Appendix 3: allegations of abuse made against staff
 
Allegations against staff (including low-level concerns) policy 
 
Section 1: allegations that may meet the harm threshold
This section applies to all cases in which it is alleged that a current member of staff, including a supply teacher, volunteer or contractor, has:

• Behaved in a way that has harmed a child, or may have harmed a child, and/or 

• Possibly committed a criminal offence against or related to a child, and/or

• Behaved towards a child or children in a way that indicates they may pose a risk of harm to children, and/or 

• Behaved or may have behaved in a way that indicates they may not be suitable to work with children – this includes behaviour taking place both inside and outside of school 

If we’re in any doubt as to whether a concern meets the harm threshold, we will consult our local authority designated officer (LADO). 
We will deal with any allegation of abuse quickly, in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation. 
A ‘case manager’ will lead any investigation. This will be the Manager, or the chair of Directors  where the Manager is the subject of the allegation. The case manager will be identified at the earliest opportunity.
Our procedures for dealing with allegations will be applied with common sense and judgement.
If we receive an allegation of an incident happening while an individual or organisation was using the school premises to run activities for children, we will follow our safeguarding policies and procedures and inform our LADO.
Suspension of the accused until the case is resolved
Suspension of the accused will not be the default position and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that there might be grounds for dismissal. In such cases, we will only suspend an individual if we have considered all other options available and there is no reasonable alternative.
Based on an assessment of risk, we will consider alternatives such as:

• Redeployment within the school so that the individual does not have direct contact with the child or children concerned

• Providing an assistant to be present when the individual has contact with children

• Redeploying the individual to alternative work in the school so that they do not have unsupervised access to children

• Moving the child or children to classes where they will not come into contact with the individual, making it clear that this is not a punishment and parents/carers have been consulted

• Temporarily redeploying the individual to another role in a different location

If in doubt, the case manager will seek views from the school’s personnel adviser and the designated officer at the local authority, as well as the police and local authority children’s social care where they have been involved.
Definitions for outcomes of allegation investigations

• Substantiated: there is sufficient evidence to prove the allegation

• Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive, or to cause harm to the subject of the allegation

• False: there is sufficient evidence to disprove the allegation

• Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation (this does not imply guilt or innocence)

• Unfounded: to reflect cases where there is no evidence or proper basis that supports the allegation being made

Procedure for dealing with allegations
In the event of an allegation that meets the criteria above, the case manager will take the following steps:

• Conduct basic enquiries in line with local procedures to establish the facts to help determine whether there is any foundation to the allegation before carrying on with the steps below

• Discuss the allegation with the designated officer at the local authority. This is to consider the nature, content and context of the allegation and agree a course of action, including whether further enquiries are necessary to enable a decision on how to proceed, and whether it is necessary to involve the police and/or local authority children’s social care services. (The case manager may, on occasion, consider it necessary to involve the police before consulting the designated officer – for example, if the accused individual is deemed to be an immediate risk to children or there is evidence of a possible criminal offence. In such cases, the case manager will notify the designated officer as soon as practicably possible after contacting the police)

• Inform the accused individual of the concerns or allegations and likely course of action as soon as possible after speaking to the designated officer (and the police or local authority children’s social care services, where necessary). Where the police and/or local authority children’s social care services are involved, the case manager will only share such information with the individual as has been agreed with those agencies

• Where appropriate (in the circumstances described above), carefully consider whether suspension of the individual from contact with children at the school is justified or whether alternative arrangements such as those outlined above can be put in place. Advice will be sought from the designated officer, police and/or local authority children’s social care services, as appropriate

• Where the case manager is concerned about the welfare of other children in the community or the individual’s family, they will discuss these concerns with the DSL and make a risk assessment of the situation. If necessary, the DSL may make a referral to local authority children’s social care

• If immediate suspension is considered necessary, agree and record the rationale for this with the designated officer. The record will include information about the alternatives to suspension that have been considered, and why they were rejected. Written confirmation of the suspension will be provided to the individual facing the allegation or concern within 1 working day, and the individual will be given a named contact at the school and their contact details

• If it is decided that no further action is to be taken in regard to the subject of the allegation or concern, record this decision and the justification for it and agree with the designated officer what information should be put in writing to the individual and by whom, as well as what action should follow both in respect of the individual and those who made the initial allegation

• If it is decided that further action is needed, take steps as agreed with the designated officer to initiate the appropriate action in school and/or liaise with the police and/or local authority children’s social care services as appropriate

• Provide effective support for the individual facing the allegation or concern, including appointing a named representative to keep them informed of the progress of the case and considering what other support is appropriate 

• Inform the parents or carers of the child/children involved about the allegation as soon as possible if they do not already know (following agreement with local authority children’s social care services and/or the police, if applicable). The case manager will also inform the parents or carers of the requirement to maintain confidentiality about any allegations made against teachers (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of a teacher will be advised to seek legal advice

• Keep the parents or carers of the child/children involved informed of the progress of the case (only in relation to their child – no information will be shared regarding the staff member) 

• Make a referral to the DBS where it is thought that the individual facing the allegation or concern has engaged in conduct that harmed or is likely to harm a child, or if the individual otherwise poses a risk of harm to a child

Timescales
We will deal with all allegations as quickly and effectively as possible and will endeavour to comply with the following timescales, where reasonably practicable:

• Any cases where it is clear immediately that the allegation is unsubstantiated or malicious should be resolved within 1 week 

• If the nature of an allegation does not require formal disciplinary action, appropriate action should be taken within 3 working days 

• If a disciplinary hearing is required and can be held without further investigation, this should be held within 15 working days 

However, these are objectives only and where they are not met, we will endeavour to take the required action as soon as possible thereafter. 
Specific actions
Action following a criminal investigation or prosecution
The case manager will discuss with the local authority’s designated officer whether any further action, including disciplinary action, is appropriate and, if so, how to proceed, taking into account information provided by the police and/or local authority children’s social care services.
Conclusion of a case where the allegation is substantiated
If the allegation is substantiated and the individual is dismissed or the school ceases to use their services, or the individual resigns or otherwise ceases to provide their services, the school will make a referral to the DBS for consideration of whether inclusion on the barred lists is required. 
If the individual concerned is a member of teaching staff, the school will consider whether to refer the matter to the Teaching Regulation Agency to consider prohibiting the individual from teaching.
Individuals returning to work after suspension
If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.
The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation, if they are still attending the school.
Unsubstantiated, unfounded, false or malicious reports
If a report is: 

• Determined to be unsubstantiated, unfounded, false or malicious, the DSL will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to local authority children’s social care may be appropriate

• Shown to be deliberately invented, or malicious, the school will consider whether any disciplinary action is appropriate against the individual(s) who made it

Unsubstantiated, unfounded, false or malicious allegations
If an allegation is:

• Determined to be unsubstantiated, unfounded, false or malicious, the LADO and case manager will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to local authority children’s social care may be appropriate

• Shown to be deliberately invented, or malicious, the school will consider whether any disciplinary action is appropriate against the individual(s) who made it

Confidentiality and information sharing
The school will make every effort to maintain confidentiality and guard against unwanted publicity while an allegation is being investigated or considered.
The case manager will take advice from the LADO, police and local authority children’s social care services, as appropriate, to agree:

• Who needs to know about the allegation and what information can be shared

• How to manage speculation, leaks and gossip, including how to make parents or carers of a child/children involved aware of their obligations with respect to confidentiality 

• What, if any, information can be reasonably given to the wider community to reduce speculation

• How to manage press interest if, and when, it arises

Record-keeping
The case manager will maintain clear records about any case where the allegation or concern meets the criteria above and store them on the individual’s confidential personnel file for the duration of the case. 
The records of any allegation that, following an investigation, is found to be malicious or false will be deleted from the individual’s personnel file (unless the individual consents for the records to be retained on the file).
For all other allegations (which are not found to be malicious or false), the following information will be kept on the file of the individual concerned:

• A clear and comprehensive summary of the allegation

• Details of how the allegation was followed up and resolved

• Notes of any action taken, decisions reached and the outcome 

• A declaration on whether the information will be referred to in any future reference

In these cases, the school will provide a copy to the individual, in agreement with local authority children’s social care or the police as appropriate.
We will retain all records at least until the accused individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer.
References
When providing employer references, we will:

• Not refer to any allegation that has been found to be false, unfounded, unsubstantiated or malicious, or any repeated allegations that have all been found to be false, unfounded, unsubstantiated or malicious

• Include substantiated allegations, provided that the information is factual and does not include opinions

Learning lessons
After any cases where the allegations are substantiated, the case manager will review the circumstances of the case with the LADO to determine whether there are any improvements that we can make to the school’s procedures or practice to help prevent similar events in the future. 
This will include consideration of (as applicable):

• Issues arising from the decision to suspend the member of staff

• The duration of the suspension

• Whether or not the suspension was justified 

• The use of suspension when the individual is subsequently reinstated. We will consider how future investigations of a similar nature could be carried out without suspending the individual

For all other cases, the case manager will consider the facts and determine whether any improvements can be made.
Non-recent allegations
Abuse can be reported, no matter how long ago it happened.
We will report any non-recent allegations made by a child to the LADO in line with our local authority’s procedures for dealing with non-recent allegations.
Where an adult makes an allegation to the school that they were abused as a child, we will advise the individual to report the allegation to the police.
Section 2: concerns that do not meet the harm threshold
This section applies to all concerns (including allegations) about members of staff, including supply teachers, volunteers and contractors, which do not meet the harm threshold set out in section 1 above.
Concerns may arise through, for example: 

• Suspicion

• Complaint

• Safeguarding concern or allegation from another member of staff 

• Disclosure made by a child, parent or other adult within or outside the school

• Pre-employment vetting checks 

We recognise the importance of responding to and dealing with any concerns in a timely manner to safeguard the welfare of children.
Definition of low-level concerns
The term ‘low-level’ concern is any concern – no matter how small – that an adult working in or on behalf of the school may have acted in a way that:

• Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and

• Does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the designated officer at the local authority

Examples of such behaviour could include, but are not limited to:

• Being overly friendly with children

• Having favourites

• Taking photographs of children on their mobile phone

• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door

• Humiliating students 

Sharing low-level concerns 
We recognise the importance of creating a culture of openness, trust and transparency to encourage all staff to confidentially share low-level concerns so that they can be addressed appropriately.
We will create this culture by: 

• Ensuring staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others

• Empowering staff to share any low-level concerns as per section 7.7 of this policy

• Empowering staff to self-refer 

• Addressing unprofessional behaviour and supporting the individual to correct it at an early stage

• Providing a responsive, sensitive and proportionate handling of such concerns when they are raised

• Helping to identify any weakness in the school’s safeguarding system

Responding to low-level concerns
If the concern is raised via a third party, the Manager will collect evidence where necessary by speaking:

• Directly to the person who raised the concern, unless it has been raised anonymously 

• To the individual involved and any witnesses  

The Manager will use the information collected to categorise the type of behaviour and determine any further action. The Manager will be the ultimate decision-maker in respect of all low-level concerns, though they may wish to collaborate with the DSL.  
Keeping Children Safe in Education also links to this report for more information Developing and implementing a low-level concerns policy: A guide for organisations which work with children]
Record keeping
All low-level concerns will be recorded in writing. In addition to details of the concern raised, records will include the context in which the concern arose, any action taken and the rationale for decisions and action taken. 
Records will be:

• Kept confidential, held securely and comply with the Data Protection Act 2018 and the UK GDPR

• Reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. Where a pattern of such behaviour is identified, we will decide on a course of action, either through our disciplinary procedures or, where a pattern of behaviour moves from a concern to meeting the harm threshold as described in section 1 of this appendix, we will refer it to the designated officer at the local authority 

• Retained at least until the individual leaves employment at the school 

Where a low-level concern relates to a supply teacher or contractor, we will notify the individual’s employer, so any potential patterns of inappropriate behaviour can be identified.
References 
We will not include low-level concerns in references unless:

• The concern (or group of concerns) has met the threshold for referral to the designated officer at the local authority and is found to be substantiated; and/or

• The concern (or group of concerns) relates to issues that would ordinarily be included in a reference, such as misconduct or poor performance

Appendix 4: specific safeguarding issues 
Assessing adult-involved nude and semi-nude sharing incidents
This section is based on annex A of the Department for Science, Innovation and Technology and the UK Council of Internet Safety’s advice for education settings. 
All adult-involved nude and semi-nude image sharing incidents are child sexual abuse offences and must immediately be referred to police/social care. However, as adult-involved incidents can present as child-on-child nude/semi-nude sharing, it may be difficult to initially assess adult involvement.
There are two types of common adult-involved incidents: sexually motivated incidents and financially motivated incidents.
Sexually motivated incidents
In this type of incident, an adult offender obtains nude and semi-nudes directly from a child or young person using online platforms.
To make initial contact, the offender may present as themselves or use a false identity on the platform, sometimes posing as a child or young person to encourage a response and build trust. The offender often grooms the child or young person on social media, in chatrooms or on gaming platforms, and may then move the conversation to a private messaging app or an end-to-end encrypted (E2EE) environment where a request for a nude or semi-nude is made. To encourage the child or young person to create and share nude or semi-nude, the offender may share pornography or child sexual abuse material (images of other young people), including AI-generated material.
Once a child or young person shares a nude or semi-nude, an offender may blackmail the child or young person into sending more images by threatening to release them online and/or send them to friends and family.
Potential signs of adult-involved grooming and coercion can include the child or young person being:

• Contacted by an online account that they do not know but appears to be another child or young person

• Quickly engaged in sexually explicit communications, which may include the offender sharing unsolicited images

• Moved from a public to a private/E2EE platform

• Coerced/pressured into doing sexual things, including creating nudes and semi-nudes

• Offered something of value such as money or gaming credits

• Threatened or blackmailed into carrying out further sexual activity. This may follow the child or young person initially sharing the image or the offender sharing a digitally manipulated image of the child or young person to extort ‘real’ images

Financially motivated incidents
Financially motivated sexual extortion (often known as ‘sextortion’) is an adult-involved incident in which an adult offender (or offenders) threatens to release nudes or semi-nudes of a child or young person unless they pay money or do something else to benefit them. 
Unlike other adult-involved incidents, financially motivated sexual extortion is usually carried out by offenders working in sophisticated organised crime groups (OCGs) overseas and are only motivated by profit. Adults are usually targeted by these groups too.
Offenders will often use a false identity, sometimes posing as a child or young person, or hack another young person’s account to make initial contact. To financially blackmail the child or young person, they may:

• Groom or coerce the child or young person into sending nudes or semi-nudes and financially blackmail them

• Use images that have been stolen from the child or young person taken through hacking their account

• Use digitally manipulated images, including AI-generated images, of the child or young person

The offender may demand payment or the use of the victim’s bank account for the purposes of money laundering.
Potential signs of adult-involved financially motivated sexual extortion can include the child or young person being:

• Contacted by an online account that they do not know but appears to be another child or young person. They may be contacted by a hacked account of a child or young person

• Quickly engaged in sexually explicit communications which may include the offender sharing an image first

• Moved from a public to a private/E2EE platform

• Pressured into taking nudes or semi-nudes

• Told they have been hacked and they have access to their images, personal information and contacts

• Blackmailed into sending money or sharing bank account details after sharing an image or the offender sharing hacked or digitally manipulated images of the child or young person

Children who are absent from education
A child being absent from education, particularly repeatedly, can be a warning sign of a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation, or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage. 
There are many circumstances where a child may be absent or become missing from education, but some children are particularly at risk. These include children who:

• Are at risk of harm or neglect

• Are at risk of forced marriage or FGM

• Come from Gypsy, Roma, or Traveller families

• Come from the families of service personnel

• Go missing or run away from home or care

• Are supervised by the youth justice system

• Cease to attend a school

• Come from new migrant families

We will follow our procedures for unauthorised absence and for dealing with children who are absent from education, particularly on repeat occasions, to help identify the risk of abuse, exploitation and neglect, including sexual exploitation, and to help prevent the risks of going missing in future. This includes informing the local authority if a child leaves the school without a new school being named, and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points. 
Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being absent, such as travelling to conflict zones, FGM and forced marriage. 
If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries. We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger.
Child criminal exploitation 
Child criminal exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity. It may involve an exchange for something the victim needs or wants, and/or for the financial or other advantage of the perpetrator or facilitator, and/or through violence or the threat of violence. 
The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse.
The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. For example, young people may be forced to work in cannabis factories, coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people. 
Indicators of CCE can include a child:

• Appearing with unexplained gifts or new possessions

• Associating with other young people involved in exploitation

• Suffering from changes in emotional wellbeing

• Misusing drugs and alcohol

• Going missing for periods of time or regularly coming home late

• Regularly missing school or education 

• Not taking part in education

If a member of staff suspects CCE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.
Child sexual exploitation
Child sexual exploitation (CSE) is a form of child sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity. It may involve an exchange for something the victim needs or wants and/or for the financial advantage or increased status of the perpetrator or facilitator. It may, or may not, be accompanied by violence or threats of violence.
The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse. 
The victim can be exploited even when the activity appears to be consensual. Children or young people who are being sexually exploited may not understand that they are being abused. They often trust their abuser and may be tricked into believing they are in a loving, consensual relationship. 
CSE can include both physical contact (penetrative and non-penetrative acts) and non-contact sexual activity. It can also happen online. For example, young people may be persuaded or forced to share sexually explicit images of themselves, have sexual conversations by text, or take part in sexual activities using a webcam. CSE may also occur without the victim’s immediate knowledge, for example through others copying videos or images.
In addition to the CCE indicators above, indicators of CSE can include a child:

• Having an older boyfriend or girlfriend

• Suffering from sexually transmitted infections or becoming pregnant

If a member of staff suspects CSE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate. 
Child-on-child abuse
Child-on-child abuse is when children abuse other children. This type of abuse can take place inside and outside of school. It can also take place both face-to-face and online, and can occur simultaneously between the two. 
Our school has a zero-tolerance approach to sexual violence and sexual harassment. We recognise that even if there are there no reports, that doesn’t mean that this kind of abuse isn’t happening. 
Child-on-child abuse is most likely to include, but may not be limited to:

• Bullying (including cyber-bullying, prejudice-based and discriminatory bullying)

• Abuse in intimate personal relationships between children (this is sometimes known as ‘teenage relationship abuse’) 

• Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)

• Sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence)

• Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of 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 online element)

Where children abuse their peers online, this can take the form of, for example, abusive, harassing, and misogynistic messages; the non-consensual sharing of indecent images, especially around chat groups; and the sharing of abusive images and pornography, to those who don't want to receive such content.
If staff have any concerns about child-on-child abuse, or a child makes a report to them, they will follow the procedures set out in section 7 of this policy, as appropriate. In particular, section 7.8 and 7.9 set out more detail about our school’s approach to this type of abuse.
When considering instances of harmful sexual behaviour between children, we will consider their ages and stages of development. We recognise that children displaying harmful sexual behaviour have often experienced their own abuse and trauma, and will offer them appropriate support. 
Domestic abuse 
Children can witness and be adversely affected by domestic abuse and/or violence at home where it occurs between family members. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result. 
Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse (abuse in intimate personal relationships between children) and child/adolescent to parent violence and abuse. It can be physical, sexual, financial, psychological or emotional. It can also include ill treatment that isn’t physical, as well as witnessing the ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse, including where they see, hear or experience its effects.
Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home. Children who witness domestic abuse are also victims.
Older children may also experience and/or be the perpetrators of domestic abuse and/or violence in their own personal relationships. This can include sexual harassment. 
Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children and affect their health, wellbeing, development and ability to learn.
If police are called to an incident of domestic abuse and any children in the household have experienced the incident, the police will inform the key adult in school (usually the designated safeguarding lead) before the child or children arrive at school the following day. 
The DSL will provide support according to the child’s needs and update records about their circumstances. 
Homelessness
Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare. 
The DSL will be aware of contact details and referral routes in to the local housing authority so they can raise/progress concerns at the earliest opportunity (where appropriate and in accordance with local procedures). 
Where a child has been harmed or is at risk of harm, the DSL will also make a referral to local authority children’s social care.
So-called ‘honour-based’ abuse (including FGM and forced marriage)
So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes committed to protect or defend the honour of the family and/or community, including FGM, forced marriage, and practices such as breast ironing. 
Abuse committed in this context often involves a wider network of family or community pressure and can include multiple perpetrators. 
All forms of HBA are abuse and will be handled and escalated as such. All staff will be alert to the possibility of a child being at risk of HBA or already having suffered it. If staff have a concern, they will speak to the DSL, who will activate local safeguarding procedures.
FGM
The DSL will make sure that staff have access to appropriate training to equip them to be alert to children affected by FGM or at risk of FGM.
Section 7.3 of this policy sets out the procedures to be followed if a staff member discovers that an act of FGM appears to have been carried out or suspects that a pupil is at risk of FGM.
Indicators that FGM has already occurred include:

• A pupil confiding in a professional that FGM has taken place

• A mother/family member disclosing that FGM has been carried out

• A family/pupil already being known to social services in relation to other safeguarding issues

• A girl:

• Having difficulty walking, sitting or standing, or looking uncomfortable

• Finding it hard to sit still for long periods of time (where this was not a problem previously)

• Spending longer than normal in the bathroom or toilet due to difficulties urinating

• Having frequent urinary, menstrual or stomach problems

• Avoiding physical exercise or missing PE 

• Being repeatedly absent from school, or absent for a prolonged period 

• Demonstrating increased emotional and psychological needs – for example, withdrawal or depression, or significant change in behaviour

• Being reluctant to undergo any medical examinations

• Asking for help, but not being explicit about the problem

• Talking about pain or discomfort between her legs

Potential signs that a pupil may be at risk of FGM include:

• The girl’s family having a history of practising FGM (this is the biggest risk factor to consider)

• FGM being known to be practised in the girl’s community or country of origin

• A parent or family member expressing concern that FGM may be carried out 

• A family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues

• A girl:

• Having a mother, older sibling or cousin who has undergone FGM

• Having limited level of integration within UK society

• Confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”

• Talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents/carers stating that they or a relative will take the girl out of the country for a prolonged period

• Requesting help from a teacher or another adult because she is aware or suspects that she is at immediate risk of FGM

• Talking about FGM in conversation – for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)

• Being unexpectedly absent from school

• Having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication

The above indicators and risk factors are not intended to be exhaustive.
Forced marriage
Forcing a person into marriage is a crime. A forced marriage is one entered into without the full and free consent of 1 or both parties and where violence, threats, or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. 
It is also illegal to cause a child under the age of 18 to marry, even if violence, threats or coercion are not involved.
Staff will receive training around forced marriage and the presenting symptoms. We are aware of the ‘1 chance’ rule, i.e. we may only have 1 chance to speak to the potential victim and only 1 chance to save them. 
If a member of staff suspects that a pupil is being forced into marriage, they will speak to the pupil about their concerns in a secure and private place. They will then report this to the DSL.
The DSL will:

• Speak to the pupil about the concerns in a secure and private place 

• Activate the local safeguarding procedures and refer the case to the local authority’s designated officer 

• Seek advice from the Forced Marriage Unit on 020 7008 0151 or fmu@fco.gov.uk

• Refer the pupil to an education welfare officer, pastoral tutor, learning mentor, or school counsellor, as appropriate

Preventing radicalisation

• Radicalisation refers to the process of a person legitimising support for, or use of, terrorist violence

• Extremism is the promotion or advancement of an ideology based on violence, hatred or intolerance, that aims to:

  • Negate or destroy the fundamental rights and freedoms of others; or

  • Undermine, overturn or replace the UK’s system of liberal parliamentary democracy and democratic rights; or

  • Intentionally create a permissive environment for others to achieve the results outlined in either of the above points

• Terrorism is an action that: 

• Endangers or causes serious violence to a person/people;

• Causes serious damage to property; or

• Seriously interferes or disrupts an electronic system

The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.
Schools have a duty to prevent children from becoming involved with or supporting terrorism. The DSL, or designated Prevent lead, will undertake in-depth Prevent awareness training, including on extremist and terrorist ideologies. They’ll make sure that staff have access to appropriate training to equip them to identify children at risk. 
We will assess the risk of children in our school from becoming involved with or supporting terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.
We will ensure that suitable internet filtering is in place, and equip our students to stay safe online at school and at home.
There is no single way of identifying an individual who is likely to be susceptible to radicalisation into terrorism. Radicalisation can occur quickly or over a long period. 
Staff will be alert to changes in students’ behaviour. 
The government website Educate Against Hate and the NSPCC say that signs that a pupil is being radicalised can include:

• Refusal to engage with, or becoming abusive to, peers who are different from themselves 

• Becoming susceptible to conspiracy theories and feelings of persecution 

• Changes in friendship groups and appearance 

• Rejecting activities they used to enjoy 

• Converting to a new religion 

• Isolating themselves from family and friends

• Talking as if from a scripted speech

• An unwillingness or inability to discuss their views

• A sudden disrespectful attitude towards others

• Increased levels of anger

• Increased secretiveness, especially around internet use 

• Expressions of sympathy for extremist ideologies and groups, or justification of their actions

• Accessing extremist material online, including on social media

• Possessing extremist literature

• Being in contact with extremist recruiters and joining, or seeking to join, extremist organisations 

Children who are at risk of radicalisation may have low self-esteem, or be victims of bullying or discrimination. It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong. 
If staff are concerned about a pupil, they will follow our procedures set out in section 7.5 of this policy, including discussing their concerns with the DSL. 
Staff should always take action if they are worried.
Further information on the school’s measures to prevent radicalisation are set out in other school policies and procedures.
Sexual violence and sexual harassment between children 
Sexual violence and sexual harassment can occur:

• Between 2 children of any age and sex

• Through a group of children sexually assaulting or sexually harassing a single child or group of children 

• Online and face to face (both physically and verbally) 

Sexual violence and sexual harassment exist on a continuum and may overlap.
Children who are victims of sexual violence and sexual harassment will likely find the experience distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same school. 
If a victim reports an incident, it is essential that staff make sure they are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting any form of abuse or neglect. Nor should a victim ever be made to feel ashamed for making a report. 
When supporting victims, staff will:

• Reassure victims that the law on child-on-child abuse is there to protect them, not criminalise them 

• Regularly review decisions and actions, and update policies with lessons learnt 

• Look out for potential patterns of concerning, problematic or inappropriate behaviour, and decide on a course of action where we identify any patterns 

• Consider if there are wider cultural issues within the school that enabled inappropriate behaviour to occur and whether revising policies and/or providing extra staff training could minimise the risk of it happening again 

• Remain alert to the possible challenges of detecting signs that a child has experienced sexual violence, and show sensitivity to their needs 

Some groups are potentially more at risk. Evidence shows that girls, children with SEN and/or disabilities, and lesbian, gay, bisexual or transgender (LGBT) children are at greater risk. 
Staff should be aware of the importance of: 

• Challenging inappropriate behaviours

• Making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up

• Challenging physical behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them

If staff have any concerns about sexual violence or sexual harassment, or a child makes a report to them, they will follow the procedures set out in section 7 of this policy, as appropriate. In particular, section 7.8 and 7.9 set out more detail about our school’s approach to this type of abuse.
Serious violence 
Indicators which may signal that a child is at risk from, or involved with, serious violent crime may include:

• Increased absence from school

• Change in friendships or relationships with older individuals or groups

• Significant decline in performance

• Signs of self-harm or a significant change in wellbeing

• Signs of assault or unexplained injuries

• Unexplained gifts or new possessions (this could indicate that the child has been approached by, or is involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation (see above)) 

Risk factors which increase the likelihood of involvement in serious violence include:

• Being male

• Having been frequently absent or permanently excluded from school

• Having experienced child maltreatment 

• Having been involved in offending, such as theft or robbery

Staff will be aware of these indicators and risk factors. If a member of staff has a concern about a pupil being involved in, or at risk of, serious violence, they will report this to the DSL.
Checking the identity and suitability of visitors
All visitors will be required to verify their identity to the satisfaction of staff and to leave their belongings, including their mobile phone(s), in a safe place during their visit.
If the visitor is unknown to the setting, we will check their credentials and reason for visiting before allowing them to enter the setting. Visitors should be ready to produce identification.
Visitors are expected to sign the visitors’ book and wear a visitor’s badge.
Visitors to the school who are visiting for a professional purpose, such as educational psychologists and school improvement officers, will be asked to show photo ID and:

• Will be asked to show their DBS certificate, which will be checked alongside their photo ID; or 

• The organisation sending the professional, such as the local authority or educational psychology service, will provide prior written confirmation that an appropriate level of DBS check has been carried out (if this is provided, we will not ask to see the DBS certificate) 

All other visitors, including visiting speakers, will be accompanied by a member of staff at all times. We will not invite into the school any speaker who is known to disseminate extremist views, and will carry out appropriate checks to ensure that any individual or organisation using school facilities is not seeking to disseminate extremist views or radicalise students or staff.
Missing students
Our procedures are designed to ensure that a missing child is found and returned to effective supervision as soon as possible. If a child goes missing, we will inform parents and carers and the school responsible for that child.