1.1 Safeguarding at NCG: an Overview

1.1 Safeguarding at NCG: An Overview

This document provides detailed information regarding the college’s responsibilities and procedures in relation to welfare and safeguarding. Other useful associated policies are; the Complaints Procedure, the Health& Safety Policy, the Bullying & Harassment Policy, and the Disability Policy: all of which are available on the website.

To ensure the policy is up to date with current legislation, it will be reviewed quarterly by the Lead Safeguarding Officer and the Director of Quality Assurance. The Lead Safeguarding Officer will also make any amendments necessary in between official reviews. To ensure accurate and up to date records are maintained, all are monitored on a monthly basis by the Safeguarding Lead, or other nominated person in their absence.

1.2 The Difference between Welfare & Safeguarding

The line between welfare and safeguarding is very fine and what may appear to be a welfare issue could easily develop into, or be the signs of a safeguarding issue. As explained below, safeguarding specifically relates to a child or vulnerable adult suffering abuse at the hands of another person. Whilst it is easy to identify a child, it is not so clear who is considered a vulnerable adult. According to the Lord Chancellor’s Department (1997) a vulnerable adult is defined as thus…

“An adult who is or may be in need of community care services by reason of disability, age or illness; and is or may be unable to take care of unable to protect him or herself against significant harm or exploitation”

As any one of our students may have health issues, mental health problems or a disability; concerns about any person, whether they are under or over 18, fall under the scope of this policy.

1.3 Definitions of Safeguarding, Welfare & Abuse

According to the Care Quality Council, Safeguarding means:

“Protecting people’s health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect”.

It is this definition which forms the basis of our policy and procedures. We do not use the term Child Protection, due to the majority of our students being over the age of 18, and as such, the term Child Protection has less meaning for our staff and students than does Safeguarding.

For the purpose of this document the following definitions apply:

Welfare means the general care and support of staff or students at NCG.

Safeguarding means the active prevention and protection against the abuse of any person or persons under 18, or who are considered to be a vulnerable adult, who work or study at NCG.

Abuse means a violation of an individual’s human and civil rights by other 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 vulnerable person 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:

• Physical abuse: including hitting, pushing, kicking, misuse of restraint or inappropriate sanctions.
• Sexual abuse: including sexual assault or acts to which the adult did not, or could not consent.
• Psychological abuse: including emotional abuse, bullying, threats, deprivation of contact, humiliation, intimidation, coercion, verbal abuse.
• Financial or material abuse: including fraud or damage to property.
• Neglect or acts of omission: including ignoring medical or physical care needs, inadequate nutrition and failure to provide appropriate health, social or educational services.
• Discriminatory abuse: including racism, sexism and other forms of harassment.
• E-abuse via the internet, or other e-technologies.

1.4Statement of Intent

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), and vulnerable adults.

As such, NCG will ensure that the service they provide...

• is accessible, well publicised, ensures confidentiality and is available in an environment that is sensitive to the needs of adults at risk and children.
• takes account of the views of children, young people, and adult service users, in the decisions about and delivery of services.
• ensures that racial heritage, language, religious beliefs, sexuality, gender and disability is taken into account - for example by the use of interpreters or by making adjustments to enable access for disabled people.
• prohibits any reference to, or promotion of, radicalisation.
• takes into account the service user's wishes and feelings and balances this against their rights and need to be safeguarded.
• considers if there are risks from any form of abuse; mental health problems; misusing drugs and alcohol; or a risk of homelessness.

1.5 Key People

NCGhas two sites, the main building is Murray House, 85 Piccadilly, Manchester M1 2DA and the second site is on the 1st & 2nd floors of 40 Fountain Street, Manchester, M2 2BE. The safeguarding team comprises of two members of staff: John Mandy at Fountain Street, who is also responsible for DBS checksand the Lead Safeguarding Officer is Charlotte Kerns,who is based at Murray House and is responsible for the policy, overall decisions and training. Theywill ensure communication between themselves takes place whenever a concern is raised, so that all are aware of any issues and actions currently in progress.

• Charlotte Kerns: +44 (0)161 233 4290 ext: 221.

• John Mandy: +44 (0)161 233 4290 ext 224

1.6 Staff Responsibilities

NCG will ensure that all staff working with children, young people and vulnerable adults will...

• give the highest priority to the welfare of every person at NCG.
• recognise, identify and respond to safeguarding concerns.
• respond appropriately to a disclosure of abuse.
• respond appropriately to allegations against staff, other adults, or themselves.
• act appropriately and understand safe practice in carrying out their duties.
• be alert to the risks which abusers, or potential abusers, may pose.
• be aware of the importance of the role of promoting the welfare of all its studentsand attend safeguarding training.
• contribute as necessary to all stages of NCG’s safeguarding and protection processes.

• abide by the Staff Code of Conduct, as stipulated in the Staff Handbook and their contract of employment.

Section 2

Preventative Measures

2.1 Safer Staffing

NCG operates rigorous recruitment practices across all departments with the aim that all its employees are safe to work with under 18s and vulnerable adults: this includes host families and contract workers. Our Safer Recruitment Practices include:

• DBS checks for all employees; including host families who provide accommodation to under 18s and external contractors. If a new employee does not have a DBS certificate and the college deems it necessary for them to start employment prior to clearance they will be asked to complete a declaration that they, or a person they have a close relationship with, is not barred from working with children or vulnerable adults. In addition to this, a pre-employment risk assessment will be carried out (See Appendix...). Under no circumstances will any person be allowed to carry out a role that falls underRegulated Activity, prior to being cleared by the DBS. (See page 17 of Keeping Children Safe in Education, Department of Education 2014 for a definition of Regulated Activity).
• Proof of identity, eligibility to work in the UK and qualifications.
• At least two referees: confirmation of the appointment is conditional to references being satisfactory.
• All the staff are asked to read, and sign to say they have read this policy and the Staff Handbook when inducted.
• If a person does declare an offence, the nature and severity of this will be risk assessed, and a decision made as to whether or not they will still be employed will be taken by the Senior Management Team (See Appendix...).
• If a DBS check is not clear, in relation to working with under 18s or vulnerable adults, the person will not be employed by the college.
• The DBS will be informed immediately if any employee demonstrates they pose a risk to under 18s or vulnerable adults.
• All DBS records are kept on a central electronic register; that is accessed only by the key people involved in safeguarding, the Principal, the HR Officer, and the Managing Director.

2.2 Appropriate Staff & Student Relationships

Staff should bear in mind that many students may form attachments to staff due to various reasons, for example, feeling lonely; however, they may misinterpret attention outside of working hours or sharing personal contact details as being more than just a professional relationship and as such it is not advisable. Staff should not socialise with students and no personal emails or telephone numbers of staff should be shared with students; if a student requests this, then work contact details should be given. Likewise, requests from students for a member of staff to befriend them on Facebook, or any other social media site, should be politely refused and the student directed to the college’s Facebook page. It may be difficult at times to refuse a student, but it should be clearly explained that this is college policy.

2.3 Internet Safety

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.

In response to this, the college has put in place the following guidelines to advise on the safe use of e-technology. As the area is very specific, it is deemed to be encompassed by the Safeguarding Policy, but warrants a dedicated section within this policy. It may also fall under the realm of bullying and harassment and so staff should refer to the Bullying & Harassment Policy as is deemed appropriate; which is available on the N-Drive, in the Policies folder, or on the college website which can be accessed via the following link:

What do we mean by e-safety?

E-safety refers to, the safe use of mobile phones (including texting), tablets, PCs, laptops and the internet (including email, apps & downloads/uploads); so that a person is not at risk from others or a risk to others through use any of the above.

What are the risks?

The use of technology gives everyone easy access to another person. Whilst this is generally a positive thing, it can also pose great risks to people in the form of...

• Cyber-bullying: The use of mobile phones, email, social media or blogs to intimidate, verbally & emotionally abuse another person over a sustained period of time. This is anything that makes a person feel threatened or upset. For example, calling people names, making them feel stupid, using abusive language with them, or being consistently rude.
• Inappropriate images: By inappropriate we mean any image that is of a sexual nature or that has been taken to be used in a sexual manner. This could be in the form of accessing (and distributing) pornographic material, sending sexual images via email, texts, apps or social media that are offensive. It can also mean taking a picture or video of someone, without their permission, and distributing this via e-technology. It also includes taking sexual images of yourself and sending them to other people.
• Inappropriate sexual messaging: This is a message with a sexual content that is sent via any of the following methods, email, social media, blogs, apps or texting. This could be telling someone they are beautiful or sexy, but is unwanted by the person receiving the communication.
• Racial or discriminatory abuse: By this we mean any abuse via e-technology that is related to race, sexual orientation, gender, age, ethnic background, religious beliefs or lifestyle choice.
• Access for sexual predators, to children, young people or vulnerable adults: E-technology provides the perfect forum for sexual predators as they can remain anonymous and hide their true intent for as long as the feel is necessary to win the trust of somebody. They may lie about their age or gender, and befriend someone for a long time before the reveal they are interested sexually. The risk of this is incredibly high and is commonly referred to as grooming; that is the process of building up trust with a young or vulnerable person with the intent of sexually abusing them, either virtually or physically. By sexual abuse, we mean the act of unwanted sexual attention; this can range from; sending images or videos of masturbation or nudity, touching someone in a way that they do not want, forcing someone to touch you in a sexual way or to send sexual content to them, to rape.

Safer Browsing

The college has in place a web filtering system to help prevent inappropriate e-behaviour that blocks websites which contain the following terms:

Alcohol & Tobacco Criminal Activity Gambling Sexual Images

Hate & Intolerance Illegal Drugs Nudity Child Abuse

Porn Sexual Violence Weapons

School CheatingSex Education Tasteless

This is effective when connected to the internet via any means, and any technology, whilst using the college’s networks. It is applicable to staff and students, and the usage is monitored by the IT company contracted by the college: Comms-Byte,.

Inappropriate use of technology

The college deems the following to be inappropriate use of technology to be:

• Searching for anything on the internet containing the filtered terms.
• The giving out personal emails or telephone numbers by staff without informing their line manager. (At times this may be necessary, for example if the work mobile is not working on a social trip).
• Communication of an intimate nature between staff and students, or staff and staff via any technological media.
• The posting of any abusive or sexually inappropriate material/images/audio on any website, messaging media, blogs or forums.
• Taking photos or videos of people without their permission.
• Posting images of people on sites, blogs, forums etc, even if the photo or image was taken with permission.
• Giving a third party the contact details for a person without their permission; this includes work emails.

In addition to the web filter, the college’s Facebook page is monitored by the Communications Officer and any inappropriate messaging or materials are blocked before they are publicly posted.

2.4 Safeguarding Training

All staff receive online safeguarding training to at least Level 1, which includes e-safety and inappropriate use of technology. The online training is renewed every 3 years for all staff and every 2 years for the safeguarding officers, lead and senior management team. In addition to this, the college provides in-house training sessions to all staff, host families and senior management on an annual basis. A register of who has completed in-house training is stored in the safeguarding folder on the N-Drive and the online register can be accessed by the safeguarding lead at: both are monitored on a monthly basis by the Safeguarding Lead and the HR Officer.

For students, the induction presentation includes a section on staying safe and appropriate behaviour; including, who to speak to if they have a concern. The Student Handbook, and posters in all classrooms detail the college’s Code of Conduct and Behavioural Policy for students. Students are also required to sign to say they have read this and agree to adhere to it prior to starting their course.

Section 3

Care of the

Under 18’s

As an adult college we take the care of students under 18 very seriously and we do our upmost to minimise the risk to the growing number of this group of students. As such we have dedicated procedures as outlined below in caring for students who are under 18.

3.1 Pre-Arrival Information & Documentation (Needs to be revised for Under 18s)

The care of our younger students begins prior to their arrival in the UK and consists of providing them and their parents/guardians with a Pre-Arrival Pack containing the following.

• A named contact.
• Detailed information about what to expect during their stay, both in and outside of college.
• Details of their accommodation and their host family.
• A summary of safeguarding at NCG & information about staying safe in the city.
• A comprehensive Parental AgreementFormthat allows parents/guardians to stipulate what their child/children are allowed to do out of college hours;our code of conduct, and rules for under 18s and Disciplinary Procedure.
• Arrival information.
• Information we require, such as mobile number, medical problems or dietary requirements.
• Information about the college.

3.2 Arrival & First Day Procedures

Unless it has been previously agreed and expressly confirmed between the student’s guardian and NCG, all under 18’s will be met at the airport by a DBS checked driver from Stallion Travel at the Information Desk. The driver will have a sign with the student’s name clearly stated on it.

After being collected by the driver, the student is then driven to their accommodation to be met by their NCG DBS checked host or own pre-arranged accommodation guardian.