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Safeguarding policy and procedures

  1. POLICY STATEMENT

    1. DMR Training & Consultancy Ltd (DMR) acknowledges its responsibilities in relation to safeguarding and promoting the welfare of young people (anyone under the age of 18) and adults at risk (formerly vulnerable adults). DMR recognises its responsibility to safeguard the welfare of all young people and adults at risk by protecting them from physical, emotional or sexual harm and from neglect or bullying or any form of radicalisation.
    2. DMR will comply with current safeguarding legislation, regulations and guidelines and will take additional reasonable steps to safeguard and minimise the risk of harm to everyone accessing its qualifications and training programmes.
    3. DMR’s Health and Safety Policy, the Prevent Strategy and this Safeguarding Policy and related procedures are designed to ensure the safeguarding of learners who access DMR’s qualifications and training programmes in regulated activities. DMR takes seriously any allegation or information concerning abuse or neglect and, where deemed necessary within the legislation, will make a referral to the appropriate agency. In addition, DMR’s safeguarding procedures also help protect DMR’s members of staff from potential harm or damage and can help avoid any false allegations.
    4. Safeguarding is everybody’s responsibility and, as such this policy applies to all DMR’s members of staff who work in direct contact with learners. Abuse may take place both outside and inside DMR’s premises. Everyone who is part of DMR is responsible for safeguarding, promoting and protecting the welfare of young people and adults at risk. Members of staff will be provided with appropriate training and support to ensure that they are able to implement this policy.
    5. This policy should be read in conjunction with the DMR Safeguarding Risk Assessment.

  2. OVERVIEW

    1. DMR fully recognises its responsibilities for protecting young people and adults at risk and will commit to fully supporting members of staff in the discharging of this policy and associated procedures.
    2. This policy applies to all members of staff, including agency staff and contractors working at DMR.
    3. DMR will: –
      1. Ensure it practices safe recruitment in checking the suitability of members of
        staff to work with young people and adults at risk.
      2. Implement processes for identifying and reporting cases, or suspected cases, of abuse.
      3. Support learners who have been abused in accordance with their agreed
        protection plan and ensuring that where a learner who is subject to a protection plan leaves a qualification or training programme, that the relevant social worker is informed immediately.
      4. Establish a safe environment in which young people and adults at risk can learn
        and develop, feel secure, are encouraged to talk and are listened to.
      5. Ensure learners know the identity of the Designated Safeguarding Officer whom they can approach if they have a concern.
      6. Will take account of guidance issued by the Department of Education, the Department for Work and Pensions, the Wigan Safeguarding Children Board, the Wigan Safeguarding Adults Board and the London Borough of Hammersmith and Fulham and will develop effective links with these and other agencies (e.g. Social Services, Child and Adult Mental Health Service, Education Welfare Service and Educational Psychology Service) and co-operate as required with their enquiries regarding protection matters including attendance at case conferences, as required.
      7. Will take seriously and respond swiftly and appropriately to all incidents,
        allegations or suspicions of poor practice or abuse.
      8. Will raise the awareness of young people and adults at risk on safeguarding and associated protection arrangements and help equipping young people and adults at risk with the knowledge needed to help keep them safe.
      9. Will provide training and development for the Designated Safeguarding Officer and other members of staff to help them recognise issues relating to safeguarding of young persons and adults that may be at risk.
      10. Will ensure all members of staff understand their responsibilities in being alert to the signs of abuse and their responsibility for referring any concerns to the Designated Safeguarding Officer responsible for the protection of young people and adults at risk.
      11. Will retain written records of concerns about young people and adults at risk, even where there is no need to refer the matter immediately and will ensure all records are kept securely and in locked locations.

  3. LEGLISLATION

    1. Legislation and a range of statutory guidelines and guidance relating to the safeguarding of children and adults at risk are in place and applicable to DMR. They include the following: –
      1. Children Act (1989);
      2. Children Act (2004);
      3. Children Act (2014);
      4. The Protection of Children Act (1999);
      5. Education Act (2002);
      6. Education Act (2011);
      7. Keeping Children Safe in Education (2024) (due to be updated from September
        2025);
      8. No Secrets (2015);
      9. What to do if You are Worried a Child is being Abused (March 2015);
      10. Working Together to Safeguard Children (2023);
      11. Sexual Violence and Sexual Harassment (2021);
      12. Education and Training (Welfare of Children) Act (2021);
      13. Police Act 1997 (Protection of Vulnerable Adults) Regulations (2013);
      14. Safeguarding Vulnerable Groups Act (2006) (Controlled Activity and
        Prescribed Criteria) Regulations and Amendments (2012);
      15. Care Act (2024);
      16. The Sexual Offences Act (2003);
      17. Children and Social Work Act (2017);
      18. GDPR (2018) and the Data Protection Act (2018);
      19. Modern Slavery Act (2015);
      20. Safeguarding Children and Young People from Knife Crime (2019);
      21. UK Council for Internet Safety (UKCIS) (2020);
      22. The Counter Terrorism and Security Act (2015);
      23. The Protection of Freedoms Act (2012);
      24. The Human Rights Act (1998);
      25. The Equality Act (2010);
      26. Safeguarding Children and Safer Recruitment in Education (2007);
      27. Domestic Abuse Act (2021);
      28. Childcare Act (2006);
      29. Every Child Matters (2003);
      30. Female Genital Mutilation Act (2003).

  4. MANAGEMENT RESPONSIBILITY

    1. The DMR Managing Director has overall responsibility for the development of and implementation of this policy.
    2. The DMR Designated Safeguarding Officer DSO manages the day-to-day implementation, related policies and procedures, training requirements and maintains and monitors all reports for satisfactory closure.
    3. Cases of reported allegations or risks and outcomes will be reviewed as part of the monthly Performance Management Review process.
    4. DMR is committed to promoting a positive, supportive and secure environment where learners feel valued and safe.
    5. DMR is committed to working with local safeguarding organisations, such as the Wigan Safeguarding Children Board, Wigan Safeguarding Adults Board, the London Borough of Hammersmith and Fulham Channel, the police, the Department for Education, the Department for Work and Pensions, devolved local authorities and other agencies, community and referral groups such as Social Services, Child and Adult Mental Health Service, Education Welfare Service and Educational Psychology Service etc.to ensure the safeguarding of all learners.

  5. DMR DESIGNATED SAFEGUARDING OFFICER

    1. It is the responsibility of the Designated Safeguarding Officer (DSO) to: –
      1. Investigate, improve, monitor and review DMR’s safeguarding processes;
      2. Take action on referrals from both internal and external sources;
      3. Make decisions about referrals to the Social Services Child Protection Team,
        Safeguarding Boards and the police;
      4. Endeavour to keep up to date with all relevant legislation, regulations and
        guidelines;
      5. Collect all necessary data and ensure it is kept strictly confidential and protected
        by password access and stored under lock and key;
      6. Determine if an internal investigation is required and to liaise with Social Services
        and the police to avoid compromising any official investigation;
      7. Identify and signpost to organisations for support where characteristics of
        exploitation, extremism, bullying, abuse or grooming has been recognised;
      8. Liaise with the Managing Director to ensure all necessary support and guidance is
        available as appropriate.

  6. RESPONSIBILITIES OF DMR MEMBERS OF STAFF

    1. It is the responsibility of all members of staff to: –
      1. Attend safeguarding training as required;
      2. Familiarise themselves with this Safeguarding Policy and associated procedures;
      3. Safeguard and promote the welfare of young people and adults at risk;
      4. Alert the DSO if they have concerns about a child or adult at risk;
      5. Seek urgent medical or police assistance if needed;
      6. Understand the risks of bullying, grooming, abuse, exploitation, extremism and on
        -line safety and how to support learners in keeping themselves safe.

  7. DEFINITIONS

    1. Young Person
      This policy recognises and builds on the legal and statutory definitions of a young person, the distinction between ages of consent, civil and criminal liability are recognised, but in the pursuit of good practice for DMR, a young person is recognised as being under the age of 18 years. (Children’s Act 1989 and 2004).
    2. Adult at Risk
      This refers to all those adults (aged over 18) who have care and support needs, are experiencing or are at risk of experiencing, abuse or neglect and as a result of those care and support needs are unable or less able to protect themselves from abuse or neglect or the risk of it (Care Act 2024).
    3. Physical Abuse
      A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
    4. Emotional Abuse
      The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only in so far as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
    5. Sexual Abuse
      Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child 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 children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place on-line, and technology can be used to facilitate off-line abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
    6. Child Sexual Exploitation
      Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator and/or through violence or the threat of violence. The victim may have been sexually exploited even if the sexual activity appears consensual.Sexual abuse 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 clothing. It may include non-contact activities, such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse including via the internet.

       

      Child sexual exploitation can occur over time or be a one-off occurrence, and may happen without the child’s immediate knowledge for example through others sharing videos or images of them on social media.

      Child sexual exploitation can affect any child who has been coerced into engaging in sexual activities. This includes 16 and 17 year olds who can legally consent to have sex. Some children may not realise they are being exploited for example they believe they are in a genuine romantic relationship.

      Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology. A significant number of children who are victims of sexual exploitation go missing from home, care or education at some point. Some of the following signs may be indicators of sexual exploitation: –

      1. Young people who appear with unexplained gifts or new possessions;
      2. Young people who associate with other young people involved in exploitation;
      3. Young people who have older boyfriends or girlfriends;
      4. Young people who suffer from sexually transmitted infections or become pregnant;
      5. Young people who suffer from changes in emotional wellbeing;
      6. Young people who misuse drugs and alcohol;
      7. Young people who go missing for periods of time or regularly come home late;
      8. Young people who regularly miss school or education or do not take part in
        education.
    7. Sexual Violence and Sexual Harassment
      Sexual violence and sexual harassment is unwanted conduct of a sexual nature, and this can occur between two or more children of any age and sex. Members of staff should be aware that this sort of behaviour is not limited to adults.
    8. Bullying
      Bullying is persistent behaviour directed against an individual, which is intimidating, offensive or malicious and undermines the confidence and self-esteem of the recipient which may cause him or her to suffer stress. Bullying can take place by direct personal contact, or through digital communication such as mobile phones, social networking sites, e-mail or gaming consoles.
    9. Peer-on-Peer Abuse
      This includes all types of bullying (including cyber bullying, prejudice-based and discriminatory bullying); abuse in intimate personal relationships between children (sometimes known as ‘teenage relationship abuse’) sexual violence and sexual harassment such as sexual comments, remarks, jokes and on-line sexual harassment, which may be standalone or part of a broader pattern of abuse, rape, assault by penetration and sexual assault; (this may include an on-line element which facilitates, threatens and/or encourages sexual violence); physical abuse such as hitting, kicking, hair pulling or otherwise causing physical harm (this may include an on-line element which facilitates, threatens and/or encourages physical abuse); 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, consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery); upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress, or alarm, initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an on-line element)
      child sexual exploitation; gang activity and youth violence.Teenage relationship abuse is defined as a pattern of actual or threatened acts of physical, sexual and/or emotional abuse, perpetrated by an adolescent (between the ages of 13 and 18) against a current or former partner. Abuse may include insults, coercion, social sabotage, sexual harassment, threats and/or acts of physical or sexual abuse. Sexual violence and sexual harassment can occur between two children of any sex. They can occur through a group of children sexually assaulting or sexually harassing a single child or a group of children.

       

      Peer on Peer abuse requires a specific focus within DMR as it is recognised that it is a particularly sensitive and complex area of safeguarding learners. All members of staff should recognise that learners are capable of abusing their peers and that inappropriate behaviour should never be tolerated or passed off as ‘banter’ or ‘part of growing up’.

      Peer on peer abuse is often gender specific, such as girls being inappropriately touched or sexually abused by boys; boys may be more vulnerable to initiation or hazing type violence and rituals. It is important to deal with a situation of peer abuse immediately and sensitively. As with any safeguarding concern, it is important to gather the information as soon as possible to ascertain the true facts. This should be done objectively, with consideration of intent. Where it is deemed that any party involved in the peer-on-peer abuse is at risk, then a safeguarding referral should be made. Where there is a potential criminal act, the police should also be informed.

    10. Female Genital Mutilation
      Female Genital Mutilation (FGM) is a procedure where the female genitals are deliberately cut, injured or changed, but where there is no medical reason for this to be done. FGM is most commonly carried out on girls between infancy and the age of 15, most often before puberty starts. It is illegal in the UK. Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) places a statutory duty upon teachers along with regulated health and social care professionals in England and Wales, to report to the police where they discover (either through disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Teachers must personally report to the police cases where they discover that an act of FGM appears to have been carried out.
    11. Neglect
      The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: –

       

      1. Provide adequate food, clothing and shelter (including exclusion from home or
        abandonment);
      2. Protect a young person from physical and emotional harm or danger;
      3. Ensure adequate supervision (including the use of inadequate caregivers);
      4. Ensure access to appropriate medical care or treatment;
      5. Neglect may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
    12. Significant Harm
      Some children are in need because they are suffering or likely to suffer significant harm. The Children Act 1989 introduced the concept of significant harm as the threshold that justifies compulsory intervention in family life in the best interests of children.
    13. Extremism
      Extremism goes beyond terrorism and includes people who target the vulnerable – including the young – by seeking to sow division between communities on the basis of race, faith or denomination; justify discrimination towards women and girls; persuade others that minorities are inferior; or argue against the primacy of democracy and the rule of law in our society. Extremism is defined in the Counter Extremism Strategy 2015 as the vocal or active opposition to the UK’s fundamental values, including the rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs. Calls for the death of members of the UK’s armed forces are also regarded as extremist. See the DMR Prevent Strategy Policy for further detailed information.
    14. Psychological Abuse
      This includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion or harassment. It also includes verbal abuse, cyber bullying and isolation or an unreasonable and unjustified withdrawal from services or supportive networks.
    15. Financial Abuse
      This includes theft of money or valuables, fraud, exploitation, pressure in connection with wills, property, enduring power of attorney, or inheritance or financial transactions, or the inappropriate use, misuse or misappropriation of property, possessions or benefits.
    16. Neglect and Acts of Omission
      This includes not being provided with enough food or the right kind of food, or not being taken proper care of. Leaving the person without help to wash or change dirty or wet clothes, not getting them to a doctor when one is needed or not making sure that they have the right medicines.
    17. Discriminatory Abuse
      This includes some forms of harassment, slurs or similar unfair treatment relating to race, gender, gender identity, age, disability, sexual orientation or religion.
    18. Self-Neglect
      This is not a direct form of abuse, but members of staff need to be aware of it in the general context of risk assessment/risk management and to be aware that they may owe a duty of care to a vulnerable individual who places him/herself at risk in this way.
    19. Self-Harm
      Self-harm is defined as self-poisoning or injury, irrespective of the apparent purpose of the act. Self-harm is an expression of personal distress, not an illness, and there are many varied reasons for a person to harm him or herself. Most cases of self-harm do not result in suicide; however, self-harm is known to be a risk factor in suicidal behaviour.
    20. Suicide
      Suicide is the intentional and deliberate act of taking one’s own life; youth suicide is a major global public health issue. While suicide rates are higher among 20-24 year olds, suicidal behaviour that may precede suicide is established in the earlier years. Suicide consistently ranks as one of the leading causes of death for adolescents between 15 and 19 years of age. Research suggests that certain situations put children and young people at more risk of suicide, including suffering loss or bereavement, relationship issues, experiencing bullying and/or racism, living in isolated areas and living in unhappy circumstances.
    21. Looked After Children
      The term ‘Looked After Children’ in the Children Act 1989 refers to all children and young people being looked after by a local authority, namely: – those subject to care orders or interim care orders (under sections 31 and 38 of the 1989 Act); those children who have been placed, or are authorised to be placed, with prospective adopters by a local authority (section 18(3) of the Adoption and Children Act 2002); those who are voluntarily accommodated under section 20 of the 1989 Act, including unaccompanied asylum-seeking children (where children are accommodated under this provision, parental responsibility remains with the parents); and those who are subject to court orders with residence requirements (e.g. secure remand or remand to local authority accommodation), in accordance with section 21 of the 1989 Act.
    22. So-Called ‘Honour Based’ Violence and Abuse
      So-called ‘honour-based’ violence (HBV) encompasses 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.
    23. Forced Marriage
      A forced marriage is a marriage in which one or both spouses do not consent to the marriage but are coerced into it. Duress can include physical, psychological, financial, sexual and emotional pressure. In cases of vulnerable adults who lack the capacity to consent to marriage, coercion is not required for a marriage to be forced. The Forced Marriage (Civil Protection) Act was enacted in 2007 and came into force on 25th November 2008. The Act forms part of the Family Law Act 1996 and makes provision for protecting children, young people and adults from being forced into marriage without their free and full consent.
    24. Domestic Abuse
      Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality. Controlling behaviour is a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour. Coercive behaviour is an act or a pattern of acts of assault, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten their victim.Therefore, domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn.
    25. Prevent
      Prevent is about safeguarding learners to keep them safe from being radicalised and/or exploited by extremists. The Prevent Duty is not about discouraging learners from having political views and concerns and should balance its legal duties in terms of both ensuring freedom of speech but also of protecting learners and staff welfare. Please refer to the DMR Prevent Strategy Policy.
    26. Eating Disorders
      Eating Disorders include; anorexia nervosa, bulimia nervosa, or other related (or ‘atypical’) eating disorders (mainly binge eating disorder). In general, eating disorders develop over time, sometimes over years, and often at a point when life brings fear and insecurity.
    27. Homelessness
      Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare. The DSO should be aware of contact details and referral routes into the local Housing Authority so they can raise/progress concerns at the earliest opportunity.
    28. Child Criminal Exploitation (County Lines)
      Criminal exploitation is a geographically widespread form of harm, that is a typical feature of county lines criminal activity: drug networks or gangs groom children and young people to carry drugs and money from urban areas to suburban and rural areas. This also involves enticing or grooming young people into crime or gang activity for illicit gains. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.Children can become trapped by this type of exploitation, as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the activity appears to be something they have agreed or consented to.

       

      It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however members of staff should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

    29. Modern Slavery
      Modern slavery encompasses human trafficking, slavery, servitude and forced or compulsory labour.
    30. Mental Health
      Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation. Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Members of staff, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. Where children have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood.
    31. Adults at Risk (source NHS Choices)
      1. Physical Abuse
        This can include being assaulted, hit, slapped, pushed, restrained, being denied food or water, not being helped to go to the bathroom and misuse of medication.
      2. Sexual Abuse
        This includes indecent exposure, sexual harassment, inappropriate looking or touching, as well as rape. Sexual teasing or innuendo, sexual photography, subjection to pornography, witnessing sexual acts, and sexual acts that the person does not agree to or were pressured into consenting to.
      3. Psychological Abuse
        This includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion or harassment. It also includes verbal abuse, cyber bullying and isolation or an unreasonable and unjustified withdrawal from services or supportive networks.
      4. Financial Abuse
        This includes theft of money or valuables, fraud, exploitation, pressure in connection with wills, property, enduring power of attorney, or inheritance or financial transactions, or the inappropriate use, misuse or misappropriation of property, possessions or benefits.
      5. Neglect and Acts of Omission
        This includes not being provided with enough food or the right kind of food, or not being taken proper care of. Leaving the person without help to wash or change dirty or wet clothes, not getting them to a doctor when one is needed or not making sure that they have the right medicines.
      6. Discriminatory Abuse
        This includes some forms of harassment, slurs or similar unfair treatment relating to race, gender, gender identity, age, disability, sexual orientation or religion.
      7. Self-Neglect
        This is not a direct form of abuse, but members of staff need to be aware of it in the general context of risk assessment/risk management and to be aware that they may owe a duty of care to a vulnerable individual who places him/herself at risk in this way.
      8. Self-Harm
        Self-harm is defined as self-poisoning or injury, irrespective of the apparent purpose of the act. Self-harm is an expression of personal distress, not an illness, and there are many varied reasons for a person to harm him or herself. Most cases of self-harm do not result in suicide; however, self-harm is known to be a risk factor in suicidal behaviour.
      9. Suicide
        Suicide is the intentional and deliberate act of taking one’s own life; youth suicide is a major global public health issue. While suicide rates are higher among 20-24 year olds, suicidal behaviour that may precede suicide is established in the earlier years. Suicide consistently ranks as one of the leading causes of death for adolescents between 15 and 19 years of age. Research suggests that certain situations put children and young people at more risk of suicide, including suffering loss or bereavement, relationship issues, experiencing bullying and/or racism, living in isolated areas and living in unhappy circumstances.
      10. Modern Slavery
        Modern slavery encompasses human trafficking, slavery, servitude and forced or compulsory labour.
    32. Other Safeguarding Issues
      The following list identifies other potential types of safeguarding issues: –

       

      1. Bullying including on-line bullying;
      2. People missing from training, home or care;
      3. Substance misuse;
      4. Faith abuse;
      5. Gangs and youth violence;
      6. Gender-based violence/violence against women and girls;
      7. Hate crime.

  8. SIGNS OF POSSIBLE ABUSE

    1. When considering whether there is evidence to suggest a young person or an adult at risk has been abused, there are a number of possible indicators. However, there may be other explanations, so it is important not to jump to conclusions. There may also be no signs or symptoms, this does not mean that a report of abuse is false. Members of staff should seek advice from the DSO or the relevant local Safeguarding Board.
    2. Physical Abuse
      1. Any injuries not consistent with the explanation given for them;
      2. Injuries that occur to the body in places, which are not normally exposed to falls,
        rough games etc.
      3. Injuries that have not received medical attention;
      4. Neglect – under nourishment, failure to grow, constant hunger, stealing or gorging
        food, untreated illnesses, inadequate care etc.
      5. Repeated urinary infections or unexplained tummy pains;
      6. Bruises, bites, burns, fractures etc that do not have an accidental explanation;
      7. Cuts/scratches/substance abuse;
      8. Changes in routine.
    3. Sexual Abuse
      1. Any allegations made by a person concerning sexual abuse;
      2. Person with excessive preoccupation with sexual matters and detailed knowledge
        of adult sexual behaviour, or who regularly engages in age-inappropriate sexual play;
      3. Sexual activity through words, play or drawing;
      4. Young person or vulnerable adult who is sexually provocative or seductive with
        adults;
      5. Severe sleep disturbances with fears, phobias, vivid dreams or nightmares,
        sometimes with overt or veiled sexual connotations;
      6. Eating disorders – anorexia or bulimia.
    4. Emotional Abuse
      1. Changes or regression in mood or behaviour, particularly where a child, young
        person or adult at risk withdraws or becomes clingy – also depression/aggression and/or extreme anxiety;
      2. Nervousness, frozen watchfulness;
      3. Obsessions or phobias;
      4. Sudden under-achievement or lack of concentration;
      5. Inappropriate relationships with peers and/or adults, carers or family;
      6. Attention-seeking behaviour;
      7. Persistent tiredness;
      8. Running away, stealing or lying;
      9. These signs may also indicate the possibility that a child, young person or
        vulnerable adult is self-harming.
    5. Modern Slavery
      1. Not having any documents (or having falsified documents);
      2. Not having access to parents or guardians;
      3. Possessing money or goods that can’t be accounted for;
      4. Limited or sporadic attendance;
      5. Spending a lot of time doing household chores, rarely leaving their
        house, having no freedom of movement and no time for leisure;
      6. Going missing, being found in different parts of town/city/country;
      7. Living apart from their family, often in unregulated private foster care;
      8. Living in substandard accommodation with limited access to hygiene facilities;
      9. Being unable or reluctant to give details of accommodation or personal details

  9. RISK MANAGEMENT

    1. The Police Act 1997 (enhanced Criminal Record Certificates) (Protection of Vulnerable Adults) Regulations 2013 requires employers to carry out Disclosure and Barring Service (DBS) Checks before employees are allowed to come into contact with at vulnerable adults. The DBS make barring decisions as legislated by the Safeguarding Vulnerable Groups Act 2006 which sets out the scope and operation of the vetting and barring scheme.
    2. All DMR’s members of staff engaged directly in regulated activities are subject to an enhanced DBS check, renewed every 3 years. A central register is maintained by the DMR Head of Business Development.
    3. DMR has a statutory duty to make reports and provide relevant information to the DBS where there are grounds for believing, following an investigation, that a member of staff is unsuitable to work with young people or adults at risk or may have committed misconduct.
    4. The responsibility for reporting cases to the DBS lies with the Managing Director.
    5. When recruiting and selecting members of staff, DMR will ensure that there is a rigorous interview, applicants’ identity and claims to any vocational or other qualifications will be verified, references will be taken up by direct contact with referees, evidence of the date of birth and address of the potential employee will be sought and where appropriate, an enhanced disclosure via the DBS will be secured.
    6. During job interviews the DMR interviewers will explore candidates’ ability to support the DMR agenda for safeguarding and promoting the welfare of young people or adults at risk, any gaps in candidates’ employment history and any concerns or discrepancies arising from the information provided by Learnersand/or referees.
    7. A job offer will only be made subject to the necessary checks being satisfactory, including identity verification, the right to work in the UK, references, qualifications held and the enhanced DBS check.
    8. All members of staff will have a job description and contract of employment or subcontractor agreement and will be required to work a probationary period.
    9. When results of DBS checks are pending, those members of staff will not have access to any learner or learner information that could in any way compromise any safeguarding requirements.
    10. Where the DBS checking process returns information relating to prior criminal convictions of the individual being checked, the detail provided will be a risk assessed by the Managing Director who will consider the nature of any offence(s) and the passage of time since the offence(s) and in context to the subject’s role in the business, prior to a formal offer of employment being made. Where necessary, specialist advice and assistance may be sought in strict confidence from external sources e.g. Wigan Safeguarding Children’s Board.
    11. All such risk assessments will be documented, retained for future reference and stored securely by the Managing Director.
    12. DMR has a Whistleblowing Policy for enabling members of staff to share, in confidence with the Managing Director or Head of Business Development concerns they may have around the protection of children or adults at risk. The procedure is intended to provide safeguards to enable members of staff to raise concerns without fear of adverse repercussions.
    13. DMR recognises that children and adults at risk may be at risk when operating on-line, such as being exposed to illegal, inappropriate, or harmful content, (e.g. pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, and extremism), being subjected to harmful on-line interaction with other users (e.g. peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes), on-line behaviour that increases the likelihood of, or causes, harm (e.g. making, sending and receiving explicit images) and risks such as on-line gambling, inappropriate advertising, phishing and or financial scams.
    14. DMR will put appropriate on-line filters and monitoring systems in place and regularly review their effectiveness.
    15. Should a learner make an allegation against another learner, this will be dealt with under the Disciplinary Procedure (Learners).
    16. Visitors or contractors required to have access to any DMR premises where young people or adults at risk may be present will be inducted and supervised at all times by a DMR member of staff who holds the relevant DBS clearance.

  10. STAFF TRAINING

    1. All members of staff will undergo a mandatory induction programme to DMR which includes safeguarding training. The DMR Safeguarding Policy and procedures will be issued to all new members of staff as part of their induction.
    2. All DMR’s members of staff are required to undertake mandatory safeguarding training and updating training as may be arranged periodically and according to need.
    3. All members of staff may also receive regular updates on safeguarding via e-mail, bulletins, briefings, training sessions and staff meetings.
    4. DMR is committed to ensuring that all members of staff understand their responsibilities in being alert to the signs of abuse and their responsibility for referring any concerns to the DSO.
    5. Members of staff will be made aware of their responsibility to safeguard and promote the welfare of children, young people or adults at risk.
    6. Learners/clients are made aware of the DMR DSO whom they can approach directly with any concerns they may have.
    7. All disclosures, complaints and incidents are to be reported to the DSO. All documentation will be managed and stored securely by the DSO.

  11. WHAT TO DO IF MEMBERS OF STAFF SUSPECT SOMEONE IS BEING ABUSED

    1. All members of staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another.
    2. All members of staff working in direct contact with learners must be alert to the signs of abuse.
    3. Anyone who suspects that abuse is taking place inside or outside DMR’s premises, or to whom a learner discloses issues relating to safeguarding, should contact the DSO immediately. This includes low level concerns.
    4. Members of staff who are approached with concerns or suspicions about a child or adult at risk, must bring the concerns raised to the attention of the DSO immediately.
    5. Members of staff should maintain confidentiality by not discussing the concerns or suspicions with anyone other than the DSO.
    6. The DSO will develop effective links with relevant agencies and co-operate as required with any enquires regarding child or adult at risk protection matters, including attendance at case conferences and other external meetings.
    7. If a young person or adult at risk comes to a member of staff with a disclosure of apparent abuse, the member of staff should: –
      1. Allow the young person or adult at risk to speak freely without interruption;
      2. Reassure them, let them know you are glad they have spoken up and that they
        are right to do so;
      3. Be honest, let the young person or adult at risk know that you cannot keep this a
        secret and that you will need to refer it on to get them the support that they need. Be clear that they know what will happen next;
      4. Never trivialise, exaggerate the issue or make suggestions;
      5. Try to remain calm, remember this is not an easy thing for them to do;
      6. Try not to show emotions, if you show anger, disgust or disbelief, they may stop
        talking because they feel they are upsetting you or they may feel your negative feelings are directed towards them;
      7. Show concern, and refer on any learner who needs support;
      8. Not offer or promise confidentiality, but record the facts;
      9. Offer support and security and not to react emotionally;
      10. Understand that protocols may require that they have no further involvement but
        will be given feedback;
      11. Make the young person or adult at risk feel secure and safe without causing
        them any further anxiety;
      12. Tell the learner that the record will be made and the DSO informed;
      13. Refer in an appropriate and timely manner to the DSO;
      14. Write up, to the best of your memory, what was said to you including when,
        where and who else might have heard it. This should be forwarded to the DSO.
    8. The DSO will take the case forward discussing the matter with relevant local Wigan Safeguarding Board or the London Borough of Hammersmith and Fulham (as applicable). In the case of FGM or if there is an immediate risk to a child or adult at risk, referral should be made to the police.
    9. Referral involves giving Children or Adult Services or the police, information about
      concerns relating to a child, young person, adult at risk or family in order that enquiries can be undertaken by the appropriate agency followed by any necessary action. In certain cases, the level of concern will lead straight to a referral without external consultation being necessary.
    10. Parents/carers should be informed if a referral is being made except in circumstances where it is considered that informing parents/carers would place a young person, adult at risk, yourself or others at immediate risk. However, an inability to inform parents for any reason should not prevent a referral being made. It would then become a joint decision with Children’s or Adult Services about how and when the parents or carers should be approached and by whom.
    11. If the concern is about abuse or risk of abuse from someone not known to the child or child’s family, young person or adult at risk (stranger abuse) then a telephone referral directly to the police should be made and the parents or carers advised.
    12. If the concern is about abuse or risk of abuse from a family member or someone known to the child, young person or adult at risk, then a telephone referral to the Referral and Assessment Team or the Adult Services Duty Team should be made.
    13. If emergency medical attention is required, this can be secured by calling an ambulance or taking a child, young person or adult at risk to the nearest Accident and Emergency Department. In the case of a young person, it would be appropriate for a responsible person or designated adult to accompany the child to hospital.
    14. If a young person or adult at risk is in immediate danger the police should be contacted as they alone have the power to remove a child immediately if protection is necessary, via a Police Protection Order.
    15. Members of staff should not: –
      1. Panic;
      2. Allow their shock or distaste to show;
      3. Show any disbelief or fail to take the allegations seriously;
      4. Ask questions other than to clarify that they have enough information to act;
      5. Ask questions which could be seen as leading in any way;
      6. Speculate or make assumptions;
      7. Make negative comments about alleged abuser;
      8. Approach the alleged abuser;
      9. Make promises or agree to keep secrets;
      10. Take sole responsibility;
      11. Shirk the responsibility to report the concern;
      12. Treat allegations merely as a domestic issue and send the learner back to the
        family home;
      13. Ignore what the learner has told you or dismiss out of hand the need for
        immediate protection;
      14. Decide that it is not your responsibility to follow-up the allegation;
      15. Approach the learner’s family or those with influence within the community,
        without the express consent of the learner, as this will alert them to your concerns and may place the learner in danger;
      16. Contact the family in advance of any enquiries by the police, adult or children’s
        social care, either by telephone or letter;
      17. Share information outside information sharing protocols without the express
        consent of the learner;
      18. Attempt to be a mediator or encourage mediation, reconciliation, arbitration or
        family counselling.

  12. INFORMATION REQUIRED AT THE REFERRAL STAGE

    1. Information passed to the Safeguarding Board, Social Care or the police must be as helpful as possible, hence the necessity for making a detailed record at the time of the disclosure/concern. Ideally this information should be compiled utilising an Incident Referral Form. The following information may be required: –
      1. Details of the young person or adult at risk including their name, age, gender,
        address and contact detail, parental responsibility, disabilities, culture, agencies already working with the family, relationship between the young person or adult at risk and the accused;
      2. Details of the accused including name, address, age, contact details, position held
        and any other details of known previous incidents;
      3. Primary evidence;
      4. Core information about the alleged incident;
      5. Facts from the person making the allegation including dates, times, venue and
        witness details;
      6. Records with dates;
      7. Details of anyone who has already been informed or already involved in the
        investigation.
    2. The DSO or member of staff should ensure that an accurate record is made and kept, detailing the concerns that have been referred. The concerns should be confirmed in writing to the Referral and Assessment Team or Adult Duty Team following the referral (within 48 hours). The action agreed should be recorded or that no further action is to be taken and the reasons for this decision.

  13. CONFIDENTIALITY

    1. Confidentiality and trust should be maintained as far as possible. The degree of confidentiality will be governed by the need to protect the child, young person or adult at risk who is always the primary concern. The child, young person or adult at risk must at the earliest opportunity in the disclosure be informed of the need to pass information on. every effort must be made to ensure that confidentiality is maintained when an allegation has been made and is being investigated.
    2. All conversations regarding a safeguarding disclosure made by a child or adult at
      risk should always be held in private.
    3. DMR complies with the requirements of the Data Protection Act 2018 and the
      General Data Protection Regulation (GDRP) May 2018, but also recognises the principle set out in Keeping Children Safe in Education which is “Fears about sharing information must not be allowed to stand in the way of the need to safeguard and promote the welfare and protect the safety of children”. When there is a concern that a learner is at risk of significant harm, all information held by DMR must be shared with Children’s Social Care, police and health professionals. Section 47 of the Children Act 1989 and sections 10 and 11 of the Children Act 2004 empower all agencies to share information in these circumstances.
    4. Information should be handled and disseminated on a ‘need to know’ basis only. This
      may include the following people: –

       

      1. DSO;
      2. The parents of the person who is alleged to have been abused (only following
        advice from the Children’s Social Care/police or where the abuse does not involve
        the family);
      3. The person making the allegation;
      4. Children’s Social Care, Safeguarding Boards or the police;
      5. The alleged abuser (and parents if the alleged abuser is a young person) only following advice from the Children’s Social Care/police.
      6. Information should be stored in a secure place with limited access to designated
        people, in line with the data protection laws (e.g. that information is accurate, regularly updated, relevant and secure).

  14. ALLEGATIONS OF ABUSE AGAINST DMR MEMBERS OF STAFF

    1. Allegations of abuse, or concerns raised against DMR’s members of staff, will always be treated seriously. The allegation must always be referred to the DSO, who will follow the Safeguarding Procedure in the same way as for other safeguarding allegations. The DSO will take the appropriate steps to ensure the safety of the child or adult at risk and any others who may be at risk.
    2. If the allegation or concern is against the DSO, it should be reported to the Managing Director or the Head of Business Development.
    3. Where there is a complaint against a member of staff, the Wigan Metropolitan Borough Council or the London Borough of Hammersmith and Fulham Local Authority Designated Officer (LADO) will be informed and involved. This may result in possibly criminal (police) investigations and/or a young person or adult at risk protection investigation, carried out by Social Services. In this instance, the Local Safeguarding Children Board, LADO Procedure should be followed. All steps of this procedure will be advised and supported by the LADO, working in partnership with DMR.
    4. The LADO will advise on how to proceed and whether the matter can be dealt with within DMR’s own disciplinary arrangements or whether a multi-agency strategy meeting is required. Any external investigation must not be compromised by DMR’s internal disciplinary procedure.
    5. Where the LADO decides that the issue can be dealt with internally, the reasoning and advice will be recorded and sent to the DSO, the Safeguarding Children Board or the Safeguarding Adults Board and the Police Child Protection Unit. In this instance it will be necessary to inform the LADO of the outcome of the internal DMR investigation.
    6. Where the LADO decides the case needs to proceed to an ‘Incident Evaluation Meeting’ (IEM) he/she will make a referral to the Children’s Services Referral and Assessment Team and convene the meeting/s in accordance with their guidance.
    7. Complaints made directly to the police will be reported to the LADO as soon as possible and again he/she will decide whether to hold a strategy meeting. The police may interview the complainant if they feel this is appropriate.

  15. GUIDANCE FOR MEMBERS OF STAFF FOR SAFEGUARDING CHILDREN AND ADULTS AT RISK

    1. It is essential that care is taken to minimise the possibility for abuse and misunderstanding and misinterpretation. False allegations are rare, but general good practice will help prevent them. The following examples will help to create a positive culture and climate for children, young people and adults at risk who visit DMR’s premises.
    2. The aim is to provide staff with advice which will not only help to protect learners but will also help to identify any practices or behaviours which could be mistakenly interpreted and therefore should be avoided in order to prevent false allegations of abuse being made.
    3. Good practice will also protect DMR through reducing the possibility of anyone using their role within the organisation to gain access to learners, in order to abuse them.
    4. There is much members of staff can do to avoid putting themselves in situations where their actions may be misinterpreted, and they inadvertently lay themselves open to accusations of abusing learners.
    5. Staff who breach this guidance outside of these specific circumstances may be subject to disciplinary procedures.
    6. Members of staff should: –
      1. Never work alone with children, young people or adults at risk out of public view;
      2. Maintain a safe and appropriate emotional and physical distance from children, young people or adults at risk. It is not appropriate for members of staff to have an intimate relationship with children, young people or adults at risk who attend DMR’s premises;
      3.  Not engage in rough or sexually provocative games or “horse play”;
      4. Not make sexual comments;
      5. Not invite or allow children, young people or adults at risk into their home;
      6. Not give their personal contact details (including mobile number and e-mail address) to a learner they have met through work;
      7. Not give children, young people or adults at risk lifts in their car except in
        emergencies. Wherever possible it should be with the full knowledge and consent of the parents (or guardians/carer), for those learners aged under 18. A member of the senior management team should be made aware of the journey and reason including time and location. Wherever possible, another colleague should accompany the car journey;
      8. Never develop a personal relationship. Avoid socialising with learners on occasions when it does not constitute part of normal work duties;
      9. Never let allegations, made by anyone, go unacknowledged, unresolved or not acted upon;
      10.  Never engage in inappropriate touching of any kind. If it is an accepted part of an activity, touching children, young people or adults at risk should be appropriate to the situation and follow accepted guidelines where they exist. Consoling a child, young person or adult at risk who is upset, administering first aid or supporting a participant in an activity is acceptable and necessary behaviour;
      11. Never give learners alcohol, tobacco products or any form of drug or medication.
      12. Never engage in or tolerate any bullying or harassment of any person;
      13. Never allow learners to engage in unacceptable behaviour or use offensive or discriminatory language without being challenged;
      14. Take photographs of learners for their personal use;
      15. Avoid situations where guest speakers and visitors are left alone with learners;
      16. Never expose learners to environments or circumstances or allow them to engage in activities that compromise their health or personal safety;
      17. Always ensure DMR’s procedures are followed at all times.
    7. If it is necessary to being in a position of one-to-one contact with a learner, the member of staff should only do so after discussion with and the approval of their line manager or a member of the DMR senior management team at the time.
  16. EMPLOYERS
    1. DMR works with a wide range of employers in order to deliver its qualification and other training programmes. Employers may be accessing DMR’s services in order to recruit and/or train learners, taking learners on work placements and/or work experience or employing young people who access DMR qualification and other training programmes.
    2. DMR will, and as appropriate under its health and safety arrangements, make employers aware of its safeguarding procedures and of their responsibility to ensure appropriate arrangements for safeguarding young people up to age 18 and adults at risk on their premises. Safeguarding is integral to DMR’s employer approval arrangements.

  17. E-SAFETY

    1. DMR is committed to ensuring that all members of staff and learners are aware of on-line safety, and how they can best ensure that they remain free from harm caused by online activities.
    2. DMR must therefore ensure that all members of staff and learners use information and communication technology in a safe and responsible manner.
    3. The potential dangers of using information and communication technology may include: –
      1. Access to illegal, harmful or inappropriate images or other content;
      2. Unauthorised access to/loss of/sharing of personal information;
      3. The risk of being subject to grooming by those with whom a learner may make
        contact with on the internet;
      4. The sharing/distribution of personal images without an individual’s consent or
        knowledge;
      5. Inappropriate communication/contact with others, including strangers;
      6. Cyber-bullying;
      7. Access to unsuitable video/internet games;
      8. An inability to evaluate the quality, accuracy and relevance of information on the
        Internet;
      9. Plagiarism and copyright infringement;
      10. Illegal downloading of music or video files;
      11. The potential for excessive use which may impact on the social and emotional
        development and learning of the learner.
    4. DMR is committed to ensuring members of staff receive regular training to keep up to date with new developments and ensure they are sufficiently confident to educate learners in the safe and responsible use of technology.
    5. DMR has appropriate filtering and monitoring arrangements in place and will manage the use of digital images and videos, data protection, digital communications, unsuitable/inappropriate activities and incidents of misuse.
    6. When using digital images, members of staff will inform and educate learners about the risks associated with the taking, use, sharing, publication and distribution of images. In particular they will recognise the risks attached to publishing their own images on the internet e.g. on social networking sites.
    7. Members of staff are permitted to take digital images and video to support educational aims, but must follow DMR’s policies concerning the sharing, distribution and publication of those images. Those images should only be taken on DMR equipment: the personal equipment of members of staff should not be used for such purposes.
    8. Care will be taken when capturing digital images and videos that learners are appropriately dressed and are not participating in activities that might bring the individuals or DMR into disrepute.
    9. Learners must not take, use, share or publish or distribute images of others without their permission.
    10. Images and videos published on the DMR website, or elsewhere that include learners will be selected carefully and will comply with good practice guidance on the use of such images.
    11. Learners’ full names will not be used anywhere on a DMR website or blog, particularly in association with photographs.
    12. Written permission from parents/carers will be obtained before photographs of learners are published on DMR’s website.
    13. Personal data will be recorded, processed, transferred and made available according to the GDPR Legislation which states that personal data must be: –
      1. Fairly and lawfully processed;
      2. Processed for limited purposes;
      3. Adequate, relevant and not excessive;
      4. Accurate;
      5. Kept no longer than necessary;
      6. Processed in accordance with the data subject’s rights;
      7. Secure;
      8. Only transferred to others with adequate protection.
    14. All DMR’s members of staff will ensure that: –
      1. Care is taken to ensure the safe keeping of personal data, minimising the risk of
        its loss or misuse;
      2. Personal data is used or processed on secure password protected devices and that these devices are properly ‘logged off’ at the end of any session in which they are using personal data;
      3. When personal data is stored on any portable computer system, USB stick or any other removable media, the data must be encrypted and password protected, the device must be password protected (memory sticks/cards and other mobile devices cannot be password protected), the data must be securely deleted from the device, in line with DMR’s policy once it has been transferred or its use is completed.
    15. When using communication technologies DMR ensures the following good practice: –
      1. The official DMR e-mail service is regarded as safe and secure. Members of staff
        and learners should therefore use only the DMR e-mail service to communicate with others when on site, on DMR business or on DMR systems;
      2. Members of staff will be responsible and liable for any content or language used.
        in any e-mail sent or forwarded;
      3. The e-mail system is a corporate tool and should be used as such. Disciplinary proceedings will result from any misuse. Users must immediately report the receipt of any e-mail that makes them feel uncomfortable, is offensive, threatening or bullying in nature and must not respond to any such e-mail;
      4. Any digital communication between members of staff, learners or parents/carers must be professional. These communications may only take place on official DMR systems. Personal e-mail addresses, text messaging or public chat/social network programmes must not be used for these communications;
      5. Learners will be taught about e-mail safety issues, such as risks attached to the use of personal details. They will be taught strategies to deal with inappropriate e-mails and be reminded of the need to write e-mails clearly and correctly and not include any unsuitable or abusive material;
      6. Personal information will not be posted on DMR website and only official e-mail
        addresses should be used to identify members of staff.
    16. DMR systems are only to be used for agreed, appropriate and suitable work-related activities. Internet activity which is considered unsuitable or inappropriate will not be allowed and if discovered will lead to disciplinary action. Internet activity which is illegal will be reported and could lead to criminal prosecution. In the event of an e-safety incident, it is important that there is a considered, coordinated and consistent approach.

  18. REASONABLE FORCE

    1. There are circumstances when it is appropriate for members of staff to use ‘reasonable force’ to safeguard learners. The term ‘reasonable force’ covers the broad range of actions used by members of staff that involve a degree of physical contact to control or restrain learners. This can range from guiding a learner to safety by the arm, to more extreme circumstances such as breaking up a fight or where a learner needs to be restrained to prevent violence or injury. ‘Reasonable’ in these circumstances means ‘using no more force than is needed’. The use of force may involve either passive physical contact, such as standing between learners or blocking a learner’s path, or active physical contact such as leading a learner by the arm out of a training room. The decision on whether or not to use ‘reasonable force’ to control or restrain a learner is down to the professional judgement of the member of staff concerned within the context of the law and should always depend on individual circumstances.

  19. RECORDING IMAGES OF YOUNG PEOPLE OR ADULTS AT RISK

    1. DMR views recording images and videos of young people and adults at risk to create a learning portfolio and gain a qualification as beneficial as it is crucial for progression in their qualification or training programme. These images and videos are solely used as evidence in their portfolio. DMR believes that the benefits of recording images and videos in a responsible manner outweigh the potential concerns listed below.
    2. In order to understand the reasons for the various rules and restrictions relating to the recording of images and videos it is important to understand how they can be misused.
    3. The key concerns regarding the use of images of young people and adults at risk are: –
      1. People taking inappropriate photographs or recorded images of young people and adults at risk;
      2. The possible identification of young people and adults at risk when a photograph is accompanied by inappropriate information. In particular, this can be used to give credence to a stranger pretending that they know a young people and adult at risk with a view to abduction or grooming or may allow an estranged parent to track down young people and adults at risk in contravention to a court order;
      3. The inappropriate use, adaptation or copying of images for use on websites showing child abuse images;
      4. Anybody who wants to take photographs or otherwise record images must have a valid reason for doing so;
      5. The photographer/camera person should make themselves known to the organiser or person in charge;
      6. Prior to taking any images, the photographer/camera person must have bona fide
        identification and be able to produce it on request.

  20. EMPLOYEE RECRUITMENT

    1. During candidate interviews, the interview panel will explore: –
      1. The candidate’s attitude toward children, young people and adults at risk;
      2. His or her ability to support the DMR’s agenda for safeguarding and promoting the welfare of children, young people or adults at risk;
      3. Any gaps in the candidate’s employment history;
      4. Any concerns or discrepancies arising from the information provided by the
        candidate and/or referee.
    2. A job offer will only be made subject to the necessary checks being satisfactory.
    3. All members of staff will have a job description and contract of employment or subcontractor agreement and will be required to work a probationary period.
    4. A central list will be held for those who require checks with the details that are set out in the DfE document Safeguarding Children and Safer Recruitment in Education.

  21. CONTACT NUMBERS

    1. The following are useful contact numbers: -DMR Designated Safeguarding Officer (David Melia) – 07706001587.

      Wigan GMP Public Protection Intelligence Unit – 0161 856 7957.

      Wigan Local Authority Designated Officer – 019842 486042 or 01942 828300 (out of office hours).

      Wigan Children Safeguarding Board – 01942 486025.

      Wigan Adults Safeguarding Board – 01942 828777.

      London Borough of Hammersmith and Fulham – Initial Consultation and Advice Team (ICAT) – 020 8753 6600 or 020 8748 8588 (out of office hours).

      London Borough of Hammersmith and Fulham – LADO – e-mail LADO Referrals: LADO@lbhf.gov.uk (monitored Mon to Fri, 9am to 5pm).

      London Borough of Hammersmith and Fulham Safeguarding Adults Board – Freephone 0800 145 6095, 8am to 6pm, Monday to Friday or 020 8748 8588 (out of hours).

      The NSPCC Child Protection 24-hour Helpline – 0808 800 5000.

      Freephone Modern Slavery Helpline – 0800 0121 700, operates 24 hours per day. This number provides support for those who may be victims of human trafficking.

      National Domestic Abuse Helpline – 0808 2000 247.

      Disclosure and Barring Service (DBS)

      The DBS exists to help organisations identify people who are unsuitable for certain types of work, especially work involving access to or contact with children and other vulnerable members of society, by making “disclosures” of any criminal, police or similar records. The DBS provides a disclosure service, which offers access to records held by the police, together with information from the following lists: Protection of Children Act 1999 (POCA), Protection of Vulnerable Adults (POVA) and List 99. A charge is made for obtaining a disclosure for paid positions, although disclosures for volunteers, which will include the majority of trustees, are free but will incur an administration charge from the umbrella group they choose to use. A list of umbrella bodies is available on-line.
      Tel: 0300 0200 190
      Website: www.dbs.gsi.gov.uk

      Every Child Matters (ECM):
      The ECM website holds a series of published documents that provide guidance on safeguarding, legislation, resources and the Children Act 2004.
      Website: www.everychildmatters.co.uk

  22. REVIEW

    •  This policy will be reviewed at least annually.
    • Implementation date: August 2013
      • Last review date: July 2025.