present)
any potential indicators of exploitation
any potential indicators of Female Genital Mutilation (FGM)
any potential indicators of radicalisation
any potential indicators of living in a household with domestic abuse
a referral to Children’s or Adult Social Care and/or police must be made immediately if a learner or apprentice is suffering or likely to suffer harm or in immediate danger.

Responding to disclosure

Staff will not investigate but will, wherever possible, elicit enough information to pass on to the DSL in order that s/he can make an informed decision of what to do next.

The DSL will ensure that the learner’s or apprentice’s wishes and feelings are taken into account when determining what action to take and what services to provide. Adult protection processes will operate with the best interests of the learner or apprentice at their core.

Staff will:

listen to and take seriously any disclosure or information that a learner or an apprentice may be at risk of harm
try to ensure that the person disclosing does not have to speak to another member of staff
clarify the information
try to keep questions to a minimum and of an ‘open’ nature e.g. using TED technique – ‘Tell me, Explain to me, Describe to me….’
try not to show signs of shock, horror or surprise
not express feelings or judgements regarding any person alleged to have harmed the learner or apprentice.
explain sensitively to the person that they have a responsibility to refer the information to the DSL. Learners or apprentices need to know that staff may not be able to uphold confidentiality where there are concerns about their safety or someone else’s
reassure and support the person as far as possible
explain that only those who ‘need to know’ will be told;
explain what will happen next and who will be involved as appropriate
record details including date and what the learner or apprentice has said in the learners and apprentices’ words and pass to the DSL, record any visible signs, e.g. injuries or bruises
record the context and content of their involvement, and will distinguish between fact, opinion and hearsay.

Action by the DSL (or Lead Officer for Adult Learning, Skills and Employability) in their absence

Following any information raising concern, the DSL will consider:

any urgent medical needs of the learner and apprentice
discussing the matter with other agencies involved with the learner or and apprentice
consulting with appropriate persons e.g. Duty and Advice Team
the learner‘s or apprentice’s wishes, where appropriate

Then decide:

whether to make a referral to Adult Social Care because the learner or apprentice is suffering or is likely to suffer significant harm and if this needs to be undertaken immediately.

Action following a learner or apprentice referral

The DSL or other appropriate member of staff will:

make regular contact with the social worker and other professionals involved to stay informed
provide a report for, attend and contribute to any subsequent learner or apprentice protection conference

Appendix 1: Types of abuse

Somebody may abuse or neglect a person by inflicting harm or by failing to act to prevent harm. People may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse.

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a vulnerable adult or child.

Recognising Physical Abuse

The following are often regarded as indicators of concern:

An explanation which is inconsistent with an injury.
Several different explanations provided for an injury.
Unexplained delay in seeking treatment.
Other family members or carers are uninterested or undisturbed by an accident or injury.
Repeated presentation of minor injuries (which may represent a “cry for help” and if ignored could lead to a more serious injury).
Family use of different doctors and A&E departments.
Reluctance to give information or mention previous injuries.

Emotional abuse: the persistent emotional maltreatment of a person such as to cause severe and adverse effects on their emotional outlook. It may involve conveying to a person that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving someone opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature inappropriate expectations being imposed on others. These may include interactions that are beyond a person’s capability as well as overprotection and limitation of exploration and learning or preventing the person from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing people frequently to feel frightened or in danger, or the exploitation or corruption of others. Some level of emotional abuse is involved in all types of maltreatment, although it may occur alone.

The following may be indicators of emotional abuse:

Aggressive behaviour towards others.
Scape-goated within the family.
Frozen watchfulness, particularly in pre-school children.
Low self-esteem and lack of confidence.
Withdrawn or seen as a “loner” – difficulty relating to others.

Sexual abuse: involves forcing or enticing an adult, child or young person to take part in sexual activities, not necessarily involving violence, whether or not the adult, child or young person is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving adults, children or young people in looking at, or in the production of, sexual images, watching sexual activities, encouraging people to behave in sexually inappropriate ways, or grooming a person in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can children. The sexual abuse of learners or apprentices by other learners or apprentices is a specific safeguarding issue (also known as peer on peer abuse) in education and all staff should be aware of it.

Some behavioural indicators associated with this form of sexual abuse are:

Inappropriate sexualised conduct.
Self-harm (including eating disorder), self-mutilation and suicide attempts.
Involvement in prostitution or indiscriminate choice of sexual partners.

Some physical indicators associated with this form of abuse are:

Pain or itching of genital area.
Blood on underclothes.
Pregnancy in a younger girl where the identity of the father is not disclosed.
Physical symptoms such as injuries to the genital or anal area, bruising to buttocks, abdomen and thighs, sexually transmitted disease, presence of semen on vagina, anus, external genitalia or clothing.

Neglect: the persistent failure to meet a person’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development.

Evidence of neglect is built up over a period of time and can cover different aspects of parenting.

Indicators include:

Failure by parents or carers to meet the basic essential needs e.g. adequate food, clothes, warmth, hygiene and medical care.
A learner or apprentice seen to be listless, apathetic and irresponsive with no apparent medical cause.
Failure of child to grow within normal expected pattern, with accompanying weight loss.
Vulnerable adult or child thrives away from home environment.
Frequent absence from the educational setting.
Child left with adults who are intoxicated or violent.
Child abandoned or left alone for excessive period.

Financial abuse: a type of abuse which includes having money or other property stolen, being defrauded, being put under pressure in relation to money or other property and having money or other property misused.

Financial abuse might look like:

Borrowing money and not giving it back
Stealing money or belongings
Taking pension payments or other benefit away from someone
Taking money as payment for coming to visit or spending time together
Forcing someone to sell their home or assets without consent
Tricking someone into bad investments
Forcing someone to make changes in wills, property or inheritance

Appendix 2: Allegation of Abuse

When a member of staff suspects that any learner or apprentice may have been subject to abuse, or a student has disclosed that abuse has taken place, either to themselves or another learner, the allegation must be reported immediately to the Designated Safeguarding Lead (DSL) or the Deputy DSL, if the DSL is off site – unless it relates to these people. The DSL (or Deputy DSL if the DSL is off site) will ensure the allegation is acted on immediately. If required a risk assessment will be carried out to determine the timescales and escalation of the allegation. If the allegation is about Lead Officer for Adult Learning, Skills and Employability, staff should report to the Chair of the Advisory Board.

Actions when there are concerns about a learner or apprentice:

Concern, allegation, disclosure or suspicion of abuse

Is the person at immediate risk?

No	Yes
Action within 24 hours.	Ring 999 immediately.
Support the individual.	Support the individual
Complete AECL safeguarding report form and contact DSL immediately.	Complete AECL safeguarding report form and contact DSL immediately.
Forward completed report to the DSL within two working days. This should be done in a confidential manner.	Forward completed report to the DSL within one working day. This should be done in a confidential manner.
The DSL will file the report in a secure area	Confidentiality should be maintained at all times.
	If immediate response is required and the DSL is unavailable, contact the Deputy DSL, Adult Services, Children’s Services or the police.
	See Appendix 7 for contact details.

North Lincolnshire’s Children’s Services Point of Contact (SPOC) Freephone 08081689667

View further guidance here

Appendix 3: Guidance for all Staff

Guidance for all Staff on Dealing with Disclosure / Suspected Abuse / Neglect

Dealing with disclosures of abuse:

Always listen carefully and quietly – do not press for any evidence at all.
Remain calm and reassuring – do not dismiss the disclosure – do not show distress or concern.
Do not refute the allegation.
Show that you care through open and reassuring facial and body language.
Do not interrogate or ask leading questions (it could later undermine a case). Use of the TED questions; (Tell me, Explain, Describe)
Ensure you take a written verbatim account of the person’s disclosure using the appropriate disclosure Form.

At this point, take the following steps:

Explain to the learner or apprentice that the disclosure must be reported – emphasise your trust in them.
Do not promise to keep the allegation secret or that ‘everything will be alright’.
Reassure by telling the student that they have done the right thing in telling you, do not offer physical reassurance.
Do not admonish in any way e.g. ‘I wish you had told me sooner’.
Inform the DSL initially verbally.
Under no circumstances discuss the matter with any other person – if the allegations prove to be untrue, any such discussion would be deemed defamatory. Information to staff is on a ‘need to know’ basis at the discretion of the DSL.
If the learner or apprentice agrees, take them with you to the DSL.

With the DSL, prepare a detailed report itemising:

the information revealed by the learner or apprentice with absolutely no opinion.
actions taken by yourself, including when the suspicions were reported, to whom the suspicions were reported, and follow-up action taken within the Service.
date and sign any written record of events and action taken and keep confidential and secure.
the DSL keeps learners and apprentices’ records centrally and securely and are not kept in the learner’s or apprentice’s file.
All staff are under a duty to report all suspicions of abuse to the DSL.
The DSL is responsible for passing on these concerns to Adult Services.
Accurate records are essential in the event of further investigations.

If you see or hear something that concerns you:

Don’t ignore it.
Write up on the AECL safeguarding reporting sheet and seek advice immediately from your DSL
Don’t feel silly – if it worries you, someone else needs to know.
If it is something related to safeguarding, but not a learner or apprentice whose safety is immediately at risk – inform the Safeguarding and Support Officer (DSL) for pastoral support and advice
If it is related to a learner or apprentice being at risk – see the DSL, or Lead Officer for Adult Learning, Skills and Employability, immediately and definitely before the learner goes home that day, if possible.
All staff may raise concerns directly with Adult Services, if they feel an incident is not being dealt with appropriately, or they are unable to locate relevant staff.

Appendix 4: Responding to reports

Responding to reports of sexual violence and sexual harassment

It is important to note that learners and apprentices may not find it easy to tell staff about their abuse verbally. Learners and apprentices can show signs or act in ways that they hope members of staff will notice and react to. In some cases, the victim may not make a direct report. For example, a friend may make a report or a member of staff may overhear a conversation that suggests someone has been harmed or a person’s own behaviour might indicate that something is wrong.

It is essential that all victims are reassured that they are being taken seriously, regardless of how long it has taken them to come forward and that they will be supported and kept safe. Abuse that occurs online or outside of the AECL should not be downplayed and should be treated equally seriously. A victim will never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should they be made to feel ashamed for making a report or feel that their experience is being minimised.

When there has been a report of sexual violence, the DSL (or Lead Officer for Adult Learning, Skills and Employability) will make an immediate risk and needs assessment. Where there has been a report of sexual harassment, the need for a risk assessment should be considered on a case-by-case basis.

The risk and needs assessment should consider:

the victim, especially their protection and support
whether there may have been other victims
the alleged perpetrator(s); and
all other learners and apprentices, (and, if appropriate, staff) at AECL, especially any actions that are appropriate to protect them from the alleged perpetrator(s), or from future harm.

Risk assessments will be recorded (written or electronic) and will be kept under review, actively considering the risks posed to all learners, apprentices and put adequate measures in place to protect them and keep them safe.

The DSL/Lead Officer for Adult Learning, Skills and Employability will ensure they are engaging with Adult’s Social Services and specialist services as required. Where there has been a report of sexual violence, it is likely that professional risk assessments by social workers and or sexual violence specialists will be required. The AECL risk assessment is not intended to replace the detailed assessments of expert professionals and will be used to inform the AECL’s approach to supporting and protecting students and updating the school risk assessment.

The DSL response will include:

the wishes of the victim in terms of how they want to proceed. This is especially important in the context of sexual violence and sexual harassment. Victims should be given as much control as is reasonably possible over decisions regarding how any investigation will be progressed and any support that they will be offered. This will however need to be balanced with the AECL’s duty and responsibilities to protect other learners and apprentices
the nature of the alleged incident(s), including whether a crime may have been committed and/or whether Harmful Sexual Behaviour has been displayed
any power imbalance between the learners and apprentices. For example, is the alleged perpetrator(s) significantly older, more mature or more confident? Does the victim have a disability or learning difficulty?
if the alleged incident is a one-off or a sustained pattern of abuse (sexual abuse can be accompanied by other forms of abuse and a sustained pattern may not just be of a sexual nature)
that sexual violence and sexual harassment can take place within intimate personal relationships between peers
are there ongoing risks to the victim, other learners and apprentices, or AECL staff and other related issues and wider context, including any links to sexual exploitation and criminal exploitation.

The starting point regarding any report will always be that there is a zero tolerance approach to sexual violence and sexual harassment and it is never acceptable and it will not be tolerated.

There are likely scenarios for AECL to consider when managing any reports of sexual violence and/or sexual harassment. It will be important in all scenarios that decisions and actions are regularly reviewed and that relevant policies are updated to reflect lessons learnt, with potential patterns of concerning, problematic or inappropriate behaviour been identified.

Appendix 5: Allegations against staff

Allegations against staff that may meet the harms threshold

We will manage cases of allegations that might indicate a person may pose a risk of harm if they continue to work in regular or close contact with learners and apprentices in their present position, or in any capacity. AECL will follow procedures for dealing with allegations against staff and volunteers that comply with guidance from the local authority and locally agreed inter-agency procedures (See Appendix 5: Allegations against staff – reporting procedures).

Where it is identified a learner or apprentice has been harmed, that there may be an immediate risk of harm to a learner or apprentice or if the situation is an emergency, we will contact Adult Social Care and as appropriate the police immediately.

Concerns that do not meet the harm threshold

AECL will promote an open and transparent culture in which all concerns about all adults working in or on behalf of AECL are dealt with promptly and appropriately. Low level concerns does not mean that it is insignificant, it means that the behaviour towards a learner or apprentice does not meet the threshold but that an adult working in or on behalf of the AECL may have acted in a way that:

is inconsistent with the local authority code of conduct, including inappropriate conduct outside of work, and
does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO.

Appendix 6: Awareness of safeguarding

All staff should have an awareness of safeguarding issues that can put learners and apprentices at risk of harm.

Child on child sexual violence and sexual harassment

Sexual violence and sexual harassment can occur between two learners or apprentices of any age and sex. It can occur through a group of learners or apprentices sexually assaulting or sexually harassing a single learner, apprentice or group of learners or apprentices Sexual violence and sexual harassment exist on a continuum and may overlap; they can occur online and face to face (both physically and verbally) and are never acceptable.

Learners and apprentices who are victims of sexual violence and sexual harassment wherever it happens, will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same provider.

Please visit Sexual violence and sexual harassment between children in schools and colleges for full guidance.

County lines

County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs using dedicated mobile phone lines or other form of “deal line”. This activity can happen locally as well as across the UK – no specified distance of travel is required. Children and vulnerable adults are exploited to move, store and sell drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.

Children and vulnerable adults can be targeted and recruited into county lines in a number of locations including schools (mainstream and special), further and higher educational institutions, pupil referral units, children’s homes and care homes.

Children and vulnerable adults are also increasingly being targeted and recruited online using social media. Children can easily become trapped by this type of exploitation as county lines gangs can manufacture drug debts which need to be worked off or threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network.

A number of the indicators for CSE and CCE as detailed above may be applicable to where children are involved in county lines. Some additional specific indicators that may be present where a child is criminally exploited through involvement in county lines are children who:

go missing and are subsequently found in areas away from their home
have been the victim or perpetrator of serious violence (e.g. knife crime)
are involved in receiving requests for drugs via a phone line, moving drugs, handing over and collecting money for drugs
are exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection
are found in accommodation that they have no connection with, often called a ‘trap house or cuckooing’ or hotel room where there is drug activity
owe a ‘debt bond’ to their exploiters
have their bank accounts used to facilitate drug dealing

Cybercrime

People with skill and interest in computing and technology may inadvertently or deliberately stray into cyber-dependent crime. If there are concerns about a learner or apprentice in this area, the designated safeguarding lead (or a deputy), should consider referring into the Cyber Choices programme. This is a nationwide police programme supported by the Home Office and led by the National Crime Agency, working with regional and local policing. It aims to intervene where young people are at risk of committing, or being drawn into, low level cyber-dependent offences and divert them to a more positive use of their skills and interests. Please visit the Cyber Choices website for further information.

Domestic abuse

All learners and apprentices be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Experiencing domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on learners or apprentices. In some cases, a learner or apprentice may blame themselves for the abuse or may have had to leave the family home as a result. Learners or apprentices can also experience domestic abuse within their own intimate relationships.

Forced marriage

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some perpetrators use perceived cultural practices as a way to coerce a person into marriage. Education providers can play an important role in safeguarding children from forced marriage.

Please visit https://www.gov.uk/guidance/forced-marriage for further guidance.

So-called ‘honour’-based abuse (including Female Genital Mutilation and Forced Marriage)

So-called ‘honour’-based abuse (HBA) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the context of preserving ‘honour’ often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take.

All forms of HBA are abuse (regardless of the motivation) and should be handled and escalated as such. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBA, or already having suffered HBA.

FGM

FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences. More information can be found at FGM- information and resources and FGM : multi-agency statutory guidance.

Incels

“Incel” is short for “involuntarily celibate”. It generally – though not exclusively – refers to online groups of men who feel they are unable to enter into sexual relationships. They blame women for their grievances, which they discuss in internet forums. More information about Incels can be found here

Mental health

Where learners and apprentices have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences, can impact on their mental health, behaviour, and education. We identify children in need of extra mental health support, this includes working with external agencies. More information can be found at https://www.gov.uk/guidance/mental-health-and-wellbeing-support-in-schools-and-colleges

Modern Slavery and the National Referral Mechanism

Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. More information can be found at Modern slavery.

Online Safety

We ensure that learners and apprentices are informed about safeguarding, including online safety as part of an induction package and broad and balanced curriculum. Online abuse is any type of abuse that happens on the internet, facilitated through technology. It can include:

bullying
emotional abuse
sexual abuse
sexual exploitation
sexting (request for nudes)
scams
radicalisation

Peer on peer/ child on child abuse

Children can abuse other children (often referred to as peer on peer abuse) and it can take many forms. It can happen both inside and outside of school and online. It is important that all staff recognise the indicators and signs of peer on peer abuse and know how to identify it and respond to reports. This can include (but is not limited to): bullying (including cyberbullying, prejudice-based and discriminatory bullying); abuse within intimate partner relationships; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexual violence and sexual harassment; consensual and non-consensual sharing of nudes and semi-nudes images and/or videos; causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party; upskirting and initiation/hazing type violence and rituals. Addressing inappropriate behaviour (even if it appears to be relatively innocuous) can be an important intervention that helps prevent problematic, abusive and/or violent behaviour in the future.

Prevent Duty

This section should be read in conjunction with the AECL Prevent Action Plan.

All schools and colleges are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015 (the CTSA 2015), in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty.

This includes sharing information, in line with the DfE PREVENT Duty for schools and KCSIE 2024. All staff must report any concerns and the DSL will liaise with the PREVENT Police (CTU) lead and complete the PREVENT referral form.

The Prevent duty is part of an educational establishment’s wider safeguarding obligations. The DSL and other senior leaders are familiar with the Prevent duty guidance, more information can be found at Prevent duty guidance here

Channel is a multi-agency programme across England and Wales that provides support to people susceptible to becoming terrorists or supporting terrorism, underpinned by Section 36 of the CTSA 2015. Further information on Channel is available here

The DSL (DDSLs) are responsible for making PREVENT referrals, as with all referrals, the school will be asked to attend Channel and share information.

Prevent contacts in the Local Authority:-

NLC designated officer for Prevent
Stuart Minto (07717 588137)

Head of Service – Education Standards
Karen Hackett (07385 410798)

School Improvement Officer (Safeguarding
Sarah Stokoe (0738 5005271 or 01724 298165)

Named officer for safeguarding individual children
Matthew Clayton 01724 296500

Private fostering

Private fostering occurs when a child under the age of 16 (under 18 for children with a disability) is provided with care and accommodation by a person who is not a parent, person with parental responsibility for them or a relative in their own home.

A child is not privately fostered if the person caring for and accommodating them has done so for less than 28 days and does not intend to do so for longer. Such arrangements may come to the attention of school staff through the normal course of their interaction, and promotion of learning activities, with children. Where the arrangements come to the attention of the school or college we will notify the local authority to allow the local authority to check the arrangement is suitable and safe for the child. More information can be found at Private Fostering (CA 1989).

Radicalisation

Learners and apprentices of any age are vulnerable to extremist ideology and radicalisation.

Extremism is the vocal or active opposition to our fundamental values, including democracy, the rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs. This also includes calling for the death of members of the armed forces.

Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.

Terrorism is an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes or disrupts an electronic system. The use or threat must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.

The DSL is aware of the local procedures for making a Prevent referral. Further information can be accessed at Prevent Duty guidance and Channel and Prevent Multi-Agency Panel guidance , which is a voluntary, confidential support programme which focuses on providing support at an early stage to those who are identified as being vulnerable to being drawn into terrorism.

Romance scam (fraud)

Romance scams involve people being duped into sending money to criminals who go to great lengths to gain their trust and convince them that they are in a genuine relationship. They use language to manipulate, persuade and exploit so that requests for money do not raise alarm bells. These requests might be highly emotive, such as criminals claiming they need money for emergency medical care, or to pay for transport costs to visit the victim if they are overseas. Scammers will often build a relationship with their victims over time.

More information can be found at https://www.actionfraud.police.uk/a-z-of-fraud/dating-fraud

Sexual violence and sexual harassment

Sexual violence and sexual harassment can occur between two people of any age and sex from primary to secondary stage and into colleges and beyond. It can also occur online. It can also occur through a group of people sexually assaulting or sexually harassing a single person or group of people. People 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 and will be exacerbated if the alleged perpetrator(s) attends the same education institution. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and face to face (both physically and verbally) and are never acceptable. It is essential that all victims are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report. Staff should be aware that some groups are potentially more at risk. Evidence shows females, people with special educational needs and disabilities (SEND) and LGBT people are at greater risk.

Sexual violence

It is important that staff are aware of sexual violence and the fact learners and apprentices can, and sometimes do, abuse their peers in this way and that it can happen both inside and outside of AECL. When referring to sexual violence we are referring to sexual violence offences under the Sexual Offences Act 2003 as described below:

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. (Schools should be aware that sexual assault covers a very wide range of behaviour so a single act of kissing someone without consent, or touching someone’s bottom/breasts/genitalia without consent, can still constitute sexual assault.)

Causing someone to engage in sexual activity without consent: A person (A) commits an offence if: s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not consent to engaging in the activity, and A does not reasonably believe that B consents. (This could include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.)

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, e.g.to 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 s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.

Further information can be accessed at Sexual-consent.

Sexual harassment

When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline and both inside and outside of the AECL environment. Sexual harassment is likely to: violate someone’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 (education providers 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:
consensual and non-consensual sharing of nudes and semi-nudes images and/or videos.

Further information is available at Sharing-nudes.

sharing of unwanted explicit content
upskirting (is a criminal offence)
sexualised online bullying
unwanted sexual comments and messages, including, on social media
sexual exploitation; coercion and threats.

Further information is available from https://www.stopitnow.org.uk/concerned-about-a-child-or-young-persons-sexual-behaviour/help-and-advice/preventing-harmful-sexual-behaviour/

Upskirting

The Voyeurism (Offences) Act 2019, which is commonly known as the Upskirting Act, came into force on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a person’s clothing (not necessarily a skirt) without their permission and or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. It is a criminal offence. Anyone of any sex, can be a victim.

Appendix 7: Useful contact numbers

Designated Safeguarding Lead (DSL)	Paul Burnett 01724 297467 Paul.Burnett@northlincs.gov.uk
Lead Officer for Adult Learning, Skills and Employability (DDSL)	Sarah Johnson 01724 297146 Sarah.Johnson@northlincs.gov.uk
Advisory Board member with responsibility for safeguarding	Sarah Stokoe School Improvement Officer (Safeguarding) 07385 005271 Sarah.stokoe@northlincs.gov.uk
North Lincolnshire’s Children’s Services Point of Contact (SPOC)	01724 296500 (office hours) 01724 296555 (out of hours) Freephone 08081689667
North Lincolnshire Council Adult Protection Team	01724 297000 adultprotectionteam@northlincs.gov.uk
Allegations against/concerns about adult(s) working with children	Local Authority Designated Officer (LADO) Helen Myers 01724 298293
Police (emergency) Police (non-emergency)	999 101
Humberside Police Community Cohesion Officer	Mansoor Gull (PC 1264) 101 ext 4663
Head of Education: Standards and Early Years	Helen Hatton 01724 298396 Helen.Hatton@northlincs.gov.uk
NSPCC Whistleblowing helpline	0800 028 0285
Prevent	Stuart Minto 07717 588137 Karen Hackett 07385 410798
The Blue Door	0800 197 47 87 01724 841947 (office)

Useful links:

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