HIT Training has established a Safeguarding Policy with the goal of safeguarding children, young people, and vulnerable adults from abuse, neglect, or harm. The company is committed to raising awareness about safeguarding risks and concerns. Furthermore, HIT Training recognizes its responsibility to protect staff members by preventing unfounded accusations of abuse.
The company is dedicated to collaborating with local safeguarding or adult safeguarding Boards and other health and social care partnerships to safeguard its learners. The company will guarantee to have one nominated person, the Operations Director, who has attended the Designated Training workshop conducted by LSIS. The Operations Director will be responsible for developing and implementing any HIT Training Ltd procedures related to Safeguarding.
HIT Training Ltd will make sure that enough trainers are available within the company to provide safeguarding awareness training. All staff members will be scheduled to attend these training events. The definition of children, as defined in the Children Act of 1989, includes individuals who are under 18 years old. According to the Safeguarding Vulnerable Groups Act 2006, a ‘vulnerable adult’ refers to someone who is at least 18 years old and meets any of the following criteria:
- receiving a social care service,
- receiving a health service,
- living in sheltered accommodation,
- detained in custody or under a probation order,
- requiring assistance in managing their affairs, or
- participating in a service or activity targeted towards older people, those with disabilities, or those with physical or mental health conditions.
Accountability and Responsibility: HIT Training Ltd has three trained Safeguarding Facilitators who can provide training. Regional Managers will be responsible for ensuring that all their staff members undergo the necessary training and adhere to HIT Training Ltd’s safeguarding policies and procedures.
The Operations Director will serve as the Safeguarding Designated person and will report to the Chief Executive and Board. Incidents or concerns are reported to Managers at the local level and then escalated to the Operations Director. The Operations Director is held accountable for monitoring and managing incidents or concerns, maintaining the single annual report, and communicating with safeguarding agencies, in accordance with documents 314 and 382 in the HIT Quality Manual. The HIT Training Ltd Board is responsible for addressing the annual report on safeguarding within the company. © Hit Training Ltd 2011
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Safeguarding Policy (212) Roles and Responsibilities of the designated person
This responsibility will be in addition to their existing or main roles and responsibilities.
The designated worker will be responsible for promoting positive safeguarding procedures and practice within the organization. They will receive information from, and offer advice to, staff, volunteers, children and young people, vulnerable adults, parents and carers regarding concerns related to vulnerable adult or child protection issues. They will also maintain secure records of this information.
The information will be assessed promptly and necessary actions will be taken. People need to know both national and local safeguarding laws. They should also understand the procedures for reporting incidents to local authorities and how the police investigate abuse cases involving children and vulnerable adults. It is important to establish connections with Local Safeguarding Children Boards, as well as relevant individuals in children’s and adult services or the police.
The overall responsibilities of the company include assessing the safeguarding development needs of staff and volunteers, coordinating their training, and keeping them informed about good practice and new legislation. Additionally, they are responsible for monitoring the number of safeguarding concerns, maintaining confidential records, and providing feedback on the quality of safeguarding work. Staff members must analyze their own practice, assess risks, and ensure their practice aligns with established good practice to protect themselves from false allegations. They must also recognize their responsibilities and report any concerns about poor practice or possible abuse. Following staff guidelines and participating in annual safeguarding training is mandatory. The company offers Safeguarding workshops throughout the year, and guidelines should be followed when accompanying prospective staff during site visits.
During induction, all staff members must be provided with or directed to the company’s Safeguarding policy, which can be accessed on Google docs. Additionally, the company is responsible for conducting Criminal Record Bureau checks and implementing safe recruitment and employment practices.
New and current personnel working closely with children, young individuals, and vulnerable adults are required to undergo a background check conducted by the Home Office to obtain criminal record information. This crucial step is taken by HIT and organized by our personnel administrator. Our recruitment and selection procedure notifies all applicants that their hiring is contingent upon a satisfactory enhanced CRB check.
In February 2009, the Independent Safeguarding Authority (ISA) implemented changes to vetting and barring practices. These practices have since been reviewed and relaxed, with the possibility of more changes in the future. The Operations Director at HIT Training Ltd is responsible for ensuring compliance with relevant legislation, regulations, and practices in this field. © Hit Training Ltd 2011 Page 2 of 14 Safeguarding Policy 212 Safeguarding Policy (212)
For more information, please visit the CRB and ISA websites and refer to the inter-agency guidelines. The Safeguarding Vulnerable Groups Act 2006 includes the relevant legislation for establishing two new Barred Lists. These lists consist of individuals who are prohibited from working with children (replacing List 99 and disqualification orders) and vulnerable adults (replacing the Protection of Children Act (POCA) list and the Vulnerable Adults Scheme (POVA list)).
The Human Rights Act 1998, implemented in October 2000, aims to enforce the rights outlined in the European Convention on Human Rights. Important articles include:
– Article 3: Prohibits torture and inhuman or degrading treatment or punishment.
– Article 5: Ensures the right to liberty and security of an individual.
– Article 8: Guarantees the right to privacy and family life.
Although the United Kingdom ratified the United Nations Convention on the Rights of the Child in 1991, it has not fully integrated the convention into its legal framework. Nevertheless, various laws have incorporated several crucial elements of the convention. According to the UNCRC, a child is defined as a person below 18 years old. The Safeguarding Vulnerable Groups Act of 2006 mandates that all HIT personnel protect themselves from harm and uphold professional behavior to minimize unjust allegations of misconduct.
The Safeguarding Act mandates that HIT personnel must remain vigilant in identifying and preventing harm to individuals, promptly responding and taking necessary actions when receiving disclosures, following a prescribed procedure. Additionally, it is crucial for HIT personnel to effectively communicate their responsibilities regarding the Safeguarding agenda to all relevant stakeholders. The Children Act 1989 serves as a critical legal framework for professionals involved in the care of children and young people.
The Children Act 1989 prioritizes the well-being and welfare of individuals under 18 years old. It emphasizes that decisions made by caretakers should prioritize the needs of children and young people. This legislation provides guidance for local authority services that support children in need, as well as introducing changes to regulations regarding various types of homes and organizations. Additionally, it addresses topics such as fostering, child minding, day care for young children, adoption, and other related goals.
Part V of the act pertains to safeguarding children and specifies that only the police, local authority children’s services, and the NSPCC have the jurisdiction to investigate allegations or concerns of child abuse. It also imposes obligations on statutory agencies to collaborate for the benefit of vulnerable children. Section 175 of the Education Act 2002 mandates local authorities, maintained schools, and further education institutions (including sixth form colleges) to fulfill their responsibilities with the aim of safeguarding and advancing the well-being of children and young individuals.
Section 157 applies to independent schools, including academies and technical colleges. According to Section 10 of the Children Act 2004, local authorities must work together with relevant agencies to enhance the well-being of individuals under 18 years old. Section 11 mandates various organizations such as local authorities, police, and health services to meet their responsibilities in safeguarding and promoting children’s welfare.
The Rehabilitation of Offenders Act 1974 aims to protect ex-offenders by enabling them to withhold information about their criminal records from employers, thus preventing discrimination based on their past convictions. However, individuals working with vulnerable groups are required to fully disclose all previous convictions and cautions when applying for a job.
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The Sexual Offences Act 2003 revises existing legislation and categorizes certain actions towards children as sexual offenses.
The 2007 Safeguarding Children and Safer Recruitment in Education guidance document is a consolidated version of earlier material. It introduces the offence of abuse of trust, which occurs when a person in a caring or authoritative professional position initiates a sexual relationship with a young person or vulnerable adult, committing an offence. This document examines the processes of recruitment and selection, as well as recruitment and vetting checks, along with the responsibilities for safeguarding and promoting the welfare of children in education.
In order to create a safe learning environment, it is crucial to utilize equality legislation and provider level equality and diversity policies, alongside safeguarding legislation and policy. These laws and policies contribute to the reinforcement of safeguarding measures, including addressing bullying and harassment, as well as governing the implementation of safeguarding practices. For more information on equality legislation, please visit www.qualityhumanrights.com.
HIT Training Ltd strives to adhere to both legislation and best practices related to safeguarding. Our operations are governed by the Children Act 1989, which provides legal protection for children and young people in the UK. Additionally, according to the Protection of Children Act 1999, employers are required to conduct Criminal Record Checks on employees before they can work with children.
The Safeguarding Vulnerable Groups Act 2006 outlines the activities that both employers and individuals will be held accountable for concerning children and vulnerable adults. Since 2008, Ofsted inspectors have been assessing whether procedures at HIT Training Ltd comply with government regulations for safeguarding learners. Their assessment includes evaluating the impact of the company’s policies, procedures, vetting, and training on learners. The Board conducts annual reviews of HIT Training Ltd’s Safeguarding Policy and monitors its implementation.
The review process involves analyzing monitoring data and consulting with and receiving feedback from learners, clients, staff, and other stakeholders to assess the impact of the policy and identify any necessary action. © Hit Training Ltd 2011 Page 5 of 14 Safeguarding Policy 212 Safeguarding Policy (212) Relevant Documents This policy and procedure should be read alongside documents 314 and 382, as well as the Safeguarding handouts distributed during workshops and any future revisions.
Annex 1 Safeguarding Children and Vulnerable Adults – a quick guide for staff. The primary focus is to safeguard children, young people, and vulnerable adults from abuse, neglect, or significant harm. All employees at HIT Training Ltd have a duty to protect and enhance the well-being of these individuals during their involvement in HIT training programs and activities. To report any suspicions or concerns regarding their welfare, staff members must comply with the provided guidelines. These guidelines also encompass recognizing abuse and identifying potentially susceptible individuals.
Abuse can appear in various forms for children, young people, and vulnerable adults. For children and young people, abuse can include physical abuse (such as hitting, shaking, or burning), emotional abuse (continuous emotional maltreatment), sexual abuse (forcing or enticing a child to take part in sexual activities), and neglect (failure to meet a child’s basic needs). In the case of vulnerable adults, abuse includes physical abuse (such as hitting and misuse of medication), sexual abuse (rape and sexual assault), psychological abuse (emotional abuse and threats), discriminatory abuse (based on race, gender, religion, or disability), and financial abuse.
When a young person or vulnerable adult discloses abuse, it is important to take their disclosure seriously and not ignore it. Create a calm and supportive atmosphere to make them feel comfortable. Keep in mind that the accusation may result in a criminal investigation, so avoid asking leading questions or trying to investigate on your own as this could complicate future court proceedings. Also, refrain from guaranteeing confidentiality.
At the beginning, inform the person that you will need to report the disclosure and share the information with the HIT Manager (your Line Manager1) and Operations Director, who is the designated Safeguarding person. Immediately report the disclosure to the respective Line Manager by calling their mobile number and complete the safeguarding form within 24 hours of hearing the complaint (please refer to document 382). The Operations Director/Safeguarding Officer will, if possible: respect the individual’s wishes, but share information with external agencies if it is determined that someone is at risk of significant harm. Maintain contact with the young person and/or vulnerable adult and reporting personnel if it is agreed upon to ensure our Duty of Care. What to do if you are concerned that a young person or vulnerable adult may be at risk? Seek advice and guidance from your manager, who will recommend contacting the Operations Director or Development Director.
If you are unable to reach your Manager, contact the designated person directly. Make sure to keep a record of your concerns on document 314, the Safeguarding report, and send it to the Regional Manager and Operations Director. If the Operations Director is not available, contact the Development Director instead. It is important to discuss your concerns with the young person, if appropriate, such as instances of neglect or failure to provide necessary care or services. Remember that you only need to share basic information with your LM (Manager), and you can provide a more detailed account to the Designated person if you feel more comfortable doing so. © Hit Training Ltd 2011 Page 7 of 14 Safeguarding Policy 212 Safeguarding Policy (212) What to do if……… A young person or vulnerable adult accuses you or another member of staff of abuse? Contact your manager for advice and guidance.
The Manager should contact the Designated persons and keep a record of the accusation and actions taken. This record should be forwarded to the Regional Manager and Operations Director within 24 hours. It is important to inform all new staff on induction about the code of conduct and the Safeguarding policy. New staff should be enrolled in the next available Safeguarding workshop. The dates for the workshop can be found on the HIT calendar on Google Docs Annex 2 Safeguarding Code of Behaviour – for All Staff. There are certain conduct guidelines that should be followed by staff. Staff should avoid spending excessive amounts of time alone with children and vulnerable adults, away from others. Private meetings or meetings off-site with individual children and vulnerable adults should be avoided or take place within sight of others. If privacy is needed, the door should remain open and other staff members should be aware of the meeting. Staff are advised not to make unnecessary physical contact with children and vulnerable adults, although there may be occasions when physical contact is unavoidable, such as providing comfort at times of distress. In such cases, contact should only take place with the consent of the child or vulnerable adult and should be avoided whenever possible. Staff should not meet children and vulnerable adults outside of the work environment or at the learners’ private address.If meetings cannot occur at a HIT Training premises and must be held outside of the workplace, a public venue like a Library should be chosen. It is important that staff do not initiate an investigation or question anyone after an allegation or concern has been raised. This responsibility falls to the authorities.
Record the facts and report them to the Designated person. Staff should not initiate or engage in sexually provocative conversations or activity. Staff should challenge the use of inappropriate language. Staff should not do things for children and vulnerable adults that they can do themselves. All allegations made by a child or vulnerable adult should be reported and addressed. Child or vulnerable adult abuse issues should not be trivialized or exaggerated. Promises to keep any disclosure confidential from relevant authorities should not be made.
Staff should not display favoritism towards any individual child or vulnerable adult, nor should they employ or insinuate any type of physical discipline. There are certain areas of practice that necessitate careful consideration and guidance from a Line Manager. This includes situations where staff members are required to transport children or vulnerable adults in a car or van, regardless of the duration of the journey. However, if it is absolutely unavoidable, the consent and awareness of the parents (or guardians) must be obtained. For learners under 18 years old, Line Managers must be informed if a staff member plans to have them as a passenger in their vehicle.
It is better to use a car instead of a van because the child or vulnerable adult can be directed to sit in the back seat. Staff must show respect for the privacy rights of children and vulnerable adults and encourage them to feel comfortable enough to report any attitudes or behaviors they dislike. Staff should also exercise discretion in their personal relationships and ensure that these relationships do not interfere with their leadership responsibilities within the organization.
All existing relationships between staff and children and vulnerable adults must be declared. Staff should know how to report concerns or incidents and should be familiar with the contact details of the Operations Director (the designated person) and the Development Director (the deputy designated person). If a member of staff experiences inappropriate affection or attention from a child or vulnerable adult, they should inform others. If a staff member has concerns about the welfare of a child or vulnerable adult, whether it’s related to another staff member’s actions or based on a conversation with the individual, especially if an allegation is made, they should report it to their Regional Manager, who will then report it to the Operations Director.If a staff member is involved in an incident, either at work or outside of work activities, that could be seen as a potential safeguarding issue, they should inform their Line Manager right away. The Line Manager should then report this information to the Designated person. This procedure must be followed in cases where an allegation of child abuse is made or when there is suspicion or disclosure of abuse towards a child or vulnerable adult. It is important not to make any promises regarding confidentiality.
Begin by informing the person that any disclosure will be reported and the information will be shared with the respective Line Manager and the designated Safeguarding person, who is the Operations Director. The Operations Director will try to honor the person’s wishes, but may need to share the information with external agencies if there is a significant risk of harm. It is important to inform the respective Line Manager and Designated person about any issue that could be considered a Safeguarding concern.
The Line Manager should be notified as soon as possible, either in person or by phone. Additionally, the designated person should be contacted via phone; it is advised to refrain from using emails for communication in such cases. It is important to document the incident or concern in writing. If the complainant is the child or vulnerable adult themselves, it is recommended to ask only essential questions to understand the allegation and avoid leading questions. The use of leading questions can create issues for future investigations and court proceedings. The focus of the written record should be on presenting the facts.
The Operations Director/Development Director will determine whether the issue should be reported to an external agency, such as the Adult or Children Safeguarding Boards or the Local Authority. Typically, only the Designated or Deputy designated person should make a referral in these cases. The Designated person can also consult with external agencies to decide if a referral is necessary. If neither the Designated nor Deputy designated person is available, the individual who receives the disclosure may refer to an external agency, but this should only occur in exceptional circumstances.
The incident will be communicated by phone to the duty social worker, as specified by the local Area Child Protection Committee (ACPC) procedures or the Safeguarding Policy (212) Adult equivalent, © Hit Training Ltd 2011. If social services cannot be reached, the designated person can contact the police child protection team for the area.
The Operations Director/Designated person will keep a written record of the report, noting the date and time, as well as the name and position of the recipient. The Operations Director and the Social Services Department will collaborate to determine how to inform the parents or guardians of the child or vulnerable adult, with a record of their discussion being made.
In any inter-agency meeting, the designated person will keep records of the meetings and any agreed actions. All correspondence will be securely maintained. If there are suspicions, allegations, or apparent abuse of a child or vulnerable adult by a staff member, it should be reported to the respective Regional Manager, who will then report it to the Designated or Deputy Designated persons.
In the event that the designated persons are unavailable, another Executive Director should be contacted. Upon receiving notification of any such matter, the designated persons and/or a member of the Executive Directors must take necessary steps to ensure the safety of the child or vulnerable adult in question. They must also liaise with the person who initially reported the concern and ensure that a report of the matter is completed. If not already done, the matter should be reported to the local social service department in accordance with the above procedure, and the HIT Training Ltd CEO should be notified. Depending on the outcomes of any investigation and disciplinary reviews, HIT has the authority to report an individual to ISA. If a member of the Regional Management team or Executive team is involved in the allegation or complaint, it must be reported directly to the designated person.
If the designated person is involved in the allegation or complaint, it should be reported to the Deputy Designated person. If the HIT Training CEO is accused, it must be reported to the Non-Executive Director. All staff should be aware that allegations may be made against them, and that they may or may not be substantiated. The notification of such allegations may lead to immediate suspension of the staff member, and the company’s disciplinary procedure may be applied if deemed appropriate. © Hit Training Ltd 2011 Page 11 of 14 Safeguarding Policy 212 Safeguarding Policy (212)
HIT Training Safeguarding contacts:
Designated person – Sara Goldie, Operations Director ([email protected])
Deputy Designated person – Linda Martin, Development Director ([email protected])
Executive Team – Jill Whittaker, Finance Director ([email protected]); John Hyde, CEO ([email protected])
Non-Executive Director – Stewart Segal ([email protected])
Regional Managers:
– London Regional Manager – Adele Oxberry ([email protected])
– East Regional Manager – Ann Keen ([email protected])
– Midlands Regional Manager – Sophie Cooper ([email protected])
– West Regional Manager – Mike Worley ([email protected])
– South East Regional Manager – Lester Biddle ([email protected])
Annex 3 Notes for procedures for managing allegations against individuals working with children when external agencies are involved and an investigation is ongoing. The framework outlined in the inter-agency guidance is applicable to a broader range of allegations, not just those where there is reasonable cause to believe that a child is or will be significantly harmed. It also addresses allegations that may indicate the alleged perpetrator’s unsuitability to work with children, regardless of their current position or capacity. This guidance should be followed for all cases where it is alleged that a person working with children has:
- Behaved in a manner that has caused or could have caused harm to a child
- Potentially committed a criminal offense against a child or related to a child
- Behaved in a way towards a child or children that suggests they are unsuitable for working with children
The consideration of an allegation may involve up to three strands: a police investigation of a possible criminal offence, enquires and assessment by children’s social care about the child’s welfare, and consideration by an employer of disciplinary action. This process should also be followed for vulnerable adults. It is important to maintain confidentiality and avoid publicity during the investigation/consideration of the allegation.
According to ACPO (child protection guidelines and regulations) and AVPO (vulnerable adult protection guidelines and regulations), the police typically do not disclose information to the press or media that could potentially reveal details about an ongoing investigation, unless the individual in question has been charged with a criminal offense. Resignation and ‘compromise agreements’ should not serve as barriers to investigating allegations. It is crucial to pursue a resolution in all cases involving allegations that concern the safety or well-being of children, even if the individual involved refuses to cooperate. Whenever feasible, the accused party should be given a fair opportunity to respond to the allegation and present their side of the story.
The process of documenting the accusation and any supporting evidence and determining if it can be considered substantiated based on available information should continue, even if this cannot be achieved or the individual fails to cooperate. It may be challenging to reach a decision under such circumstances, and disciplinary actions may not be applicable if the person’s notice period elapses before the process is concluded. Nevertheless, it is crucial to reach a conclusion and document it whenever feasible. Similarly, it is imperative to avoid employing “compromise agreements” in these instances, where an individual agrees to resign, the employer does not pursue disciplinary actions, and both parties agree on specific wording to be used in future references.
In any case, an agreement of this nature will not prevent a thorough investigation by the Police. It also cannot supersede an employer’s legal obligation to refer to the POCA list or list 99 if necessary, or follow current ISA procedures. Regarding record-keeping, it is crucial for employers to maintain a clear and comprehensive summary of any allegations, including details of how they were addressed and resolved, as well as any actions taken and decisions made. These records should be kept confidentially and a copy should be provided to the employee. The information should be retained in the individual’s file until they reach the normal retirement age, or for 10 years if longer, even if they leave the organization. The purpose of these records is to provide accurate information in response to future reference requests and offer clarification in cases where a future CRB disclosure is required.
