At Pathway we are dedicated to Safeguarding our staff and learners. Please feel free to read through and if you would like more information about this policy or Pathway Group please feel free to get in touch.
Pathway Groupputting you first
1. Statement of Intent .....................................................................................................................1
2. Introduction.................................................................................................................................. 1
3. Relevant Governmant Legislation and Key Guidance Reference Points ..................2
3.1 Safeguarding Vulnerable Groups Act 2006.......................................................................2
3.2 The Children Act 2004......................................................................................................... 2
3.2 Education Act 2011..................................................................................................... 2
3.3 Human Rights Act 1998...................................................................................................... 2
3.4 Rehabilitation of Offenders Act 1974....................................................................... 2
3.5 Every Child Matters (Department for Education) 2003.......................................... 2
3.5.1 Common Assessment Framework .........................................................................3
3.6 Working Together to Safeguard Children 2010 ...................................................... 3
3.7 Safeguarding Children and Safer Recruitment 2007 ............................................. 3
4. Overview of Pathway Group’s Safeguarding Policy Implementation .................... 3
5. Designated Responsible Safeguarding officer ......................................................... 4
5.1 Responsibilities .......................................................................................................... 4
5.2 Roles and Structure .................................................................................................... 6
5.2.2 Designated Director ................................................................................................ 6
5.2.3 Designated Safeguarding Officer(s)....................................................................... 6
5.3 Key Definitions ............................................................................................................ 7
5.4 Recognising Abuse – General Considerations................................................................12
5.5 What Safeguarding Legislation States about Children................................................13
5.6 Significant Harm .......................................................................................................................14
5.7 Recording, Sharing of Information and Consent Issues ............................................ 16
5.8 Employer Agreement ............................................................................................................. 19
5.9 Monitoring and Evaluation .................................................................................................. 21
5.10 Key Contacts & Referral Agencies ................................................................................... 22
Appendix A........................................................................................................................................ 24
Appendix B .........................................................................................................................................25
14 October 2014
Pathway Group Safeguarding Policy
This policy should read in conjunction with the following policies:
• Health and Safety Policy
• Equality and Diversity Policy
• E-Safety Policy
• Lone Working Policy
• Harassment Policy
• Grievance and Discipline policy
• Complaints Policy
• Whistleblowing Policy
1. Statement of Intent
Pathway First Ltd. (operating as Pathway Group) fully recognises and takes seriously
its responsibilities on safeguarding its stakeholders including safeguarding children,
young people and vulnerable adults. This policy document is intended to publicly
communicate the levels of responsibility of Pathway Group within its own premises
and also other locations and as a guide for staff, learners and partner organisations.
The policy includes and is not limited to:
• Pathway Group stakeholders including all young people aged 13-18 and
vulnerable adults (including people who have any disability or learning
• Employers who take on our learners on apprenticeship programmes or work
Subcontractors/Associates that engage with our staff or learners on behalf of
Pathway e.g. assessors, trainers, advisors etc.
The policy is based on the requirements of government legislation and regulations
and our interpretation of national best practice.
This policy and subsequent practices are in line with the Governments Prevent
Strategy. Pathway Group Staff have been trained through the safeguarding
procedures to be vigilant and identify any signs or actions that could lead to any
exploitation or radicalisation of individuals or groups.
The policy is the focal point for ensuring the well-being of all learners, stakeholders
and staff especially from the following:
• Forced Marriages
• Female Genital Mutilation
• Sex Exploitation
The aim of this policy is to explain Pathway Group’s role in the safeguarding and
protection of children, young people and vulnerable adults and how we will promote
their welfare. The purpose is to bring about better outcomes for our stakeholders by
3. Relevant Government Legislation and Key Guidance Reference Points
3.1 Safeguarding Vulnerable Groups Act 2006
This Act restricts contact between children and vulnerable adults and those who
might do them harm.The barring aspects of the Act came into force in October 2009.
Further adjustments were made to the act in 2012
3.2 The Children Act 2004
This Act provides information about local safeguarding children boards in this area.
It identifies child safety orders and arrangements to safeguard and promote welfare
of children. Context for this act was provided in the Every Child Matters (Department
for Education) 2003.
3.2 Education Act 2011
This Act briefly highlights amongst other things, provides guidance on critical
safeguarding requirements of staff and wider guidance on what is expected from the
education sector in terms of safeguarding duties.
3.3 Human Rights Act 1998
This Act came into force in 2000; it prohibits inhumane treatment and degrading of
vulnerable adults. In the interest of maintaining public safety, this includes measures
• Right to respect for private & family life, home & correspondence
• Freedom of assembly and association
• Freedom of thought, conscience and religion
3.4 Rehabilitation of Offenders Act 1974 (Exceptions - Order 1975 as amended):
This Act requires disclosure of cautions and convictions including‘spent’convictions
where employment involves children or vulnerable adults.
3.5 Every Child Matters (Department for Education) 2003
and defined five key principles for safeguarding and supporting children:
• Stay Safe
• Enjoy and Achieve
• Economic Well-being
3.5.1 Common Assessment Framework
This framework seeks to ensure an inter-agency approach as a key part of
assessment and delivering frontline services that are integrated and focused around
the needs of children and young people including implementing the aims and
objectives of Every Child Matters.
3.6 Working Together to Safeguard Children 2010
Working Together sets out how organisations and individuals should work together
to safeguard and promote the welfare of children and young people in accordance
with the Children Act 2004.
3.7 Safeguarding Children and Safer Recruitment 2007
This is statutory guidance from the Department for Education which sets out the
responsibilities of all local authorities, schools and Further Education (FE) colleges in
England to safeguard and promote the welfare of children and young people.
4. Overview of Pathway Group’s Safeguarding Policy Implementation
This policy document and its contents are not intended to be exclusive or
comprehensively authoritative on safeguarding issues; moreover it is a guide for
Pathway Group staff, learners and their employers and placement providers to
follow and / or consult when training and working with learners.
All staff working with young people and vulnerable adults must be able to identify
when a young person may be likely to suffer significant harm through abuse or
neglect and how to act upon concerns by referring them to the local Safeguarding
Children Board or Safeguarding Adults Board.
All Pathway Group employees and managers and employees of agencies working
with the Pathway Group should be aware of internal arrangements consistent with
the child and vulnerable adults’protection procedures (Appendix B), and the roles
of key staff within the organisation
The main elements to our policy are:
• Ensuring we practice safe recruitment in checking the suitability and eligibility to
work with young and vulnerable people
• Providing effective training and regular updates to all staff and service users to
raise awareness of all safeguarding issues
• Developing and implementing effective safeguarding procedures for identifying
and reporting cases, or suspected cases of safeguarding violations e.g. abuse,
neglect, bullying etc.
• Supporting staff who suspect and disclose any safeguarding violations in
accordance with our policies and procedures
• Establishing and maintaining a safe environment in which learners and young
people can learn and develop
• Ensuring the safe use of ICT networks and, online safety guidelines for access to
• Ensuring all staff including consultants use a Pathway Group email address to
communicate with service users to document all correspondence with service
users to keep an audit trail
5. Designated Responsible Safeguarding officer
The Designated Safeguarding Officer (DSO) is Martin Chandler, In his absence
Lucy Clifford will be the Designated Safeguarding Officer. Deputy Safeguarding
Officers include Sajad Ali and Lucy Clifford.
The Designated Director is Safaraz Ali.
Pathway Group staff and employer/placement managers are trained to observe
safeguarding violations e.g. the outward signs and symptoms of abuse and bullying.
The organisation and employer/apprenticeship placement organisations will
ensure and maintain an environment where learners feel secure and keep channels
of communication open, so young people and vulnerable adults can discuss any
concerns they may have with regards to safeguarding issues.
We will follow the guidelines set out by the local Safeguarding Children and
Safeguarding Adults Board and take account of guidance issued by the local
authority regarding safeguarding policy and procedures. We are committed to:
• Ensuring that Safaraz Ali, the designated director responsible for safeguarding,
has received appropriate training and support for this role
• Ensuring that the designated safeguarding officers responsible for safeguarding
have received appropriate training and support for this role
• Ensuring every member of staff (temporary/permanent/subcontractors) know
the names of the designated safeguarding officers and director responsible for
safeguarding and understand their roles and any changes in designations and
• Ensuring all staff understand their responsibilities in being alert to the signs
of abuse and responsibility for referring any concerns to the designated
• Developing effective links with relevant agencies and co-operating as required
with their enquiries regarding safeguarding matters including attendance at case
• Consulting with local safeguarding professionals in the development and
maintenance of our policy and procedures
• Keeping written records of concerns about all learners including young people,
even where there is no need to refer the matter immediately
• Ensuring all records are kept securely; separate from the learner personal file, and
in locked locations with access to only authorised persons
• Following internal procedures where an allegation is made against a member
of staff including utilising the Pathway Group Discipline & Grievance Procedures
where appropriate and relevant
• Ensuring safe recruitment practices are always followed in accordance with the
Pathway Group’s employment and training policies and relevant legislation,
including specifically in respect of the Criminal Records Bureau and Independent
• Ensuring that the safe use of the Pathway Group ICT network and internet access
is understood and that Acceptable Learner User Policy and Procedures are
followed by staff and learners alike
• Ensuring access to a range of information, advice and guidance (IAG) on staying
safe, promoting safe health care and well-being, including referrals to external
• Maintaining security such as visitor and staff checking arrangements and
safeguarding including technology, such as IP cameras, door access and vision
panels remain robust and ensuring learners feel safe
5.2 Roles and Structure
All staff delivering services to children and young people have a responsibility
under the Children Act 2004 to safeguard and promote the welfare of children.
Pathway Group staff both employed and subcontractors and consultancy staff have
a legal responsibility for the identification and reporting of individual violations and
for safeguarding the welfare of children and young people.
• Advice and support should be sought from the relevant line manager, especially
with regard to consent and referral issues. If the line manager is not available or is
unable to provide the required information, staff should contact the designated
safeguarding officer for support.
5.2.2 Designated Director
The Designated safeguarding Director, Safaraz Ali, is responsible for:
• Individual protection issues being maintained, monitored and evaluated
• Keeping central confidential files
• Providing an out of hours contact point in exceptional circumstances
• Ensuring safeguarding and individual protection procedures and policies are
kept up to date
• Contributing to serious case reviews and implementing any resulting action
5.2.3 Designated Safeguarding Officer(s)
The designated safeguarding officers are responsible for:
• Overseeing the referral of any cases of suspected abuse or allegations of the
• Providing advice and support to staff on safeguarding issues
• Maintaining records on safeguarding referrals, complaints or concerns raised
• Liaising with and providing advice for employers
• Ensure that appropriate safeguards are put in place for learners and placements
• Ensuring that staff receive training / updates in safeguarding issues and are
aware of Pathway Group’s policies and procedures
• Ensuring appropriate continuous professional development training including
awareness training for all staff
• Liaising with the Director responsible on all safeguarding issues that arise and
ensuring all safeguarding decisions are shared appropriately
• Implementing and reviewing policy and procedures to ensure that these remain
effective in safeguarding learners and young people and that the policy and
procedures are legally compliant
5.3 Key Definitions
Safeguarding and Promoting Welfare is defined as:
• Protecting children/vulnerable adults from maltreatment
• Preventing impairment of children’s/vulnerable adults health or development
• Ensuring that children/vulnerable adults are growing up in circumstances
consistent with the provision of safe and effective care
• Enabling those children to have optimum life chances and to enter adulthood
Child Protection is part of safeguarding and promoting welfare. The term is used to
refer to the activity that is undertaken to protect specific children who are suffering
or are at risk of suffering significant harm.
Physical Abuse may involve causing physical harm to an individual e.g. hitting,
shaking, slapping, pushing, kicking, misuse of medication, restraint, inappropriate
sanctions or otherwise. Factitious Disorder or Munchausen’s syndrome can also be
classed as physical abuse.
Physical Abuse Indicators include:
• Injuries that are consistent with physical abuse
• Injuries that are the shape of objects
• Present of several injuries of a variety of ages
• Injuries that have not received medical attention
• A person being taken to many different places to receive medical attention
• Skin infections
• Unexplained weight changes or medication being lost
• Behaviour that indicates that the person is afraid of the perpetrator
• Change of behaviour or avoiding the perpetrator
Emotional Abuse is the persistent emotional ill treatment of an individual
which causes severe and persistent side effects on the individual’s emotional
development. It may involve conveying to the individual that they are worthless
or unloved, inadequate or valued only in so far as they meet the needs of another
person. It may feature age or developmentally inappropriate expectations being
imposed on individual. These may include interactions that are beyond the
individual’s development capability as well as overprotection and limitation of
exploration and learning or preventing the individual participating in normal social
interaction. It may involve seeing or hearing the ill treatment of another. It may
involve serious bullying causing individuals to feel frightened or in danger, or the
exploitation or corruption of individual. Some level of emotional abuse is present in
all types of ill treatment of an individual, though it can still occur alone.
Emotional Abuse Indicators include:
• Low self-confidence/poor self-image
• Unable to feel trust/fearful
• Has difficulty forming relationships
• Little enthusiasm
• Low perseverance
• Social, emotional and/or academic delays
• Unusual fears
• Lack of empathy
• Failure to thrive
• Feelings of shame and guilt
• Aggressive behavior
• Self harm or mutilation
• Substance abuse
• Suicide attempts
• Eating disorders
• Degrading or humiliating punishments
Most definitions of abuse generally include either psychological or emotional
abuse. There is strong similarity between the characteristics. Emotional abuse is
generally described as an element of psychological abuse. Psychological abuse may
include emotional abuse, threats of harm or abandonment, deprivation of contact,
humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse,
isolation or withdrawal from services or supportive safeguarding.
Most definitions of abuse generally include either psychological or emotional
abuse. There is strong similarity between the characteristics. Emotional abuse is
generally described as an element of psychological abuse. Psychological abuse may
include emotional abuse, threats of harm or abandonment, deprivation of contact,
humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse,
isolation or withdrawal from services or supportive safeguarding.
Psychological Abuse Indicators include:
• Emotional abuse
• Threats of harm or abandonment
• Deprivation of contact
• Verbal abuse/excessive criticism
• Isolation or withdrawal from services or support networks
Signs that psychological abuse is taking place may include:
to contact you
• The adult not getting access to medical care or appointments with other agencies
• Low self-esteem
• Lack of confidence and anxiety
• Lack of eye contact
• Increased levels of confusion
• Increased urinary or faecal incontinence
• Sleep disturbance
• The person feeling/acting as if they are being watched all of the time
• Decreased ability to communicate
being used that is not usual for the service user
• Deference/submission to the perpetrator
Sexual Abuse – involves forcing or enticing a child, young person or vulnerable
adult to take part in sexual activities, whether or not the individual is aware of what
is happening. The activities may involve physical contact, including penetrative
(e.g. rape or buggery) or non-penetrative acts. They may involve non-contact
activities such as involving individuals in looking at, or in the production of sexual
online images, pornographic material, or watching sexual activities, or encouraging
individuals to act in sexually inappropriate ways.
Sexual Abuse Indicators include:
• Rape and sexual assault to which the vulnerable adult has not consented, could
not consent, or was pressurised into consenting
• Non-contact sexual abuse could include being forced or coerced to be
photographed or videoed to allow others to look at their body
• Inappropriate sexual knowledge or behavior
• Excessive sexual play and masturbation
• Sexually transmitted diseases
• Pregnancy – especially concealed
• Children who witness intimate sex acts
• Self-harm/suicide attempts/substance abuse
• Eating disorders
• Nightmares/disturbed sleep patterns
• Wetting, soiling/smearing excreta
• Significant changes in behavior/personality
• Persistent offending
Any sexual activity involving staff will be regarded as contrary to professional
standards and hence abusive
Signs that sexual abuse may be taking place:
• Sexually transmitted diseases or pregnancy
• Tears or bruises in genital/anal areas
• Soreness when sitting
• Signs that someone is trying to take control of their body image, for example,
anorexia, bulimia or self-harm
• Sexualised behaviour
Neglect and acts of omission
Neglect is the persistence or failure to meet a learner or young person’s basic
physical and/or psychological needs. This may include ignoring medical or physical
care needs, failure to provide access to appropriate health, social care or educational
services, the withholding of necessities of life, such as medication, adequate heating
Neglect and acts of omission Indicators include:
• Ignoring medical or physical care needs
• Failure to provide access to appropriate health, social care or educational services
• The withholding of the necessities of life, such as medication, adequate nutrition
Some of the recognised signs of neglect and acts of omission are:
• Rapid or continuous weight loss
• Not having access to necessary physical aides
• Inadequate or inappropriate clothing
• Untreated medical problems
• Dirty clothing/bedding
• Lack of personal care
• Psychological/emotional abuse
Discriminatory abuse indicators:
• Racist slurs
• Sexist slurs
• Slurs or harassment on the basis of a disability
• Slurs or harassment on the basis of sexual preference
• Age discrimination is also a form of abuse
Signs that discrimination may be taking place include:
• A person overly concerned about race, sexual preference and the like
• A person tries to be more like others
• A person reacts angrily if any attention is paid to race, sex and the like
• A carer is overly critical/anxious about these areas
• Disparaging remarks made
• A person is made to dress differently
• Similar to the psychological and emotional abuse
5.4 Recognising Abuse – General Considerations
All staff should be alert to signs that an individual may be at risk of significant harm,
regardless of age, sex, culture, religion, and social class, as individual abuse occurs
regardless of these factors.
Identification of individual abuse may be difficult; it normally requires both medical
and social assessment.
who is being sexually abused may be physically abused. Staff needs to be alert to
signs of other types of abuse.
Always listen carefully to the individual – pay particular attention to any spontaneous
statement. In the case of an individual with limited language, pay attention to their
signing or behavior or play. Be aware of body language and scribbling/doodling.
could be an indicator or abuse.
Beware if the explanation of an accident is vague, lacking in details, is inconsistent
to the injury or varies with each telling.
Take note of the appropriateness of the response of parents/carers.
Observe a child’s interaction with the parent particularly wariness or fear or
Any history or unexplained illness/injuries requires the most careful scrutiny.
Beware if there are indicators of a history of domestic violence. Violence towards
adults may also indicate violence towards children, and can it be emotionally
Individuals who are being abused often do not disclose, for a variety of reasons, so
in our professional capacity we have to be vigilant to possible signals.
Be aware at all time that Pathway Group is responsible for reporting incidents of
suspected abuse and not investigating them.
What Safeguarding Legislation states about Children
The Children Act 1989 and 2004 highlight legislation about safeguarding
requirements for Children. The five outcomes for children and young people are
given legal force in the Children Act 2004.
What the outcomes are and what they mean:
1. Be healthy
• Physically healthy
• Mentally and emotionally healthy
• Sexually healthy
• Healthy lifestyles
• Choose not to take illegal drugs
• Parents, carer’s and families promote healthy choices
2. Stay safe
• Safe from maltreatment, neglect, violence and sexual exploitation
• Safe from accidental injury and death
• Safe from bullying and discrimination
• Safe from crime and anti-social behaviour in and out of school
• Have security, stability and are cared for
• Parents, carer’s and families provide safe homes and stability
3. Enjoy and achieve
• Ready for school
• Attend and enjoy school
• Achieve stretching national educational standards at primary school
• Achieve personal and social development and enjoy recreation
• Achieve stretching national educational standards at secondary school
• Parents, carer’s and families support learning
4. Make a positive contribution
• Engage in decision-making and support the community and environment
• Engage in law-abiding and positive behaviour in and out of school
• Develop positive relationships and choose not to bully and discriminate
• Develop self-confidence and successfully deal with significant life
• Changes and challenges
• Develop enterprising behaviour
• Parents, carer’s and families promote positive behaviour
5. Achieve economic well-being
• Engage in further education, employment or training on leaving school
• Ready for employment
• Live in decent homes and sustainable communities
• Access to transport and material goods
• Live in households free from low income
• Parents, career’s and families are supported to be economically active
5.6 Significant Harm
It is the duty of the relevant Safeguarding Children Board to determine whether
the child is at risk of significant harm, not Pathway Group. However we need to
have an understanding of what it means to inform our referral procedures.
There are no absolute criteria for deciding what constitutes significant harm. It re-
quires judgment based on the nature of the abuse, and the effects of that abuse on
The following stages can be used as a guide to assess significant harm:
The first stage is to establish whether the child is suffering or is likely to suffer harm.
“Harm” is something that damanges, interrupts, or has a negative effect on child’s
development. It could be:
• Physical Injury
• Sexual Exploitation
• Impairment of health or development (physical, intellectual, emotional, social or
The second stage is to decide whether ot not he harm is significant.
“Significant”Is hard to define. One way to decide is“harm”is significant in a given case
maybe to ask the following questions:
• Is the harm substantial?
• Is it extensive?
• Is the child young, disabled, unable to communicate, or for any other reason,
• Has ill treatment continued over a long period?
• Has it occurred on more than one occasion?
• Was the ill treatment intentional?
• Was it premeditated?
• Were threats or coercion used?
• Are there any sadistic or bizzare elements to the ill treatment?
If the answer to any of these questions is “yes”, then the harm is more likely to be
significant. If the answer to several questions is“yes”, then the harm is very likely to be
significant. Some forms of harm are likely always to be significant. The include:
• Sexual abuse
• Serious physical injury
• Dangerous actions such as poisoning or suffocation or shaking of a baby
• Severe, chronic neglect
• Inducted/ Fabricated Illness Syndrome
5.6.1 Children who may be at risk of significant harm
If information comes to light suggesting that a child may be at risk of significant
harm, ther is a requirement on the local authority, under Section 47 of the Children
Act, to make,“such enquiries as they consider necessary to enable them to decide
what action they should take to safeguard or promote the child’s welfare.”
The assessment of significant of harm must also consider:
• The child’s development needs
• The carer’s parenting capacity – strengths and deficits
• Supports available within family and community
• The nature of the ill treatment
• The impact of the ill treatment on the child and the child’s view of the situation
• Research message and information from SCR’s
See‘The Working Together to Safeguarding Publication: A guide to inter-agency
working to safeguard and promote the welfare of children’for more details: https://
5.7 Recording, Sharing of Information and Consent Issues
In the context of‘working together’with other agencies, young people and families,
information will have to be shared, so it is important that our records are kept up to
date at all times.
Bear in mind that a young person can request their records and until official
‘consent’has been sought we need to be sensitive as to what we record.
It is also necessary to keep written records for yourself, with a copy for the
designated safeguarding officers. You may need to refer to these at a later stage,
or keep them as evidence. These should be locked away in a secure designated
Dealing with Disclosure of Abuse and Reporting Concerns -
Receive- Reassure- React- Record
In circumstances where a learner decides to disclose an incident of abuse or neglect
to a staff member or in a situation where the staff member suspects a young person
is being abused or is at risk, Pathway Group staff should respond according to the
• Stay calm
• Don’t show shock
• Accept what the person discloses
• Find a comfortable place to talk
• Stay calm – tell the person they have
done the right thing
• Never promise to keep a secret
• Tell the person who you will need to
inform and about your legal duty
• Alleviate any feelings of guilt
• Acknowledge the difficulty of telling
• Treat information disclosed seriously
• Do not ask leading questions
• Do not criticise the perpetrator
• Do not ask the person to repeat the
disclosure to someone else
• Explain what YOU need to do next
and who YOU need to contact
• If disclosure is about immediate
abuse do not offer shower, bath or
change of clothes
• Contact a Pathway Group designated
safeguarding officer or Social Care
Officer and the Local Authority Safe-
• Make the persons wishes known
• Write things down – at that time
• Keep the original notes; even a scrap
of paper or a post-it note if used
• Designated Officers should use the
• Record the actual words the person
says, word for word
• Use a body map if appropriate. Date
and sign it
• Do not use assumption or
Important statutory duties in relation to vulnerable adults and children in need
cannot be met without effective and appropriate sharing of information. For agencies
to work together to the benefit of individuals, they must be able to share relevant
but could simply be sharing information between supporting agencies regarding a
young person, for example, before a referral is made.
However, sharing of information should take place according to the principles of
good practice and on a need to know basis. When a request for information is made
we need to be clear about why the information is needed and the way it is going to
Seeking Consent for Making a Referral or Sharing Information
Prior to information being shared with other agencies, or a referral being made,
consent should normally be sought from the young person and/or from one parent/
carer with agreed parental responsibility.
However, there are certain important circumstances where consent should not be
sought. These are:
• If this would put the child or young person or vulnerable adult at greater risk of
• Interfere with criminal enquiries
• Raise concern about the safety of staff
As a significantly 16-19 service we will come across the situation where a young
person is sufficiently mature enough to understand choices and their consequenc-
es, and will not give consent for referral, especially if they believe it will make their
situation worse. This is a particularly difficult situation. You will have to use your
judgment as to whether it is appropriate and lawful to refer without consent. Advice
must be sought from your designated Safeguarding Officer and Safeguarding Chil-
dren Board. You must inform the young person if you decide to refer.
A parent’s or young person’s lack of agreement should not prevent you from mak-
ing a referral. If they do not agree, and you decide you need to refer, then you must
inform them accordingly
Practical Advice for the Designated Safeguarding Officer
There will be no two situations the same so it is difficult to give precise guidelines,
but follow procedures given.
It can be a very difficult situation when you need to seek consent from anyone,
especially a parent. Make sure you do your research, gather all information together
and get advice from the Safeguarding Children Board/ Safeguarding Adults Board.
Make sure you discuss your strategy with deputy designated safeguarding officers
so you are clear before talking to the young person and parents/career’s.
Think about having a Deputy with you at the time for support.
If they don’t give their consent but your judgment is still to refer, then INFORM them
that you are going to refer and why.
Get support afterwards, and de-brief if particularly traumatic
Support for Staff
Although staff should be aware of their responsibilities and procedures for individual
protection issues, appropriate support should be sought to help throughout that
The Designated Director should be included in the decision to obtain consent and
refer to Safeguarding Children Board/ Safeguarding Adults Board, and will support
staff through any further action which will be taken.
The Designated Director will help in more complex or serious cases.
Children’s Social Care, or other designated contacts can be contacted for advice as
5.8 Employer Agreement
Pathway Group will ensure that all employers and work-placement providers entering
into training agreements with Pathway Group receive comprehensive orientation to
their responsibilities within the Employer Agreement and the learning and training
process. The Employer Agreement itself, a separate document stipulates clearly
certain immediate and obvious employer placement responsibilities which include:
Disclosure and Barring Service (DBS) Enhanced Disclosures –in which an employer is
legally required to conduct DBS disclosures for any and all staff it employs. Pathway
Group asserts it is the responsibility of the employer or work-placement to carry out
DBS Enhanced Disclosures on all staff including learners, whether employed or non-
Supervision of Learners at Other Organisations
Employers agree in accordance with legally binding LearnerTraining Agreements and
Employer Agreements; that they will undertake all guidance provided by Pathways
relating to the health & safety, safeguarding and well-being of all learners including,
compliance in full, on safeguarding learners and young people from all forms of
discrimination, as provided for in the Pathways Equal Opportunities policy.
Pathway Group’s Board of Directors Responsibilities
Pathway Group is responsible in so far as to ensure that its own staff: DBS disclo-
sures during their recruitment process. We ensure that staff will not be unaccompa-
nied with learners until such time as the enhanced disclosure checks are completed
satisfactorily. Similarly, in safeguarding policy and procedures accordance with
employment and training policy and procedures, become registered nationally in
accordance with the Disclosure and Barring Service and that it makes appropriate
disclosures of staff information according to the requirements of the DBS regu-
lations. No responsibility for learners undertaking DBS checks will be incurred by
Pathway Group except where Pathway Group employs that learner.
Learner Induction by Pathway Group
Pathway Group will ensure that all learners are fully inducted by assessment staff
and that Induction Phase 2 (1st Assessment Plan) have been completed and signed;
ensuring that the following has been covered:
Orientation to safeguarding policy/procedures or guidelines for:
• OFSTED: Employer’s Own Arrangements (Childcare Only).
• Pathway Group (Policy & Procedures, Staff Handbook, and Learner Handbook)
• All employer or work-placement policy & procedures
Learner Induction by Employer or Work-placement Provider
In the case of placements, Pathways recognises and asserts:
That it is the responsibility of the employer or placement provider to ensure that
their recruitment, application and interview processes are: legally compliant whilst
care is taken to verify adequate professional references and prior work history and
DBS Enhanced Disclosures for all staff (where the occupational sector or legislation
requires) and that it is the responsibility of the employer or work-placement provid-
er to fully induct all learners into the workplace and to ensure that learners are clear
• Where the Pathway Group Staff Handbook is stored for their reference informa-
tion and guidance
• (Childcare Only) OFSTED – Standards places a responsibility on the registered
person to ensure all new staff receive adequate training which includes safe-
guarding policies and procedures in their first week of employment sufficient
to ensure that all staff understand how to conduct themselves when faced with
a safeguarding matter; how and where to access the employers/providers own
safeguarding policy and procedures when required
Dealing with learners implicated in a safeguarding matter
When a safeguarding issue arises in the workplace and the person who is implicated
is a learner who is in training with Pathway Group, the employer or work-placement
• Suspend the learner and immediately follow their own published workplace
guidelines and inform the employer’s nominated person in charge of safeguarding
delay if any learner regardless of employment status is involved in some capacity
such as witnessing any incident, which may be considered a safeguarding matter.
A Cause for Concern (Coca) form must be completed and sent to Martin Chandler
(DSO) at Pathway Group
N.B. Pathway Group is operationally bound to work within the contractual terms of
various organisations such as the Skills Funding Agency (SFA) or the local authority or
under its contractual agreements to notify the SFA or other funding agency of
safeguarding incidents involving government, FE colleges, government agency or
local authority funded learners.
Effective training is the key to carrying out our responsibilities of promoting and
safeguarding children young people and vulnerable adults. Staff need to be trained
on how to identify an individual in need, and what subsequent action to take.
Training takes place on a variety of levels, and will depend upon the needs and roles
of the staff concerned.
5.9 Monitoring and Evaluation
The Designated Persons will conduct an annual review of our safeguarding and child
protection systems and policies.This will include consideration of specific cases dealt
with by staff in the last year. The resulting information – including feedback from
staff, will be used by the Designated Person to inform any improvements
Implementation of Policy Monitoring
The purpose of monitoring a policy is to ensure that it is being implemented. Learn-
er and employer documentation will evidence circulation of and orientation to pol-
icies and procedures. All reported incidents will be reported directly to the Board of
Directors by the director responsible for safeguarding who will also support policy
and procedure reviews and legal compliance with the safeguarding officers. Confi-
dential records of notified incidents will in part evidence the implementation of this
policy and associated procedures.
Contravention of the policy
Pathway Group takes responsibility for ensuring that learners are inducted, trained
and supported in partnership with employers and work-placement providers.
Pathway Group will ensure action and support in the event of a contravention of
any of its policies. In the event of any contravention of this policy Pathway Group
will investigate promptly and fully. The investigation will aim to establish whether
everything has been done to ensure that learners were inducted, trained, super-
vised and instructed in partnership with their employers and work-placement pro-
viders to achieve clarity of understanding and best practice in relation to staying
safe, safeguarding issues and associated procedures.
5.10 Key Contacts & Referral Agencies
5.10.1 Key Internal Contacts
Name Safeguarding Designation Contact Number
Martin Chandler Designated Safeguarding Officer 0780 754 0922
Safaraz Ali Designated Director 0797 465 751
Sajad Ali Deputy Safeguarding Officer 07531 866 922
Lucy Clifford Deputy Safeguarding Officer 0121 707 0550
5.10.2 Referral Agencies
Birmingham Safeguarding Children Board
Council House Extension
Telephone: 0121 464 2612
Fax: 0121 303 8427 22.
Birmingham Multi Agency Safeguarding Hub (MASH)
Telephone: 0121 303 1888
Local Authority Designated Officer (LADO)
For Non-emergency calls ring the Adults and Communities Access Point (ACAP)
on 0121 303 1234 and press option 1 on the keypad.
For out of office hours, weekends and Bank Holidays call the Emergency Duty Team
on 0121 675 4806.
Online Safety Guidelines
A.1 BE WISE
• Always ask“Why”a website or someone you make friends with on the Internet
would need your personal information.
• Be Inspired. The Internet offers great tools for learning, discovering and creating.
• Be Secure. There are constantly new scams, hoaxes, viruses and spyware on the
Internet. Install security software to keep your computer and data safe.
• Evaluate the stuff you read, see or receive through the Internet. Just because it’s
on the Internet does not make it true, reliable or genuine.
A.2 BE SMART
• Keep Safe by being careful not to give out your personal information - such as
your name, email, phone number, address, college name, any bank details, PIN
numbers or passwords - to people online.
• Meeting someone you have only been in touch with online can be dangerous –
Tell an adult and don’t do it alone!
• Accepting emails, messages on IM or opening files, pictures or texts from people
you don’t know or trust can lead to problems.
• Reliable? Someone online may be lying to you about who they are. Tell your
parent or tutor immediately, if someone or something on-line makes you feel
uncomfortable or worried.
A.3 Staying Safe on Social Networks and Instant Messenger
• Do you know everyone on your buddy or contacts list? Think carefully about who
is on your list. People on IM, like in chat, may not be who they say they are, so a
friend of a friend is not necessarily a friend.
• Keep your personal information secret when talking to someone you don’t know
in the real world. Also think about what visible information you have, for example
in your Profile or Member directory.
• Learn how to keep an archive/save a copy of your conversation, and don’t be
afraid to tell someone you are saving their conversation.
• Learn how to block, ignore and report people.
• Check you know how, to report something you feel uncomfortable about to the
Messenger or Social Networking provider.
• Use a nickname, not your real name, and a nickname that is not going to attract
the wrong type of attention.
• Keep your username and password private, and change your password on a
• Don’t reply to abusive messages. Don’t send abusive messages either. It’s best not
to say anything on IM or a Social Network that you wouldn’t say to someone’s face.
• Don’t accept messages from people you don’t know.
• Meeting someone you have only been in touch with online can be dangerous.
If you feel that you have to meet, then for your own safety you must tell your
parent or carer and take them with you – at least on the first visit – and meet in a
public place in daytime.
• Don’t pass the buck - if someone you have accepted on your buddy or contacts
list is acting weird; don’t pass them on to a friend. You could be putting your
friend at risk. Just block them and report them to an adult, parent or carer.
PROCEDURE FOR DISCLOSURE OF ABUSE
B.1 PROCEDURE FOR DISCLOSURE OF ABUSE FOR WITHIN PATHWAY GROUP
1. Discuss the disclosure with the Assessor/tutor as soon as possible
2. The Assessor will then take this forward through completing a Cause for Concern
3. Prepare a written statement. This should be kept in a confidential file, along with
a copy of the Cause for Concern form. Copies of the statement and Cause for
Concern form should be sent to the Designated Safeguarding Officer to be kept
in the central file
4. Familiarise yourself with follow up procedures if a Cause for Concern is raised and
B.2 PROCEDURE FOR DISCLOSURE OF ABUSE WHERE THERE ARE CONCERNS
ABOUT A LEARNER
1. Take an informal approach initially and seek an explanation for concerns with
the learner without raising questions of abuse.
2. Gather as much information as possible from other colleagues who may have
had some involvement with learner and other agencies.
3. Identify whether there are others that maybe at risk.
4. Discuss your concerns with your line manager if appropriate.
5. Speak with your DSO and gain advice and guidance
6. If need be suspend the learner.
7. Consider speaking to the Safeguarding Children Board for advice (if concerns
relate to a child), or Safeguarding Adults Board where appropriate.
8. Decide upon your next course of action, which could be no action or a referral to
the Safeguarding Children Board (Children only) or Safeguarding Adults Board
9. If no referral is made then record your concerns on the Candidate Concern form
and update, and monitor the situation carefully.
10. CHILDREN ONLY. If it is decided to make a referral, then consent issues need to be
addressed. Learners need to be consulted if not seen recently to seek their con-
sent to refer and a decision needs to be made about seeking consent from par-
ent/family. If possible we need to seek their agreement to making referrals to the
Safeguarding Children Board but this should only be done where such discussion
and agreement seeking does not place a child at increased risk.
11. Complete the referral form and if referral is by telephone, send form through
within 24 hours to relevant line manager.
12. Produce a written statement and place in confidential file, with referral form and
B.3 PROCEDURE FOR CONCERNS RAISED BY SOMEONE OTHER THAN INDIVIDUAL
THEMSELVES AND YOU
1. If the person concerned is a colleague within Pathway Group refer them to these
procedures and Designated Safeguarding Officer & in their absence notify the
2. If the person concerned is a colleague within another institution refer them to
their own line manager and their Safeguarding procedures.
3. If the person concerned is a parent/carer or member of the public refer them to
the Safeguarding Children Board or Safeguarding Adults Board, as appropriate,
B.4 PROCEDURE TO BE FOLLOWED IF YOU RECEIVE AN ALLEGATION AGAINST A
MEMBER OF PATHWAY GROUP’S STAFF
1. From time to time children/vulnerable people may make an allegation that they
have been abused by a member of staff.
2. The procedure for dealing with such allegations is contained in the Company’s
disciplinary procedures. Such an allegation will be treated as a potential case of
3. If you receive an allegation either by the young person or another person you
must refer the matter to the appropriate designated Safeguarding officer.
4. The member of staff may not be automatically suspended, but we have a duty
to make preliminary enquiries before a referral to the Safeguarding Children
Board (Children only). These must not interfere with possible investigations and a
referral should be made if there is any doubt.
5. If another agency receives an allegation against a member of Pathway staff, they
should contact the designated Safeguarding Officer or Safeguarding Director.
6. If a member of Pathway Group’s staff receives an allegation against a member
of another agency, staff should in the first instance discuss this with your line
7. If an allegation is made against the line manager, then refer direct to either the
designated Safeguarding officer or in their absence notify deputies.
8. (8) Follow guidelines in personal safety policy on lone working and good
professional practice when working in a one-to-one situation. Apply your
experience and judgment when dealing with interactions with learners, in order
to minimise the possibility of allegations occurring.
Apply your experience and judgment when dealing with interactions with learners, in
order to minimise the possibility of allegations occurring.
Pathway Group Safeguarding
Cause for Concern Form
Name of child/vulnerable adult:
DOB: Student Ref No:
Does the child/vulnerable adult know you are speaking to a Safeguarding Officer?
No (State reason)
Reason for concern:
(State what child/vulnerable adult said, or what you observed that caused suspi-
cion. Include date, and time of event. Where reporting what someone has said to
you, try to use as close to their exact words as you can remember). Continue on
additional pages if necessary.
Category of abuse causing concern:
(Tick any that apply)
Physical Neglect Emotional Sexual Financial Institutional
Whom have you spoken to and what was said?
Details of person completing this form
To be completed by a Safeguarding Officer.
State what action was taken and when (continue on additional pages if necessary).
Please input summary onto Safeguarding Spreadsheet.