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Safeguarding Policy

Publication Date: 17th November 2022 

Expiry Date: 17th November 2023 

Review Date: 17th October 2023

Target Audience: All Sapphire Education and Training employees, learners and relevant stakeholders 


Policy on identifying and responding to concerns regarding the safeguarding and protection of children, young people and adults at risk.

key words

Safeguarding, vulnerable, protection, prevention, safe, abuse, Prevent, extremism, radicalisation, terrorism, children, adults.

Our Safeguarding Approach


Sapphire Education and Training is committed to ensuring that we provide a caring, positive, safe and stimulating environment that promotes the social, physical and moral development of our learners. The safety, welfare and protection of all learners is paramount. This policy applies to all learners and all staff without exception. This policy applies to all visitors including Governors and contractors. All staff understand their responsibility and contribution to protecting learners and what to do where there are concerns that a learner is at risk of, or is experiencing harm or abuse. All staff understand that safeguarding is everyone’s responsibility.


At Sapphire, we will:
• Ensure there are clear procedures for reporting and dealing with allegations of abuse including any allegations against members of staff
and concerns that do not meet the harm threshold (low-level concerns).
• Provide appropriate support to learners who have been abused. For example, signposting them to services of a counsellor.
• Introduction of a training schedule to ensure all staff are trained and familiar with the Safeguarding Policies and Procedures.
• Promote the safer recruitment of staff in compliance with the Disclosure and Barring Service (DBS) regulations, including enhanced DBS checks
to ensure staff are not prohibited from teaching as well as obtaining and checking references and identity checks. Staff will be encouraged to
register on the update service.


Sapphire Education and Training’s learners are supported by knowledgeable development coaches who have a commitment to safeguarding and promoting the welfare of those undertaking training. All staff are made clear about the policies and procedures. Learners are confident that any concerns they have will be taken seriously and dealt with swiftly and they have a good awareness of safeguarding risks.

Equality Statement – Due Regard

Sapphire Education and Training aims to design and implement policy documents that meet the diverse needs of our service, population and workforce, ensuring that none are placed at a disadvantage over others. It considers the provisions of the Equality Act 2010 and promotes equal opportunities for all.
This document has been assessed to ensure that no one receives less favourable treatment on the protected characteristics of their age, disability, sex (gender), gender reassignment, sexual orientation, marriage and civil partnership, race, religion or belief, pregnancy and maternity.
In carrying out its functions, Sapphire Education and Training must have due regard to the different needs of different protected equality groups.
This applies to all the activities for which Sapphire is responsible, including policy development and review.

Confidentiality Statement

Sapphire Education and Training will operate on the premise that all information imparted to a member of staff will be treated in confidence. Confidentiality is a key issue in the lives of learners and colleagues. They may trust a member of staff with issues of a personal nature and wherever possible their confidences should be respected. Staff must become familiar with the confidentiality guidelines upheld by Sapphire Education and Training. Staff must not make promises on confidentiality that they may be unable to keep. Furthermore, staff should always make a learner or colleague fully aware of any situations where confidentiality must not be maintained as in the case of young person and vulnerable adult protection. Learners and colleagues may not disclose information that is difficult for the member of staff to deal with without further advice and support. In this case, the learner and colleagues should be told that the situation will be discussed with an individual with a speciality in
that area, but confidentiality will be maintained if possible.


1.1 Safeguarding is defined as:

  • Protecting children and adults at risk from maltreatment.
  • Preventing impairment of a child or adult at risk, health or development.
  • Ensuring that children are growing up and adults at risk are living in circumstances consistent with the provision of safe and effective care; and
  • Acting to enable all children and adults at risk to have the best life

1.2 Sapphire Education and Training is committed to safeguarding and promoting the welfare of all its learners/customers/service users.
We believe that:

  • All young people and adults at risk have the right to be protected from harm.
  • Learners/customers/service users need to be safe and to feel safe when accessing our services.
  • Learners/customers/service users need support which matches their individual needs, including those who may have experienced
  • Learners/customers/service users have the right to speak freely and voice their values and beliefs.
  • All learners/customers/service users must be encouraged to respect each other’s values and support each other.
  • All learners/customers/service users have the right to be supported to meet their emotional, and social needs as well as their
    educational needs – a happy healthy sociable young person will achieve better educationally and adults at risk remain safe and
  • Our services can and do contribute to the prevention of abuse, victimisation, bullying, exploitation, extreme behaviours, discriminatory views and risk-taking behaviours; and
  • All employees and visitors have an important role to play in safeguarding learners/customers/service users and protecting them from abuse.
1.3 Sapphire Education and Training will fulfil their local and national responsibilities as laid out in the following documents:
Child Protection
  • Children Act 1989
  • Protection of Children Act 1999
  • Adoption and Children Act 2002
  • Every Child Matters 2003
  • National Service Framework 2004
  • Children Act 2004
  • Local Safeguarding Children Board Functions
  • What to Do If You Are Worried a Child is Being Abused 2006
  • Children and Young People Act 2008
  • Laming Reports
  • The Education Act 2002
  • Mental Health and Behaviour in Schools: Departmental Advice (DfE 2014)
  • Working Together to Safeguard Children 2018
  • Keeping Children Safe in Education: DfE September 2022

Adult at Risk Protection

  • National Assistance Act [section 47]1948/1951
  • Mental Health Act 1983/2007
  • Police and Criminal Evidence Act 1984
  • National Health Service and Community Care Act 1990
  • Family Law Act 1996
  • Human Rights Act 1998
  • Care Standards Act 2000
  • No Secrets 2000
  • Sexual Offences Act 2003
  • Domestic Violence Crime and Victims Act 2004
  • Safeguarding Adults [ADASS] 2005
  • Mental Capacity Act 2005/Deprivation of Liberty [April] 2009
  • Safeguarding Vulnerable Groups Act 2006 

2. Overall Aims

2.1 This policy will contribute to safeguarding our learners/customers/service users and promoting their welfare by:

  • Clarifying standards of behaviour for employees and learners/customers/service users.
  • Contributing to establishing a safe, resilient and robust ethos within the organisation, built on mutual respect, and shared values.
  • Introducing appropriate work within the curriculum.
  • Encouraging learners/customers/service users/parents and carers to participate.
  • Alerting employees to the signs and indicators that all might not be well.
  • Developing employee awareness of the causes of abuse.
  • Developing employee awareness of the risks and vulnerabilities their learners/customers/service users face.
  • Addressing concerns at the earliest possible stage; and
  • Reducing the potential risks learners/customers/service users face of being exposed to violence, extremism, exploitation, or victimisation.

2.2 This policy will contribute to supporting our learners/customers/service users by:

  • Identifying and protecting the most vulnerable and at-risk
  • Identifying individual needs where possible; and
  • Designing plans to meet those needs.

2.3 This policy will contribute to the protection of our learners/customers/service users by:

  • Including appropriate work within the curriculum;
  • Implementing child protection and safeguarding adults at risk policies and procedures; and
  • Working in partnership with learners/customers/service users, parents and agencies.

3. Key Principles

3.1 These are our key principles of safeguarding:

  • Always see the learner/adult at risk first.
  • Never do nothing.
  • Do with, not to, others.
  • Do the simple things better.
  • Have conversations, build relationships.
  • Outcomes not outputs.

3.2 In addition we champion the following key messages:

  • Every learner/customer/service user is entitled to a rich and rounded curriculum. Sapphire Education and Training operate with public money: this should be spent wisely, targeting resources on the evidenced needs of learners/customers/service users. Assurance and audit are important aspects of this.
  • Individual directors and senior managers can and should take the lead on specific aspects of company policy such as safeguarding.

4. Key Processes

4.1 All employees should be aware of the guidance issued by their local authority safeguarding children board and adult social care departments.


5.1 All employees and visitors will:

  • Be familiar with this safeguarding policy.
  • Be subject to Safer Recruitment processes and checks, whether they are a new employee, supply employee, contractors, volunteers etc.
  • Be alert to signs and indicators of possible abuse (See Appendix 1 for current definitions and indicators).
  • Record concerns on CPOMs, which triggers an alert to the designated safeguarding officer Jackie Adey or deputy officer Katrina Smith.
  • Deal with a disclosure of abuse from a learner in line with the guidance in Appendix 2 – you must inform the Designated Safeguarding Officer immediately, and provide a detailed account on CPOMs within 24 hours.

5.2 All employees will receive basic safeguarding training at least every 12 months via the online platform Psittacus. The Designated Safeguarding Officers will receive Level 3 Safeguarding training.


6.1 Our Designated Safeguarding Officer on the senior leadership team is Jackie Adey. She has lead responsibility and management oversight and accountability for child protection and adults at-risk activity and is supported by Deputy Safeguarding Officer Katrina Smith.

Contact Details:
Mobile: 07446883435

6.2 When Sapphire Education and Training has concerns about a learner, the development coaches will report this on CPOMs where the designated Safeguarding Officer will decide what steps should be taken and will advise the Deputy Safeguarding Officer and Managing Director where appropriate.

6.3 All information will be dealt with in a confidential manner. Employees will be informed of relevant details only when the Designated Safeguarding Officer feels that the knowledge of a situation will improve their ability to support the individual learner. A written record will be made of what information has been shared with whom and when.

6.4 Child protection records are stored on CPOMs, with Development Coaches and Senior Managers having their own unique login.

6.5 For those learners who are 16-18, parents will be aware of information held on their child and kept up to date regarding any concerns or developments by the DSL.

6.6 Do not disclose to a parent any information held on a child if this would put the child at risk of significant harm.

6.7 If a learner/customer/service user moved from Sapphire Education and Training’s services, child protection records will be forwarded on to the Designated Safeguarding Officer at the new provider, with due regard to their confidential nature and in line with current government guidance on the transfer of such records. Direct contact between the two organisations may be necessary. We will record where and to whom the records have been passed and the date.

6.8 If sending by post records will be sent by ‘Special/Recorded Delivery’. For audit purposes, a note of all records transferred or received should be kept in either paper or electronic format. This will include the name, date of birth, where and to whom the records have been sent and the date sent and/or received.

6.9 When a Designated Safeguarding Officer resigns their post or no longer has child protection/adult at risk responsibility, there should be full face-to-face handover/exchange of information with the new post holder.

6.10 In exceptional circumstances, when a face-to-face handover is unfeasible, the Managing Director will ensure that the new post holder is fully conversant with all procedures and case files. 

7. The Management Team

7.1 The Management Team is accountable for ensuring the safety of the organisation.

7.2 The Management Team will ensure that:

  • Sapphire Education and Training has a Safeguarding Policy in accordance with national best practice and funding body requirements.
  • Sapphire Education and Training operates ‘safer recruitment’ procedures and ensures that appropriate checks are carried out on all new employees and relevant volunteers.
  • At least one senior member of the leadership team acts as a Designated Safeguarding Officer.
  • The Designated Safeguarding Officer attends appropriate refresher training every 2 years.
  • All employees who work at Sapphire will undertake training annually.
  • Freelance employees will be made aware of Sapphire Education and Training’s safeguarding arrangements and policies and procedures.
  • Sapphire Education and Training has procedures for dealing with allegations of abuse against employees/volunteers.

7.3 The Managing Director reviews the policies/procedures annually.

7.4 The Quality Manager/Designated Safeguarding Officer is nominated to be responsible for liaising with the local authority (LADO) and other partner agencies in the event of allegations of abuse being made against the Managing Director.


Safer Recruitment and Selection

8.1 Sapphire Education and Training pays full regard to ‘Keeping Children Safe in Education’ (DfES 2022). Safer recruitment practice includes scrutinising applicants, verifying identity and academic or vocational qualifications, obtaining professional and character references, checking previous employment history and ensuring that a candidate has the health and physical capacity for the job. It also includes undertaking interviews and undertaking appropriate checks through the Disclosure and Barring Service
(DBS). All staff employed by Sapphire Education and Training are subject to routine enhanced DBS checks every three years.

  • Standard DBS Check | This will be for positions that are included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order
    1975. This type of check contains details of an individual’s convictions, cautions, reprimands or warnings recorded on police central records and includes both ‘spent’ and ‘unspent’ convictions that will be shown on a criminal records check.
  • Enhanced DBS Check | This will be for positions included in both the ROA 1974 Exceptions Order and in the Police Act 1997 regulations. This type of check contains the same details as the standard check plus any information held locally by police forces that it is reasonably considered to be relevant to the post applied for.
  • Enhanced DBS & Barred List Check (Child) | An enhanced check with information from the DBS’s children’s barred list is only available for those individuals engaged in regulated activity with children and a small number of posts as listed in the Police Act 1997 regulations.
  • Enhanced DBS & Barred List Check (Adult) | An enhanced check with information from the DBS’s adults barred list is only available for those individuals engaged in regulated activity with adults and a small number of posts as listed in the Police Act 1997 regulations.
  • Enhanced DBS & Carred List Check (Child and Adult) | An enhanced check with information from the DBS’s Children and Adults Barred List is only available for those individuals engaged in regulated activity with both vulnerable groups including children and a small number of posts as listed in the Police Act regulations.

8.2 All recruitment materials will include a reference to the company’s commitment to safeguarding and promoting wellbeing.


9.1 We will provide learners with opportunities to develop skills, concepts, attitudes and knowledge that promote their safety and well-being.

9.2 Relevant issues will be addressed through other areas of the enrichment activities curriculum, for example, employability, one to one support sessions.

Other Areas of Work

9.3 All our policies which address issues of power and potential harm, for example, bullying, equal opportunities, handling, and positive behaviour, will be linked to ensure a whole organisation approach.

9.4 Our safeguarding policy cannot be separated from the general ethos of the company, which should ensure that learners/customers/service users are treated with respect and dignity, taught to treat each other with respect, feel safe, have a voice, and are listened to.


10.1 Since 2008, when the Government published the Prevent Strategy, there has been an awareness of the specific need to safeguard children, young people and families who are at risk of radicalisation from violent extremism. There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children, young people and adults to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

10.2 Sapphire Education and Training values freedom of speech and the expression of beliefs/ideology as fundamental rights underpinning our society’s values. British Values underpin the core values at Sapphire and are embedded into all our activities. All learners, customers, service users and employees have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

10.3 The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in supporting terrorism or in committing acts of terrorism. The normalisation of extreme views may also make children, young people and vulnerable adults to future manipulation and exploitation. Sapphire Education and Training is clear that this exploitation and radicalisation should be viewed as a safeguarding concern.

10.4 Definitions of radicalisation and extremism, and indicators of vulnerability to radicalisation are in Appendix 4.

10.5 Sapphire Education and Training seeks to protect children, young people and adults at risk against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or Far Right/Neo Nazi/White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

Risk Reduction

10.6 The management team and the Designated Safeguarding Officer will assess the level of risk within the company and put actions in place to reduce that risk. Risk assessment may include consideration of the company’s curriculum, policies, the use of company premises by external agencies, integration of learners/customers/service users by gender and SEN, anti-bullying policy and other issues specific to the company’s profile, community and philosophy.

10.7 This risk assessment will be reviewed as part of the annual Safeguarding Policy review.


10.8 Sapphire Education and Training like all others, is required to identify a Prevent Single Point of Contact (SPOC) who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism: this will normally be

the Designated Safeguarding Officer. The SPOC for Sapphire Education and Training is Jackie Adey. The responsibilities of the SPOC are described in Appendix 5.

10.9 When any employee has concerns that a learner/customer/service user may be at risk of radicalisation or involvement in terrorism, they
should speak with the SPOC. Depending on the nature of the referral, the SPOC will take advice from the FEHE coordinator. Issues of iimmediate concern will be referred to the police.

10.10 Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action. For this reason the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issue.


11.1 Sapphire Education and Training keeps itself up to date on the latest advice and guidance provided to assist in addressing specific vulnerabilities and forms of exploitation.

11.2 Our employees are supported to recognise warning signs and symptoms in relation to specific issues, include such issues in an age appropriate way in their curriculum.

11.3 Sapphire Education and Training works with and engages our families and communities to talk about such issues.

11.4 Our Designated Safeguarding Officer knows where to seek and get advice as necessary.

11.5 Sapphire Education and Training brings in experts and uses specialist material to support the work we do.


12.1 Where risk factors are present but there is no evidence of a particular risk then our DSO /SPOC advises us on preventative work that can be
done within the company to engage the learner/customer/service user into mainstream activities and social groups. The DSO may well be the person who talks to and has conversations with the person’s family, sharing the company’s concern about the young person’s vulnerability
and how the family and company can work together to reduce the risk.

12.2 In this situation, depending on how worried we are and what we agree with the parent and the young person (as far as possible):

  • The DSO/SPOC can decide to notify the local multi-agency Safeguarding Team of the decision so that a strategic overview can be maintained and any themes or common factors can be recognised; and
  • The company will review the situation after taking appropriate action to address the concerns.

12.3 The DSO/SPOC will also offer and seek advice about undertaking an early help assessment such as the Family Common Assessment Framework (fCAF) and/or making a referral to children’s social care. The local family support and the safeguarding team can assist us.

12.4 Regional Further Education/Higher Education Prevent Co-ordinators play a key role in the delivery of Prevent, providing further and higher education providers with support to build resilience against the dangers of radicalisation. We will actively work with coordinators in our area and attend regional Prevent update events.

Sapphire Education & Training Safeguard Reporting – Trusted Lines of Communication

Learner reports a concern or shares information deemed to be a safeguarding matter or low-level concern, 99% likely to report to their Teaching & Development Coach

Teaching & Development Coach – report to their Operations Manager

Operations Manager – report to DSL (Designated Safeguarding Lead). In DSL absence or if concern relates to DSL – report to Deputy DSL.

For any event, concerns direct from any stakeholder such as learner or from Teaching & Development Coach may be taken directly to DSL.

Key Positions for Safeguard Reporting

DSL – Jackie Adey – Quality Manager
Deputy DSL – Katrina Smith – Operations Manager
Operations Manager – Katrina Smith

Risk Register
Referrals are to be made to your Team Leaders who shall work with DSL to update & monitor risk register.


13.1 Where learners are 16-18, we will discuss any child protection concerns with parents/carers before approaching other agencies and will seek
their consent to making a referral to another agency. An appropriate employee will approach parents/carers after consultation with the Designated Safeguarding Officer. However, there may be occasions when the company will contact another agency before informing parents/carers because it considers that contacting them may increase the risk of significant harm to the child.


14.1 Where a learner/customer/service user is subject to an inter-agency child protection plan or a multi-agency risk assessment conference (MARAC) meeting, the company will contribute to the preparation, implementation and review of the plan as appropriate.


15.1 We will offer appropriate support to individual learners at risk or who have experienced abuse or who have abused others.

15.2 We will ensure the company works in partnership with parents/carers and other agencies as appropriate.


16.1 This procedure should be used in any case in which it is alleged that an employee, director, or visiting professional has:

  • Behaved in a way that has harmed a learner/customer/ adult or may have harmed a child;
  • Possibly committed a criminal offence against or related to a learner/customer/adult; or
  • Behaved in a way that indicates s/he is unsuitable to work with children or adults at risk.

16.2 Although it is an uncomfortable thought, it needs to be acknowledged that there is the potential for employees within the company to abuse
children or adults at risk.

16.3 All employees working within our organisation must report any potential safeguarding concerns about an individual’s behaviour towards
children and adults at risk immediately. Allegations or concerns about colleagues and visitors must be reported directly to the Designated
Safeguarding Officer unless the concern relates to the Designated Safeguarding Officer. If the concern relates to the Designated Safeguarding Officer, it must be reported immediately to the Managing Director.


17.1 Sapphire Education and Training recognises that while all children, young people and adults have a right to be safe, some young people and adults may be more vulnerable to abuse, for example, those with a disability or a special educational need, those living with domestic violence or drug/alcohol abusing parents/carers/partners, etc.


18.1 Guidance on learners/customers/service users in specific circumstances is in the local Safeguarding Board’s procedures as listed and is drawn up on as an example of best practice. All contact details for local advice should be directed to Designated Safeguarding Officer in the first instance.


Where a social worker is required Sapphire Education and Training will work with the Designated Social Worker to discuss relevant information that is held upon that individual.





Neglect is the persistent failure to meet an individual’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

  • Provide adequate food, clothing and shelter (including exclusion from home or abandonment).
  • Protect a child from physical and emotional harm or danger.
  • Ensure adequate supervision (including the use of inadequate caregivers); or
  • Ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, an individual’s basic emotional needs.

The following may be indicators of neglect (this is not designed to be used as a checklist):

  • Constant hunger;
  • Stealing, scavenging and/or hoarding food;
  • Frequent tiredness or listlessness;
  • Frequently dirty or unkempt;
  • Often poorly or inappropriately clad for the weather;
  • Poor school attendance or often late for school;
  • Poor concentration;
  • Affection or attention-seeking behaviour;
  • Illnesses or injuries that are left untreated;
  • Failure to achieve developmental milestones, for example, growth, weight;
  • Failure to develop intellectually or socially;
  • Responsibility for an activity that is not age appropriate such as cooking, ironing, or caring for siblings;
  • The child is regularly not collected or received from school; or
  • The child is left at home alone or with inappropriate carers.


Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to an individual. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in an individual.

The following may be indicators of physical abuse (this is not designed to be used as a checklist):

  • Multiple bruises in clusters, or of uniform shape;
  • Bruises that carry an imprint, such as a hand or a belt;
  • Bite marks;
  • Round burn marks;
  • Multiple burn marks and burns on unusual areas of the body such as the back, shoulders or buttocks;
  • An injury that is not consistent with the account given;
  • Changing or different accounts of how an injury occurred;
  • Bald patches;
  • Symptoms of drug or alcohol intoxication or poisoning;
  • Unaccountable covering of limbs, even in hot weather;
  • Fear of going home or parents being contacted;
  • Fear of medical help;
  • Fear of changing for PE;
  • Inexplicable fear of adults or over-compliance;
  • Violence or aggression towards others including bullying; or
  • Isolation from peers.


Sexual abuse involves forcing or enticing an individual to take part in sexual activities, not necessarily involving a high level of violence, whether or not the individual is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving individuals to look at, or in the production of, sexual images, watching sexual activities, encouraging individuals to behave in sexually inappropriate ways, or grooming an individual in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can children.

The following may be indicators of sexual abuse (this is not designed to be used as a checklist):

  • Sexually explicit play or behaviour or age-inappropriate knowledge;
  • Anal or vaginal discharge, soreness or scratching;
  • Reluctance to go home;
  • Inability to concentrate, tiredness;
  • Refusal to communicate;
  • Thrush, persistent complaints of stomach disorders or pains;
  • Eating disorders, for example, anorexia nervosa and bulimia;
  • Attention-seeking behaviour, self-mutilation, substance abuse;
  • Aggressive behaviour including sexual harassment or molestation;
  • Unusual compliance;
  • Regressive behaviour, enuresis, soiling;
  • Frequent or open masturbation, touching others inappropriately;
  • Depression, withdrawal, isolation from peer group;
  • Reluctance to undress for PE or swimming; or
  • Bruises or scratches in the genital area;
  • Non-consensual sharing of nudes and semi nudes.


Child sexual exploitation occurs when a child or young person, or another person, receives ‘something’ (for example food, accommodation, drugs, alcohol, cigarettes, affection, gifts, money) as a result of the child/young person performing sexual activities, or another person performing sexual
activities on the child/young person.

The presence of any significant indicator for sexual exploitation should trigger a referral to children’s social care. The significant indicators are:

  • Having a relationship of concern with a controlling adult or young person (this may involve physical and/or emotional abuse and/or
    gang activity);
  • Entering and/or leaving vehicles driven by unknown adults;
  • Possessing unexplained amounts of money, expensive clothes or
    other items;
  • Frequenting areas known for risky activities;
  • Being groomed or abused via the Internet and mobile technology; and
  • Having unexplained contact with hotels, taxi companies or fast food outlets.


Sexting is defined, for the purpose of this policy, as the sharing of sexual images created by a young person under 18, or another young person, of themselves. This includes both still and moving images. Any images created should not be viewed, copied, or reproduced in any form when investigating an allegation unless this is the only way to determine the facts of the case, in which case permission from DSO should be obtained. As with peer-on-peerabuse, the parents/carers of any young people involved should be informed of the allegation unless doing so would place them at risk of harm.

If the incident involves an adult or child under the age of 13, there is reason to believe that the young person has been coerced, blackmailed, or groomed, or is not able to give informed consent, the image has been shared without consent and with malicious intent. A referral to CYPS or the police should be made.


Upskirting is where someone takes a photograph under a person’s clothing without their knowledge and/or consent. The intention is to view the victims’ genitals or buttocks (with or without underwear) to gain sexual gratification or cause the victim humiliation, distress or alarm. It is a criminal offence in the UK. Anyone, of any gender, can be a victim.


Peer on peer abuse is abuse of one learner by another and may cover any aspect of safeguarding, including domestic abuse between learners aged under 18 and who are in a relationship. In allegations of peer-on-peer abuse the parents/carers of both learners should be informed (unless to do so wouldn place either at risk of harm) and a risk assessment should be carried out to determine the appropriateness of the alleged perpetrator remaining in centre whilst the matter is investigated.

Staff should be particularly vigilant to instances of sexual abuse and sexual harassment amongst learners and all instances should be treated seriously, and never dismissed as merely ‘banter’. Online bullying is a particular aspect of peer-on-peer abuse that staff need to be vigilant of, particularly with the move to on-line teaching.


County lines is the police term for urban gangs supplying drugs to suburban areas and market and coastal towns using dedicated mobile phone lines or ‘deal lines’. It involves child criminal exploitation (CCE) as gangs use children and vulnerable people to move drugs and money. Gangs establish a base in the market location, typically by taking over the homes of local vulnerable adults by force or coercion in a practice referred to as ‘cuckooing’. County lines is a major, cross-cutting issue involving drugs, violence, gangs, safeguarding, criminal and sexual exploitation, modern slavery, and missing persons.


Emotional abuse is the persistent emotional maltreatment of an individual such as to cause severe and persistent adverse effects on their emotional development. It may involve conveying that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the individual opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may also involve serious bullying (including cyberbullying), causing the individual to frequently feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment.

The following may be indicators of emotional abuse (this is not designed to be used as a checklist):

  • The child consistently describes him/herself in very negative ways – as stupid, naughty, hopeless, ugly;
  • Over-reaction to mistakes;
  • Delayed physical, mental or emotional development;
  • Sudden speech or sensory disorders;
  • Inappropriate emotional responses, fantasies;
  • Neurotic behaviour: rocking, banging head, regression, tics and twitches;
  • Self-harming, drug or solvent abuse;
  • Fear of parents being contacted;
  • Running away;
  • Compulsive stealing;
  • Appetite disorders – anorexia nervosa, bulimia; or
  • Soiling, smearing faeces, enuresis.

N.B.: Some situations where children stop communication suddenly (known as ‘traumatic mutism’) can indicate maltreatment.



Research and experience indicate that the following responses from parents may suggest a cause for concern across all four categories:

  • Delay in seeking treatment that is obviously needed;
  • Unawareness or denial of any injury, pain or loss of function (for example, a fractured limb);
  • Incompatible explanations offered, several different explanations or the child is said to have acted in a way that is inappropriate to her/his age and development;
  • Reluctance to give information or failure to mention other known relevant injuries;
  • Frequent presentation of minor injuries;
  • A persistently negative attitude towards the child;
  • Unrealistic expectations or constant complaints about the child;
  • Alcohol misuse or other drug/substance misuse;
  • Parents request removal of the child from home; or
  • Violence between adults in the household.


We understand that forcing a person into a marriage is a crime in England and Wales. We know that a forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some perpetrators use perceived cultural practices as a way to coerce a person into marriage. We play an important role in safeguarding children from forced marriage.

We will follow the Forced Marriage Unit published statutory guidance and multi-agency guidelines. Our staff can contact the Forced Marriage Unit if they need advice or information, contact: 020 7008 0151 or email



If a learner tells me about the abuse they have suffered, I must remember:

  • Stay calm.
  • Do not communicate shock, anger or embarrassment.
  • Reassure them. Tell them you are pleased that they are speaking to you.
  • Never enter into a pact of secrecy. Assure them that you will try to help but let them know that you will have to tell other people in order
    to do this. State who this will be and why.
  • Tell her/him that you believe them. People very rarely lie about abuse; but they may have tried to tell others and not been heard or believed.
  • Tell them that it is not their fault.
  • Encourage them to talk but do not ask ‘leading questions’ or press for information.
  • Listen and remember.
  • Check that you have understood correctly what they are trying to tell you.
  • Praise them for telling you. Communicate that they have done right to be safe and protected.
  • It is inappropriate to make any comments about the alleged offender.
  • Be aware that the individual may retract what they have told you. It is essential to record all you have heard.
  • At the end of the conversation, tell them again who you are going to tell and why that person or those people need to know.
  • As soon as you can afterwards, make a detailed record on CPOMs. Include any questions you may have asked. Do not add any opinions or interpretations.

NB It is not an employee’s role to seek disclosures. Their role is to observe that something may be wrong, ask about it, listen, be available and try to make time to talk.

Immediately Afterwards

You must not deal with this yourself. Clear indications or disclosure of abuse must be reported to children’s social care without delay, by the Designated Safeguarding Officer within Sapphire.



1. Inappropriate behaviour by an employee could take the following forms:

  • Physical | For example, the intentional use of force as a punishment, slapping, use of objects to hit with, throwing objects or rough physical handling.
  • Emotional | For example, intimidation, belittling, scapegoating, sarcasm, lack of respect for individual’s rights, and attitudes that discriminate on the grounds of race, gender, disability or sexuality.
  • SexualFor example, sexualised behaviour towards learners, sexual harassment, sexual assault and rape.
  • Neglect | For example, failing to act to protect an individual, failing to seek medical attention or failure to carry out an appropriate risk assessment.

2. If an individual makes an allegation about an employee, governor, visitor or volunteer the Designated Safeguarding Officer should be
informed immediately. The Designated Safeguarding Officer should carry out an urgent initial consideration in order to establish whether there is substance to the allegation. The Designated Safeguarding Officer should not carry out the investigation him/herself or interview learners.

3. The Designated Safeguarding Officer must exercise, and be accountable for, their professional judgement on the action to be taken, as follows:

  • If the actions of the employee, and the consequences of the actions, raise credible safeguarding concerns the Designated Safeguarding Officer will notify the Local Authority Designated Officer (LADO) Team. The LADO Team will advise about action to be taken and may initiate internal referrals within children’s/adults’ social care to address the needs of children/young people/adults likely to have been affected.
  • If the actions of the employee, and the consequences of the actions, do not raise credible safeguarding concerns, but do raise other issues in relation to the conduct of the employee or the learner(s)/customer(s)/service user(s), these should be addressed through the company’s own internal procedures.
  • If the Designated Safeguarding Officer in liaison with HR decides that the allegation is without foundation and no further formal action
    is necessary, all those involved should be informed of this conclusion, and the reasons for the decision should be recorded on the child and adult at risk protection file.

4. Where an allegation has been made against the Managing Director, then the Quality Manger takes on the role of liaising with the LADO team in determining the appropriate way forward.



1. Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.

2. Extremism is defined by the Government in the Prevent Strategy as:
Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.

3. Extremism is defined by the Crown Prosecution Service as:
The demonstration of unacceptable behaviour by using any means or medium to express views which:

  • Encourage, justify or glorify terrorist violence in furtherance of particular beliefs;
  • Seek to provoke others to terrorist acts;
  • Encourage other serious criminal activity or seek to provoke others to serious criminal acts; or
  • Foster hatred which might lead to inter-community violence in the UK.

4. There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and
experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.

5. Learners/customers/service users may become susceptible to radicalisation through a range of social, personal and environmental factors – it is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and
communities. It is vital that Sapphire Education and Training’s employees are able to recognise those vulnerabilities.

6. Indicators of vulnerability include:

  • Identity crisis – the individual is distanced from their cultural/religious heritage and experiences discomfort about their place in society;
  • Personal crisis – the individual may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging;
  • Personal circumstances – migration; local community tensions; and events affecting the learner/customer/service user’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;
  • Unmet aspirations – the learner/customer/service user may have perceptions of injustice; a feeling of failure; rejection of civic life;
  • Experiences of criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement/reintegration;
  • Special educational needs – learner/customer/service user may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.

7. However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the
purposes of violent extremism.

8. More critical risk factors could include:

  • Being in contact with extremist recruiters;
  • Accessing violent extremist websites, especially those with a social networking element;
  • Possessing or accessing violent extremist literature;
  • Using extremist narratives and a global ideology to explain personal disadvantage;
  • Justifying the use of violence to solve societal issues;
  • Joining or seeking to join extremist organisations; and
  • Significant changes to appearance and / or behaviour;
  • Experiencing a high level of social isolation resulting in issues of identity crisis and/or personal crisis.



The SPOC for Sapphire Education and Training is Jackie Adey, who is responsible for:

  • Ensuring that employees of the company are aware that you are the SPOC in relation to protecting learners from radicalisation and involvement in terrorism;
  • Maintaining and applying a good understanding of the relevant guidance in relation to preventing learner/customer/service user from
    becoming involved in terrorism, and protecting them from radicalisation by those who support terrorism or forms of extremism which lead to terrorism;
  • Raising awareness about the role and responsibilities of Sapphire Education and Training in relation to protecting learner/customer/service user from radicalisation and involvement in terrorism;
  • Monitoring the effect in practice of the curriculum and policies to ensure that they are used to promote community cohesion and tolerance of different faiths and beliefs;
  • Acting as the first point of contact within the company for case discussions relating to learner/customer/service users who may be at
    risk of radicalisation or involved in terrorism;
  • Collating relevant information from in relation to referrals of vulnerable learners into the Channel* process;
  • Attending Channel* meetings as necessary and carrying out any actions as agreed;
  • Reporting progress on actions to the Channel* Co-ordinator; and
  • Sharing any relevant additional information in a timely manner.
  • Channel is a multi-agency approach to provide support to individuals who are at risk of being drawn into terrorist related activity. It is led by the West Midlands Police Counter-Terrorism Unit, and it aims to establish an effective multi-agency referral and intervention process to
    identify vulnerable individuals;
  • Safeguard individuals who might be vulnerable to being radicalised, so that they are not at risk of being drawn into terrorist-related activity; and
  • Provide early intervention to protect and divert people away from the risks they face and reduce vulnerability.
  • Communicating with the Prevent FEHE co-ordinator as a first point of call for all queries relating to the further and higher education sectors.



The Act

The Counter-Terrorism and Security Act contains powers to help the UK respond to the threat of terrorism. It received Royal Assent on 12 February
2015. The act will:

  • Disrupt the ability of people to travel abroad to engage in terrorist activity and then return to the UK;
  • Enhance the ability of operational agencies to monitor and control the actions of those who pose a threat;
  • Combat the underlying ideology that feeds, supports and sanctions terrorism;
  • Give the police power to temporarily seize a passport at the border, so that they can investigate the individual;
  • Create a Temporary Exclusion Order that can temporarily disrupt a British citizen suspected of involvement in terrorist activity abroad from returning to the UK (so that when individuals do return, it is done in a manner which we control);
  • Place strong restrictions on where individuals can go, and require them to attend meetings as part of their ongoing management (e.g. with the probation service or JobCentre Plus employees);
  • Improve law enforcement agencies’ ability to find out who is responsible for sending internet communications accessing an internet communications service;
  • Eenhance our aviation, maritime and rail border security, with provisions relating to passenger data, ‘no fly’ lists, and security and screening measures;
  • Ensure that UK-based insurance firms cannot reimburse the payment of terrorist ransoms;
  • Clarify the scope of power to examine goods at (or near) ports;
  • Provide a general duty on a range of organisations to prevent people being drawn into terrorism;
  • Put Channel (the government’s voluntary programme for people vulnerable to being drawn into terrorism) on a statutory basis.


Sexual Abuse by Young People

The boundary between what is abusive and what is part of normal childhood or youthful experimentation can be blurred. The determination of whether behaviour is developmental, inappropriate or abusive will hinge around the related concepts of true consent, power imbalance and exploitation. This may include children and young people who exhibit a range of sexually problematic behaviour such as indecent exposure, obscene telephone calls, fetishism, bestiality and sexual abuse against adults, peers or children.

Developmental sexual activity encompasses those actions that are to be expected from children and young people as they move from infancy through to an adult understanding of their physical, emotional and behavioural relationships with each other. Such sexual activity is essentially information gathering and experience testing. It is characterised by mutuality and of the seeking of consent.

Inappropriate sexual behaviour can be inappropriate socially, in appropriate to development, or both. In considering whether behaviour fits into this category, it is important to consider what negative effects it has on any of the parties involved and what concerns it raises about a child or young person. It should be recognised that some actions may be motivated by information seeking, but still cause significant upset, confusion, worry, physical damage, etc. It may also be that the behaviour is “acting out” which may derive from other sexual situations to which the child or young person has been exposed. If an act appears to have been inappropriate, there may still be a need for some form of behaviour management or intervention. For some children, educative inputs may be enough to address the behaviour.


Abusive sexual activity included any behaviour involving coercion, threats, aggression together with secrecy, or where one participant relies on an
unequal power base. In order to more fully determine the nature of the incident the following factors should be given consideration. The presence of exploitation in terms of:
– Equality – consider differentials of physical, cognitive, and emotional development, power and control and authority, passive and assertive
– Consent – agreement including all the following:
• Understanding that is proposed based on age, maturity, development level, functioning and experience;
• Knowledge of society’s standards for what is being proposed;
• Awareness of potential consequences and alternatives;
• Assumption that agreements or disagreements will be respected equally;
• Voluntary decision;
• Mental competence.
– Coercion – the young perpetrator who abuses may use techniques like bribing, manipulation and emotional threats of secondary gains and losses that is loss of love, friendship, etc. Some may use physical force, brutality or the threat of these regardless of victim resistance.

In evaluating sexual behaviour of children and young people, the above information should be used only as a guide.


Children missing in Education

– A child is defined as anyone under the age of 18.

– An adult at risk (previously vulnerable adult) is defined as any person over the age of 18 and at risk of abuse or neglect because of their need for support or personal circumstance. For example:
• Living in sheltered housing;
• Receiving any form of health care;
• Receiving a welfare service in order to support their need to live independently;
• Receiving a service due to their age or disability;
• Living in residential accommodation such as a care home;
• Receiving domiciliary care in their own home;
• Expectant or nursing mother living in residential care;
• Person under supervision of probation service;

While the definitions of a child and adult at risk give the rationale for legislative intervention, it is important to note that a person may be deemed at higher risk of a safeguarding issue affecting them due to other factors, for example:
• Poor numeracy and literacy skills, or specific learning need;
• Unsupportive home environment;
• English not a first language;
• Unsupportive employer;
• Underrepresented group;
• Acting as a carer for another family member;
• Background in offending;
• Disability or social need.


keeping safe


To maintain yours and the learner’s/apprentice’s safety, the following are
strictly prohibited:

  • Befriending learners on personal social media sites;
  • Distributing personal telephone numbers;
  • Visiting learners at home or transporting learners to and from locations (this includes travelling in the car with a learner/apprentice driving);
  • Do not use sarcasm, insults, or belittling comments towards learners;
  • Personal relationships with learners

It is also important to be mindful of the following when conducting yourself:

  • Locations of one-to-one meetings with colleagues. These should take place at a neutral location;
  • Be respectful of all young and vulnerable people, and appreciate you are in a position of trust. We have the opportunity to listen to their concerns and support them;
  • Uphold confidentiality within certain remits when required by the situation but be careful not to promise to keep secrets or ask others to do so;
  • Avoid spending time alone with learners in a closed environment. If this is unavoidable for example during a formal assessment/examination, ensure a member of the site staff is aware of where you are and monitors this;
  • Be careful when giving learner/apprentice advice – as this is based on your opinion, focus support on information (facts) and guidance (signposting);
  • Do not use personal communication devices & platforms (mobile phones, laptops, social media etc) to communicate with learners.
  • Be mindful of any learners you acquire that by default creates a conflict of interest i.e. a partner or friend becomes a learner. Discuss
    appropriateness/alternative ASSESSOR arrangements with your Line Manager;
  • If a learner offers you gifts of any sort because of the support through their programme, please refer to the bribery policy for the process to follow;
  • If at any point you feel unsafe in a learners company inform the Site Manager, your Line Manager, the Designated Safeguarding Officer and leave the premises.


Learners are made aware of all of Sapphire Education and Training’s relevant policies, who the designated persons are and how to report a concern. All safeguarding concerns are recorded by the Lead Designated Safeguarding Officer, appropriate action is taken, and information, advice and guidance are given.