NCG has a duty and responsibility to ensure that everyone that comes into the organisation is safe and that all staff are aware of methods to ensure a safe environment for colleagues and students alike; in particular children (referred to as Under 18s). All adults associated with under 18s have a responsibility to safeguard them. This policy outlines safeguarding responsibilities and actions to be taken in the event of a concern.
NCG will ensure that the service they provide:
To ensure the policy is up to date with current legislation, it will be reviewed annually by the Designated Leads. The Designated Leads will also make any necessary amendments in between official reviews. To ensure accurate and up to date records are maintained, all are monitored on a regular basis by the Designated Leads.
For the purpose of this document and for rules and procedures in the school, there are two main classifications of non-adult students; under 18s (16-17) who are treated in some respects as adults and allowed to attend adult classes, and juniors aged 12-17 who cannot join adult classes and for whom restrictions are more stringent. For juniors under 16 they are further sub-classified into 14-15 year olds and 12-13 year olds.
This is the full safeguarding policy. There are also summary safeguarding information pages or presentations for the following groups:
NCG has two year round colleges, one in Manchester and one in Liverpool. NCG also has two UK summer schools in Manchester and Portsmouth. The following structure is applicable across the group and contact details of the key people can be found on the following page.
Designated Safeguarding Lead (DSL) – The DSL has overall responsibility for safeguarding at the college. They are the lead person in making decisions, writing policies and enforcing procedures. They provide advice and support to students and colleagues.
Deputy Safeguarding Lead – The deputy lead stands in for the DSL when they are unavailable or if a concern relates to the DSL.
Designated Safeguarding Officer (DSO) – The DSO works with the Designated Lead in dealing with concerns and ensuring procedures are adhered to. They provide advice and support to students and colleagues.
Welfare Officer – The Welfare Officer provides front line support to students with welfare issues. Welfare issues can affect adults or students under the age of 18. The Welfare Officer also provides advice and support to colleagues.
Key People:
| NCG Manchester | |
| Contact Details | 9 Portland St
Manchester M1 3BE Tel: +44 (0)161 233 4290 |
| Designated Safeguarding Lead | Alba Perez |
| Deputy
Safeguarding Lead |
Helen Reed
hreed@newcollegegroup.com |
| Safeguarding & Welfare Officer | Carleton Lincoln
clincoln@newcollegegroup.com |
| NCG Liverpool | |
| Contact Details | Merchants Court, 1st Floor
2-12 Lord Street Liverpool L2 1TS Tel: +44 (0)151 236 2749 |
| Designated SafeguardingLead | Kerill Kennedy |
| Deputy Lead & Safeguarding Officer | Christine Flanagan |
| Safeguarding & Welfare Officer | Melissa Cowley |
| NCG Summer Schools | |
| Contact Details | 9 Portland St
Manchester M1 3BE Tel: +44 (0)161 233 4290 |
| Designated Safeguarding Lead | Peter Dean |
| Deputy
Safeguarding Lead |
Lee Hawkes
lhawkes@newcollegegroup.com |
| Safeguarding Officer | On-site Centre Manager |
| Safeguarding & Welfare Officer | On-site Welfare Officer |
The Difference between Safeguarding, Child Protection & Welfare
The term Safeguarding refers to the policies and procedures put in place by the college to keep children safe and promote their wellbeing. Child Protection is a related term, but it refers to activity that is undertaken to protect specific children who are suffering or are likely to suffer significant harm. Welfare is a broader term which can involve supporting students with any social, financial or emotional problems and can be applied to adults and students under 18.
For the purpose of this document the following definitions apply:
Safeguarding means the active prevention and protection against the abuse of any person or persons under 18, who work or study at New College Group.
Abuse means a violation of an individual’s human and civil rights by another person or persons. Abuse may consist of single or repeated acts. It may be physical, verbal or psychological, it may be an act of neglect or omission to act, or it may occur when a child is persuaded to enter into a financial or sexual transaction to which he or she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. Within this context abuse can take the form of:
All staff are responsible for safeguarding students under the age of 18 whilst they are on NCG premises, or off-premises with students on an organised trip or conducting an NCG activity. NCG has a duty of care to safeguard under 18 students at all times whilst they are studying with NCG and it is the safeguarding team’s responsibility to oversee their safety. This code of conduct aims to build trust between under 18s and adults to promote a safe culture in the college. Adults are expected to be excellent role models for under 18s by dressing and behaving appropriately, using appropriate language and challenging inappropriate behaviour. Adults in the college are in a position of trust, so under the Sexual Offences Act of 2003 any sexual activity with a student under the age of 18 is against the law.
Staff should bear in mind that many students may form personal attachments to them, for various reasons; for example, feeling lonely or homesick. These attachments are understandable. However, students may misinterpret attention outside of working hours or sharing personal contact details as being more than just a professional relationship so it should be avoided. Staff must adhere to the following in terms of their interaction with students.
It may be difficult at times to refuse a student, but it should be clearly explained that this is college policy.
For staff to be aware and keep track of students who are under 18, the following measures are in place.
Adults must present themselves appropriately as they are role models for our under 18 students.
Adults must be positive role models and their behaviour is likely to be closely observed regarding these areas by students under 18.
NCG has a duty and responsibility to ensure that everyone that comes into the organisation is safe and that staff are all aware of methods to ensure a safe environment for colleagues and students alike, in particular children and vulnerable adults. As the use of technology is part of daily life, it is important that both staff and students have an awareness of using this safely, both inside and outside the college environment. If a student is concerned about bullying or other online behaviour, they should speak to a member of the safeguarding and welfare team.
A simplified version of this policy is available for host families. The following guidance should be observed in both homestay and residential accommodation.
Any suppliers contracted for services to transport students under the age of 18 must demonstrate that they have a safeguarding or child protection policy in place with safer recruitment procedures.
All staff have a duty of care to safeguard our students under the age of 18. Staff have a legal obligation to report any colleagues breaking the code of conduct. They should report any concerns to the Designated Safeguarding Lead (DSL), or to the Deputy Safeguarding Lead if the concern relates to the DSL or the DSL is not available.
NCG has a duty of care for all students under the age of 18 studying at the college. All adults have a responsibility to report any concerns they have to a member of the safeguarding team. At least one of the key people is available at all times, 24/7.
Staff should be aware that the following could be signs that a child is at risk of, or is being abused and they should report these immediately to the Safeguarding Team. As the signs may apply to different forms of abuse, they have not been related to any particular type, but noticing any should be an immediate cause for concern. The list is not exhaustive, and if any staff have concerns, they should follow the reporting procedures.
Physical Signs
Psychological & Behavioural Signs
Specific Areas
In addition to the types of abuse mentioned above, four other specific types of abuse that staff must be aware of are Child Sexual Exploitation (CSE) and Female Genital Mutilation (FGM), Child-on-Child Abuse (which includes bullying, cyberbullying, sexual violence and sexual harassment), and Honour-based Violence (HBV).
Child Sexual Exploitation
This is a form of sexual abuse where under-18s are exploited to engage in sexual activity in return for money, gifts, drugs, affection or status. CSE does not always involve physical contact as it can happen online or involve pressure from peers or cyber bullying.
Signs to look for in under-18s include:
Female Genital Mutilation (FGM)
This is a practice that can cause severe and long-lasting damage to physical and mental health. It is carried out for religious, social or cultural reasons, however there are no medical reasons for carrying it out. It is a criminal offence if done in the UK. Staff should be aware that a person who has suffered FGM may ask for help without being explicit about the problem due to embarrassment or fear. Any causes for concern are to be reported to the DSL. Any suspected case of FGM must be reported to the police.
Child-on-child Abuse
It should be remembered that abuse does not only come from adults, but can come from other children. Peer-on-peer abuse can include bullying (including cyberbullying), sexual violence and sexual harassment.
Cyberbullying
Cyberbullying is bullying that takes place over digital devices such as mobile phones, computers, and tablets. It can occur through text, and apps, or online in social media, forums, or gaming where people can view, participate in, or share content. Cyberbullying includes sending, posting, or sharing negative, harmful, false, or mean content about someone else causing embarrassment or humiliation. Some cyberbullying crosses the line into unlawful or criminal behaviour.
The most common places where cyberbullying occurs are:
Signs to look out for in under-18s include:
Sexual violence and sexual harassment
Sexual violence is defined as any sexual act or attempt to obtain a sexual act by violence or coercion, acts to traffic a person or acts directed against a person’s sexuality, regardless of the relationship to the victim. Sexual harassment is unwanted conduct of a sexual nature that can occur online and offline. It can include, but is not limited to:
This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include:
Some people might try to excuse mild transgressions as a “joke” or “teenage fun”. However, all forms of sexual violence are unacceptable. It should also be noted that both perpetrators and victims can be either male or female.
This is coercion or violence used against a person in the belief that family or tribal honour requires action. A person can be seriously injured or even killed in extreme cases. Signs to look out for include:
Should any person within the organisation suspect that a welfare or safeguarding issue has arisen, they must inform one of the Safeguarding Team as close to the event as possible, and no later than 24 hours after they first become concerned.
Following any reported concern, the officer informed should immediately pass on these concerns to their counterparts so that a decision can be made as to what action should be taken. In the case of a serious concern being raised, immediate risk of harm, or an allegation of abuse by a staff member or a fellow student, the local authority safeguarding or child protection board and/or Police must be informed immediately.
Only the Designated Lead, (or deputy in their absence), will make an external referral.
Handling a Disclosure of Abuse & Ensuring Confidentiality
If you are approached by a student wanting to talk you should:
It is imperative that what is said, is documented as accurately as possible, and that leading questions are not used as these may render the documentation inadmissible should legal action be taken. By leading questions, we mean direct questions that are asking if someone did something specific.
For example:
Did X touch you here?
Did you feel upset?
Instead, ask open questions like:
Can you tell me what happened?
How did this make you feel?
This allows the person to tell things in their own words, without being led by another person’s assumptions about what happened or might have happened. This should be documented using, as closely as possible, the words of the young person or vulnerable adult. This must be documented on a Welfare/Safeguarding Record of Concern Form; available on the N-Drive in Shared Documents folder then going to Forms/Compliance/Safeguarding or in the Staff Information folder on the Google shared drive. The completed form should be emailed to the Designated Lead and will be saved with the student ID number in a Google Shared folder which is only accessible by the safeguarding team.
Once it has been established that there is a safeguarding or welfare issue, the following actions should be taken. The persons involved should be contacted, and if necessary removed from an unsafe situation immediately. A meeting between the student concerned and one of the Safeguarding & Welfare Team should take place within 24 hours of it being reported. The student’s parents will be contacted by a member of the team to inform them of the situation.
Once it has been established that there is a safeguarding or welfare issue, the following actions should be taken. The student and their family should be offered immediate and then regular support by a member of the team. If the support required is outside the college’s remit, support from external agencies will be sought. The officer involved will act as a point of contact for the student, their family and any outside support agencies that the student has been referred to.
Any staff who have concerns about a colleague, or a student, being a perpetrator of abuse must report them to the Designated Lead. The reporting member of staff will be protected as a whistle blower and should not feel concerned about making an allegation. Confidentiality must be maintained at all times. Any breach of this could result in disciplinary action.
In cases where a member of staff or another student has been accused of some form of abuse, the utmost should be done to keep this allegation confidential until it has been fully investigated. Upon receipt of a Record of Concern Form , naming a staff member or a student as a possible abuser, the Designated Lead will contact the local authorities immediately. Two possible courses of action may be taken following consultation with the local authority, and in line with their recommendations.
Whilst an investigation is being carried out, support will be offered to any person against whom an allegation has been made. If the allegation is against a student, they will be supported internally by a member of the Safeguarding Team, and external support will be signposted. Where a staff member has been accused, they will be referred to the HR Officer, who will arrange for them to receive support.
If the allegation is proved to be true, the member of staff or student will be removed permanently from the college. In the case of a visa student their embassy and UKVI will be informed of the offence immediately. In the case of a staff member, the DBS will be informed, as per the law.
If the allegations are proved to be unfounded, this will be clearly documented on the records. All records will be kept, as per Government recommendations, in a password protected folder.
Summaries of the Safeguarding procedures can be seen on the following pages. All procedures are in line with those recommended by:
Manchester Safeguarding Partnership (https://www.manchestersafeguardingpartnership.co.uk/)
Liverpool Safeguarding Children Partnership (https://liverpoolscb.org.uk/scp)
Salford Safeguarding Children Partnership (https://safeguardingchildren.salford.gov.uk/)
All staff must complete basic safeguarding training (level 1). This can be NCG developed safeguarding training online or by qualified staff face to face. Alternatively, online training developed by the British Council is available. The British Council training can be found here:
https://accreditation-uk.english.britishcouncil.org/
It is the responsibility of the HR Officer to ensure that level 1 training is completed by all staff.
It is recommended that our homestay hosts also complete safeguarding training, which is the responsibility of the Student Support Team.
All staff involved in accommodation or student welfare need to complete an advanced safeguarding course (level 2) in the UK or Children First Child Protection Training in Ireland within six months of starting with NCG. Advanced safeguarding training must be renewed every two years.
At least two staff in each UK centre must be trained to be the safeguarding lead (level 3). They should be in leadership positions and able to make decisions if an incident occurs. Advanced Training for Designated Lead must be renewed every two years.
NCG operates rigorous recruitment practices across all departments with the aim that all its employees are safe to work with under 18s. Our recruitment practices can be found in the Safer Recruitment Policy, and information pertaining to all staff can be found on the Single Central Register; which is maintained by the HR Officer.
All job advertisements state the school’s commitment to safeguarding and the promotion of student welfare for under 18s. All stakeholders are expected to share this commitment. It is made clear that a DBS check will be carried out, there should be no gaps in work or educational history that cannot be explained, and that references will be checked.
All applicants are informed before their interview that we will follow up references, we require a DBS disclosure or overseas police check, all gaps in work or educational history must be accounted for, and proof of identity and qualifications will be required.
In cases where a DBS or police check has not been returned before the applicant commences work, certain procedures must be put into place. When the applicant is a teacher there are several measures in place to allow the teacher to start work: the DoS monitors the room where the teacher is working at least once each lesson, the teacher is required to teach with the door open, he or she should not be alone with one or two students at any time, he or she cannot teach 1:1 or 2:1 classes to students under 18 years old.
Staff members for all positions may be able to work but cannot supervise students under 18 years old without the presence of a vetted staff member until such time that the vetting is complete.
This section of the policy details the way NCG colleges look after students under 18 and the measures in place to ensure their safety and wellbeing.
The care of our students begins prior to their arrival in the UK/Ireland and consists of providing them and their parents/guardians with a Student Handbook containing the following:
Unless it has been previously agreed and expressly confirmed between the student’s guardian and New College Group, all students will be met at the airport by a vetted coach/taxi driver or member of NCG staff at the Information Desk. After meeting the driver, the students are then driven to their accommodation.
Students will have an induction by a member of the NCG team, which includes information about what they need to do while they are at the college, how to keep themselves safe both on and off campus, and where they can get support during their stay. They will also be shown where to find information in the student app, which includes the information provided in the induction and a section on staying safe and appropriate behaviour. They will be given an identity card which has the 24 hour emergency number printed on (also available in the app).
Risk assessments are used to assess risk for specific activities or locations. They are used to set out preventative measures, minimising risk and promoting safety.
In residential accommodation, there will be at least 1 adult for every 15 students if there are under 16s staying there. If there are only 16-17 year olds staying there, the supervision ratio is 1:20. There should always be a minimum of two adults.
In order to balance the minimising of risk, while ensuring that students get the full benefit of being in the UK, some under 18s will be allowed unsupervised time on activities and trips depending on the results of the risk assessment and their age. The risk assessment will decide which category of risk the trip falls under:
Class A– The location is deemed very risky such as a visit to a major metropolitan area such as London. For class A all under 18s must be supervised throughout.
Class B– The location is deemed of moderate risk such as a small town/city with little pedestrian traffic, low crime and/or with which students and staff are already familiar. For class B, 16-17 year olds can be unsupervised for up to 1 hour. Younger students must be supervised throughout.
Class C– The location is deemed of low risk. For example, inside a museum where there is only one normal entrance/exit and CCTV throughout the building. For class C, 16-17 year olds can be unsupervised for up to 1.5 hours and 14-15 year olds can be unsupervised for up to 30 minutes. Students of 12-13 years of age, (or younger if this ever becomes applicable), can never be left unsupervised.
If a trip/activity includes a location that falls under a lower level of risk (for example they visit a museum in London) then they may be unsupervised for their time at this location for the requisite length of time. In any unsupervised time, students will be told to stay in pairs or small groups.
The following procedures should be followed if a student is missing.
| Scenario | Action |
| Student is missing from class
(16-17 year old on adult course) |
If 20 minutes after the start of class an under 18 student is not present, staff should call the student to enquire about their welfare. If they cannot be contacted, staff should go to their residence room or call their host family. These actions should be repeated until staff have spoken to the student. If the student has still not been contacted by 4pm, they should be reported missing to the police. |
| Student is missing from class
(12-17 year old on junior course) |
If 15 minutes after the start of class an under 18 student is not present, the teacher should report the student missing to the Centre Manager, Academic Manager or Student Support Team. If they cannot be contacted, staff should go to their residence room or call their host family. These actions should be repeated until staff have spoken to the student. If the student has still not been contacted by 12pm, they should be reported missing to the police. |
| Student is missing on activity | Activity leader should try to contact the student by phone. After repeated attempts for 20 minutes, they should inform the member of staff with the emergency phone. If the student still cannot be contacted after 1 hour, they should be reported missing to the police. |
| Student does not return for curfew | Host or residence staff should attempt to contact the student. If they cannot be contacted after 30 minutes, they should inform the member of staff on the emergency phone. If the student still cannot be contacted after 1 hour, they should be reported missing to the police. |
| Student is missing from online class (when student is in home country and under parental supervision) | Parent/guardian is informed of the student’s non-attendance. |
Other Provisions
The following policies outline other systems that may be relevant to safeguarding under 18s as well as other students: