Safeguarding Policy Download PDF

The UK College of English provides English Language training in our Liverpool Street centre. Our safeguarding policy matches the needs of this centre (and possible future centres) while always acting in the best interests of the vulnerable person, whatever their individual circumstances. This policy has been updated according to government guidance from “Keeping Children Safe in Education 2024”, “Working Together to Safeguard Children”, DFE (2023) and Tri-Borough Local Safeguarding Children Board Procedure

Minimum age: 14 for closed groups; 16+ for mixed groups Age range: mostly 18 – 40, however we take students as young as 12 years old when they are studying as part of a group because they have a group leader with them. We accept the presence of the children of group leaders on site where the GL is solely responsible for their safeguarding. We don’t actively recruit under 14 years old for our closed group courses. Under-18s are mostly only taught as part of a closed group but we do occasionally take 16+ students in the adult classes throughout the year. Accommodation: Homestay, residential

UKCE is part of a bigger organisation called UK College of Business and Computing which is a higher education institution for adult students. UKCBC also operates in the above premises along with UKCE. UKCBC and UKCE work together to safeguard all U18 and vulnerable adult students at the campus and all staff have regular training for Safeguarding and Prevent. To keep children safe on the campus we ask that group leaders stay in the building at all times during the students’ lessons and any students under 16 years old are accompanied by either a GL or a teacher when going to the toilets. Further to this, the Safeguarding Lead creates a risk assessment for each individual group to determine and combat any risks for each group before they arrive

“Safeguarding” refers to the systems that help us to protect students that are under 18 or vulnerable. These include child protection, welfare, accommodation, abusive behaviour policies, fire, and health and safety policies as relevant.

“U18s” refers to “under 18s”

“Vulnerable” refers to all students who are away from their home country and subject to the negative emotions that this entails. U18s are considered automatically to be vulnerable.

“All adults” refers to those adults who are in contact with U18s and vulnerable students while working for or with UKCE.

“Designated safeguarding lead” or “DSL” refers to the named person who formulates and updates the safeguarding policy for UKCE.

“Designated safeguarding Deputy” or “DSD” refers to the named person who formulates and updates the safeguarding policy for UKCE in the absence of the DSL.

“Designated safeguarding staff” or “DSS” refers to the multiple people who implement the safeguarding policy for the College.

Students should remain aware of the policy through induction, information provided in handbooks and on notices and by abiding to the codes of conduct.

All adults are expected to remain aware of this policy, share our commitment to safeguarding, be ready to report concerns and be aware of the designated safeguarding staff and lead. Staff are required to attend Level 1 Safeguarding training.

Required to formulate and update the safeguarding policy and to implement it through training for staff, especially the DSS. DSL is required to have Specialist Safeguarding for Designated Lead Safeguarding Training – formerly known as Level 3 and to establish contact with the relevant local authorities

DSL Key Role:

• Monitor and update Safeguarding Policy and other related documents,
• Supports and advises staff and all DSS in day-to-day implementation of policies,
• Ensure staff are trained and inductions conveys all safeguarding responsibilities,
• Receives and records all information from any staff members, children, Group
• Leaders, or parents who have any safeguarding concerns,
• Makes a formal referral to a statutory child safeguarding agency or the Police

Designated Safeguarding Staff

Required to be visible and named points of contact with (formerly) Level 2 safeguarding training, and to be prepared to bypass the DSL should the need arise. Required to attend safeguarding meetings to remain aware of student situations and updates to the policy.

Liverpool Street
Keyla Ferreira Reyes (DSL)
Lorena Calderon (DSD)
Patrick Allen (Level 3)
Aneta Czajka (Level 2)

Laura Villa (Level 2) – remote working

Updated annually (or more often as required) and available on the website.

All staff undertake a Basic Awareness online training course in Safeguarding and Prevent Duty. All staff have an induction giving further school specific safeguarding information.

All students receive information during their induction, in their Student Handbooks and displayed in the classrooms with easy-to-understand information on who to speak to and what they can do if they feel threatened, bullied or uncomfortable in anyway.

The DSL for Liverpool Street is in contact with the LADO and lead advisor for City of London.

There are a number of associated procedural documents, including the condensed version of this policy for all adults including homestay hosts, group leaders, teachers and activity leaders.

The safeguarding policy is updated annually (or more often as required) and new training is offered where relevant. Some elements of safeguarding policy are incorporated into class so that students can have input into the formulation of future policies. Last updated January 2026

1. Staff are in a ‘Position of Trust’ concerning their students. This makes any sexual activity with students aged under 18 illegal, according to the Sexual Offences Act 2003.

2. All adults must observe the rules of appropriate behaviour with U18s. This includes but is not limited to: avoiding favouritism, the avoidance of inappropriate references to sex and drugs in class, management of other students to do likewise, and the avoidance of unnecessary physical contact with U18s. It is paramount to maintain a demeanour of friendly but professional neutrality with U18s.

3. Private contact with under 18s, outside of the bounds of the school, whether in person, by phone or by private social media is forbidden. Respect for GDPR legislation (i.e. security) should be taken into account when handling personal data, such as personal phone numbers on a school phone.

4. Staff have a duty to report concerns where U18s are displaying signs that might indicate abuse or neglect, as discussed in safeguarding training. These can either be witnessed by or reported to a staff member. Please request a refresher if these signs have been forgotten.

5. Staff should be aware that UKCE has a Whistleblowing Policy to protect them if they report concerns. The NSPCC Whistleblowing Helpline, 0800 028 0285, can provide impartial assistance.

6. Guidance about the potential dangers of social media should be offered as appropriate, and relevant behaviour with host families should be incorporated into class whenever possible.

7. Homestay hosts should respect privacy by knocking on bedroom and bathroom doors before entering.

The following information forms the basis of our safeguarding training for staff. Signs of the various types of abuse will be treated as causes of concern to be reported.

An allegation of abuse

This consists of Information which indicates a person may have:

• behaved in a way that has harmed a child
• committed a criminal offence against or related to a child
• behaved towards a child in such a way that indicates s/he/they would pose a risk of harm if working closely or regularly with a child

This is defined as showing interest in and / or forming an attachment with a young person with the ultimate aim of sexual gratification.

Abusers may also seek to gain the trust of other adults so that they are allowed to be in situations where they have access to potential victims. Grooming of under 18s constitutes a criminal offence

This is defined as forcing or enticing a young person to take part in sexual activities. If the person is under age, such attention constitutes sexual abuse, even if the victim is willing. The abuser may sometimes be based in a different country to their victim and may use the internet to contact them.

There is also a high incidence of teens abusing other teens e.g. by befriending / loving and then turning on their victim.

How to spot someone who may potentially have been sexually abused The person may behave inappropriately e.g. sexualised play or awareness (drawings / promiscuous behaviour) or by being over- needy and attention-seeking.

“Low-level” incidents should still be taken seriously, recorded and actioned as appropriate.

Here too, the victim may behave in an over-needy, attention-seeking way. This type of abuse is often persistent, for example in bullying, and may be compounded by the abuser making the victim wary of authority or other adults trying to help them. Victims of emotional abuse may exhibit both aggression and withdrawal within a short space of time. Emotional abuse is sometimes linked to conditions such as anorexia and selfharming.

This is potentially the most dangerous as the victim may die as a result of the abuse

How to spot physical abuse

Bruising - Symmetry (2 black eyes/bruising on both shoulders) indicates possible abuse Burns or scalds – A clear edge indicates possible abuse

Finger marks - An inability to explain the presence of these in a plausible way indicates possible abuse.

MSP (Munchhausen Syndrome by Proxy) – This involves fabricating, exaggerating, or inducing mental or physical health problems in another person, often a child, in order to gain attention or sympathy for themselves from others.

FGM (Female Genital Mutilation) this is illegal in the UK and suspected cases should be reported to the police as well as DSS.

This may occur in all levels of society as it includes actions such as leaving a child unattended or ignoring their physical and medical needs. U18s may also ‘self-neglect’ if it is their first time away from home and their parents. This should also be reported as appropriate

How to spot neglect

The child may thrive away from their home environment. They may be unused to supervision and be unable to recognise boundaries of acceptable behaviour, possibly resulting in very aggressive or anti-social behaviour.

These are often seen in teenage abusive relationships where one partner dominates the other in a range of ways, e.g. forced sexual activity, repeated insults and put downs, stopping a partner from seeing friends/family, checking on their partner all the time (texts/social media etc.), using physical violence, taking money, forcing their partner to work, controlling what their partner wears.

The dominant partner makes the other feel subordinate and deprives them of the means to be independent. Typical behaviours include threats, humiliation and intimidation to harm and punish their victim.

These behaviours are often evident in 'honour' based violence (HBV), female genital mutilation (FGM) and forced marriage.

Abuse is not only done by adults against children. Under 18s, notably teens, abuse their peers. This can be demonstrated through gang violence or gender-based violence – particularly against girls, hate and revenge crimes, bullying in all its forms are often done by peers to each other.

All children are vulnerable to abuse, but some may be more at risk than others. This may include but is not limited to;

• Students with special education needs (SEN)
• Students that have a disability
• LGBTQ+ students who face the risk of persecution from other students
• Students who are the only ones from a particular country and have no one to speak with in their mother tongue.

The responsibility to disclose an allegation or suspicion of abuse to the DSS immediately is not only a duty of UKCE staff but a legal requirement. All suspicions or allegations of abuse must be taken seriously.

If a staff member has suspicions of any abuse, they should alert one of the DSS as soon as possible. If an under 18 starts to talk to the staff member directly, they should allow that person to disclose and should allow them to continue talking following the guidelines below. They should then see the DSL in confidence.

Receive

Listen to what is being said in a semiprivate area without displaying shock or disbelief. A common reaction to news as unpleasant and shocking as child abuse is denial. However, if one displays denial to a child, or shows shock or disgust at what they are saying, the child may be afraid to continue and will shut down.

Accept what is being said without judgement and take it seriously.

Reassure

Reassure the child, but only so far as is honest and reliable. Do not promise confidentiality and never agree to keep secrets as there is a duty to report such concerns. Reassure the child that they did nothing wrong. Explain to the child that some people, whose job it is to protect children, will need to be told. Acknowledge how difficult it must have been to talk. It takes a lot for a child to come forward about abuse.

React

Listen quietly, carefully and patiently. Do not assume anything – do not speculate or jump to conclusions. Do not investigate, interrogate or decide if the child is telling the truth. An allegation of child abuse may lead to a criminal investigation, so do not do anything that may jeopardise the child’s trust or a possible police investigation. Let the child explain in his/her/their own words what happened, but do not ask leading questions. Do ask open questions such as “Is there anything else that you want to tell me?"

Communicate with the child in a way that is appropriate to their age, understanding and preference. This is especially important for children with disabilities and for children whose preferred language is not English. Do not ask the child to repeat what they have said to another staff member. Explain what has to be done next and with whom you have to talk in order to help resolve the matter.

The following table outlines the DOs and DON’Ts when dealing with a disclosure, including some useful phrases:

Refer directly to the one of the DSS as set out above. Once the DSL is involved, they will liaise with the City of London Safeguarding Children Partnership to determine the correct course of action. This would be done where it is believed:

• there is a risk of significant harm to the student
• risk of harm to others
• a criminal act has taken place
• the student is at immediate risk or danger

Where the DSL decides that further action is necessary, this may be to:

• seek further advice from Social Services
• make a referral to Social Services
• report the incident to a designated Social Worker
• report the matter to the Police if a crime is suspected

Do not discuss the case with anyone outside the DSS.

If the DSL is accused, the DSS will contact Children’s Services for the City of London directly and follow their directions

If another U18 is accused, a member of DSS will be assigned to support the accused in addition to the accuser.

Record

Make brief notes at the time and write them up in detail as soon as possible. Do not destroy any original notes in case they are required by Court.

Record the date, time, place, words used by the child and how the child appeared, be specific. Record the actual words used, including any foul language or slang.

Record factual statements and observable things. Once the report has been completed, these records must be kept confidential, as hard copies which are securely stored.

UKCE understands its responsibilities under the Counter Terrorism & Securities Act 2015 to prevent people of all ages being radicalised or drawn into terrorism and seeks to meet its obligations following its policies and procedures.

PREVENT training is considered part of safeguarding and so concerns about radicalisation would also be reported. All Academic staff and teachers have received training in this. Furthermore, the DSL has established contact with the local PREVENT police officer.

Radicalisation is defined as the act or process of making a person more radical or favouring of extreme or fundamental changes in political, economic, or social conditions, institutions or habits of the mind.

Extremism may refer to elements such as racism, homophobia, right-wing ideology and religious extremism.

At UKCE, our aim is to provide vulnerable students of any age, faith, ethnicity or background with support to prevent them being exploited by pro-terrorism organisations and engaging in terrorist activity themselves.

Terrorist material could include:

• articles, images, speeches or videos that promote terrorism
• content encouraging people to commit acts of terrorism
• websites made by terrorist organisations
• videos of terrorist attacks
• messages intended to stir up hatred against any religious or ethnic group.
• bomb-making instructions

It is the DSL’s responsibility to ensure that all adults have training as appropriate. Level 1 Basic Awareness applies to homestay hosts, teaching staff and group leaders (through the use of group leader agreements).

Level 2 Advanced Safeguarding applies to members of the DSS.

Level 3 Specialist Safeguarding Training applies to the DSL.

Initial

Level 1 Training is conducted in conjunction with the signing of the condensed safeguarding policy and code of conduct at induction

Level 2 Training is conducted externally either face-to-face or online, according to availability.

Level 3 Training is conducted externally either face-to-face or online, according to availability.

Refresher

Level 1 refresher training occurs annually within the TD schedule for staff and during UKCE inspections for homestay hosts.

Level 2 and 3 refresher training occurs every 2 years or after changes in the legislation.

Training is recorded by the collection of certificates, both internal and external.

When students who are under 18 arrive in the UK for the first time for our courses, we make it our responsibility to make sure they arrive and depart safely. When booking a course with us parents must complete, in full, the appropriate consent form with the student’s details, including any medical issues and emergency contact details. It also states if they are staying with a guardian (authorised by their parents) or in homestay accommodation.

At the end of every week one of our Office staff makes sure we have the consent forms for any under-18 student groups arriving the following week.

If they are staying in homestay accommodation then they are obliged to book this through our agencies, this is so we can guarantee their safety through our accommodation agencies which DBS check all their homestay hosts. If they book an airport transfer, then the drivers will walk the under-18 student to and from the entrance of their accommodation or airport.

At induction the staff member will enquire with the student or Group Leaders about any U18 students’ accommodation and make sure that they are happy with where they are staying. They then fill out a ‘confirmation of advice’ form, notifying us that they know their way to and from school and know the internet misuse rules.

One of the Academic Team or Welfare Officers then meet with the U18 or Group Leaders regularly to ensure the students are still happy with their accommodation and course/class

Risk assessments are used to consider the risks that are posed to vulnerable students along with actions to address these. They are used for U18 students in closed groups and all students on excursions.

Responsibility for producing them lies with the DSL (especially for more stable, ongoing standards). They are also produced ‘live’ by DSS on an ongoing basis for excursions and the relevant members of staff who are taking the students out sign their agreement to these. The actions in these live risk assessments include informing students of relevant precautions.

he following ratios of adults to U18s are observed:

In case of irregularity, such as parents visiting and taking students under their own supervision for some portion of their stay, this is recorded with relevant actions on the excursion risk assessment form.

All students are given a handbook before arrival which highlights relevant information including local laws, healthcare providers and advice about life in London. Specific precautions for U18s are also advised during the induction, including checking that students are aware and happy with their route to and from the College. Induction includes the naming of the office staff and safeguarding team as points of contact.

All teachers are told about our concern reporting system, which is a matter of telling the DSS about a concern below the level of disclosure with an emphasis on erring on the side of caution. The DSS take a note of such concerns and decide on appropriate follow-up actions and keep the reports securely.

Group Leaders are also inducted and made aware of precautions taken for their students and their involvement in keeping the children safe.

A phone line is provided for the students and printed on their student ID badges. A lanyard system identifies U18s with red lanyards, staff with dark blue, adult students with turquoise and visitors with yellow. Staggered breaks are set for groups, to avoid overcrowding and unnecessary contact between adults and U18s. Also, any under-16s are not allowed to go to the bathroom on their own and must be accompanied by either an adult or a member of staff. Student classes, which are part of a group are kept on a separate floor from the adult classes and Group Leaders are asked to stay close by to these classrooms so that they are on hand if students need them.

Parents are directed to our safeguarding procedures in summary and in detailed form, and they are required to check and agree to the level of safeguarding provision UKCE provides.

When completing parental consent forms, the parents provide their details (with two separate numbers) to allow them to be contacted. This would not be the first recourse as other points of contact include the host family, the group leaders and the students themselves with numbers that have been collected and kept secure but accessible.

We adjust curfew times according to circumstances raised by risk assessments and these are updated on the website.

We provide a parental consent form for every student who is under 18 enrolling at UKCE. In this Consent form the parents/guardians must sign a document claiming that their child is of sufficient maturity to look after themselves for the duration of their course when not supervised by an adult. This form also states that if needed they are sufficiently mature enough to administer their own medication.

On Campus, we have first aid trained staff available at all times, however, they are not allowed to administer any medication to the students unless the student is incapacitated, and they need help.

We provide further medical information for all students, including under 18s, in our Student Handbook about the NHS; medical, dentistry and opticians.

As part of their training, all staff are made familiar with the UKCE Emergency Event Procedure. In addition, all staff, students, and group leaders are encouraged to download the Citizen Aid Application on their phones as this provides live, relevant updates in the event of an emergency situation.

It is essential that children are safeguarded from potentially harmful and inappropriate online material. We at UKCE aim to educate students and staff in their use of technology and establish mechanisms to identify, intervene in, and escalate any concerns where appropriate. We have a filtering and monitoring system in place on our computers at the College that blocks certain websites or searches to ensure the safety of our students and monitor their online habits where necessary. More information can be found in our IT Policy.

Safeguarding remains as important when teaching online as when teaching in class lessons. Teachers should familiarise themselves with UKCE Safeguarding Policy before commencing the teaching online. The points below are to be used in accordance with our Safeguarding Policy.

Working via Zoom or any other online audio-visual applications does raise some additional safeguarding issues to consider.

Safeguarding Policy for online classes:

• We will send an agreement to the parents/guardians for teaching their child online through Survey Monkey and attach it to their records.
• The teacher will send the Parent/Guardian an invitation to the online lesson if they wish to join the class, they do not have to if they do not wish.
• Lessons must not be recorded unless authorised in advance by Academic Management and with written parental consent (for U18s). Any authorised recordings must be stored securely in line with GDPR.
• The teacher must enable the waiting room function and admit only authorised participants. The lesson should be locked once all expected students have joined.
• An Academic Manager may observe the lesson at any time (without interruption to the lesson), for both the teachers and the child’s sake.
• The teacher will use a separate professional online account for their online lessons rather than their personal one.
• The teacher will make sure that they select appropriate images for their profile picture and do not share ANY personal information e.g. Phone number, email address, or any social media profiles.
• The teacher will maintain the usual Safeguarding policy, using appropriate material in their online lessons. The teacher will be professional when delivering the lessons and always present themselves as they would at the regular sessions.
• The teacher will test their set up before going live. Check that the camera/mic is working properly, ensure the camera position is optimum for teaching and ensure that they are against a neutral background.
• Appropriate attire for work and lanyards are to be worn at all times.
• The student must take lessons in a room with an open door and a parent/guardian should be in the same premises whilst the lesson takes place.
• Communication between student and teacher can be via a professional email address or through the Google classroom, Teams or an online application for their classes.

All student rooms are to be checked against the following criteria:

• Acceptable cleanliness
• Furniture and fittings
• Introduction of prohibited items
• Damage, misuse or loss of fire detection and fire-fighting equipment
• A representative will visit all accommodation provided to ensure that they meet the standards of the British Council prior to placing students.
• Accommodation providers are required to have an enhanced Disclosure and Barring Service (DBS) Certificate should they accommodate students under the age of 18.
• Accommodation providers are required to create student registers that are to be regularly monitored to ensure it is current and accurate.
• Accommodation providers are to be gas safety certified.
• Accommodation provided is fitted with smoke alarms that are in working order.
• Accommodation providers will not accommodate two students with the same first language unless unavoidable or specifically requested, in writing, by the students, UKCE, legal guardians/ agency representatives.
• Accommodation providers will ensure that under no circumstances will children be placed in the same room as an adult. Children sharing a room will be of the same gender.

Accommodation providers are required to provide the following for students:

• A sufficiently spacious bedroom with natural light, equipped with a single or double bed
• A towel and bed linen which will be changed in a weekly basis and an adequate supply of duvets or blankets
• An adequately sized mirror
• A wardrobe or drawer space
• Facilities for a daily shower
• A desk and a chair or study space at the accommodation, where available
• Adequate heating and lighting
• Privacy from members of the opposite sex
• Access to washing and ironing facilities or a weekly laundry service, especially in the case of under 16s

The regulations that govern homestay accommodation are as follows:

• UKCE homestay accommodation providers will accept students into their home as temporary members of the household.
• Students will eat and live with their homestay accommodation providers and students will be given access to the property.
• The household must ensure a comfortable living environment.
• There will be an adult at the homestay accommodation to receive students on their arrival and overnight when students under the age of 16 are present.
• No student under the age of 18 will be accommodated with a student or person aged 18 or older.
• No more than four students will be accommodated in one homestay accommodation at any one time.
• No more than two students will be accommodated in the same bedroom unless specifically requested in writing by UKCE, the students, their agency representatives, or parents/legal guardians.
• English will be the language of communication within the homestay home.
• Contact names and telephone for UKCE and homestay accommodation providers will be given to students and their legal guardians/ agency representatives for use in cases of emergency.
• Host family providers will ensure that under no circumstances will children be placed in the same room as an adult. Children sharing a room will be of the same gender.

Both of our two residential accommodation agencies are registered with British Council (Britannia and Host International) and adhere to these rules:

• Students are able to pick between different options for their stay. These include single room, twin room, and ensuite room or studio rooms.
• If the student chooses these residences can be catered; apart from the studio rooms which cannot be catered.
• There is always a member of staff from the agency that looks after the residences and will monitor those students that are under 18 unless Group Leaders are there to take responsibility. These members of staff are DBS checked through the agency.
• Under-18 students booking residences are always catered for.
• The agency will also ask any students arriving that are under 18 to provide a parental consent form before their arrival. They also have their own parental consent forms if the ones the students offer are insufficient.

Safer recruitment is the cornerstone of UKCE’s safeguarding strategy, with the aim of serving the best interests of vulnerable students by not employing those with a history of harming the vulnerable and discouraging applications from them.

The Head of Academic Delivery holds a Safer Recruitment certificate to show they have completed an online Safer Recruitment training and assessment.

Stages

To discourage unsafe applications, the principles of safer recruitment (i.e. DBS checks, references, proof of identity and address) is alluded to in the advertising and job description, is incorporated in the interview and then fulfilled before adults are allowed to work with U18s.

Obtaining criminal record checks for

I. when a new DBS is required

UKCE obtain permission to run enhanced DBS upon passing interview. While awaiting DBS, UKCE run a barred list check as a minimum, and do not allow unsupervised access to U18s. The teacher is asked to complete a declaration about the main questions answered by the DBS, with the understanding that inaccuracy will lead to dismissal.

Two references are checked prior to start with a question about suitability for work with under 18s.

II. when a teacher has an existing DBS from elsewhere

This is checked on the update system. If the teacher is not on the update system, they are asked to join.

III. renewal for active employees

DBS is checked annually via the update system and UKCE hold a DBS records database.

IV. When a teacher is pending a DBS but through the needs of the company the teacher may have to teach a class

If a teacher or staff member has a DBS pending but needs to teach a class, then the Academic Team/line manager will run a Basic DBS for the teacher to make sure there are no immediate things to be aware of. The teacher/staff member then has to wear a yellow lanyard to show they are not a fully inducted yet. The Academic Team will try their best to not place that teacher in any classes involving U18s, but if necessary then they will be either observed or leave the door open to the classroom, so that a member of staff can check on them regularly. They will also only use the toilet on the 5th floor to avoid any U18 students in the building. The Academic Team/line manager will then ensure these restrictions are carried out before they receive their Enhanced DBS and a risk assessment is signed to make sure the teacher/staff member understands.

I. new

We adhere to the following procedures, either though accommodation agencies or ourselves:

-Homestays hosts cannot be used if DBS has not yet been received. UKCE obtain permission to run enhanced DBS upon passing interview. This interview also tries to ascertain suitability for working with U18s.

-Two references (called ‘recommendations’ and can be done by non-family members) are checked prior to start with a question about suitability for work with under 18s.

-Other adults that regularly spend time in the house are subject to a basic DBS check.

II. when a homestay host has an existing DBS from elsewhere

This is checked on the update system. If the host is not on the update system, they are asked to join by renewing their DBS.

III. renewal for returning hosts

DBS is checked annually via the update system.

IV. Agency

Homestays hosts that work through an agency undergo relevant checks through the agency’s accreditation.

I. when a new DBS is required

UKCE obtain permission to run enhanced DBS upon passing interview. While awaiting DBS, UKCE run a barred list check as a minimum, and do not allow unsupervised access to U18s.

Two references are checked prior to start with a question about suitability for work with under 18s.

II. when a leader has an existing DBS from elsewhere

This is checked on the update system. If the leader is not on the update system, they are asked to join.

III. renewal for returning employees

DBS is checked annually via the update system.

Transfers are completed through companies that have completed DBS checks on their drivers.

Relevant checks are completed according to guidance downloaded from the government website. Where these have not been provided, as with group leaders who are not contracted as staff, a declaration is requested.

A decision is made according to Employment of Ex-Offenders policy by considering the nature, seriousness, relevance and time since the offence. The decision is made by more than one person and recorded.

This code of conduct is conveyed through induction, teacher awareness, classroom notices and dedicated sections of the curriculum. This extends to awareness of safety online (i.e. awareness of privacy, harassment and identity theft).

In accommodation, students should:

• respect their fellow residents and be careful of everyone’s health and safety
• respect the accommodation and avoid damaging the furnishings and facilities
• respect the privacy of the hosts and not give out their information or invite guests without their permission
• never be in possession of weapons or replica weapons
• not rearrange the furniture in their accommodation
• not drink or smoke if they are under the age of 18. Other smoking devices (such as ecigarettes) are also not permitted.
• never cover smoke detectors

At all times, students should:

• arrive on time for lessons and activities
• not eat in classrooms
• only use phones in class as directed by the teachers
• try to maximise their learning by using English in class
• minimise abusive behaviour (see below)
• feel welcome to raise concerns with the safeguarding and welfare team

Abuse is defined as “the wilful, conscious desire to hurt, threaten, upset or frighten anyone.”

Abusive Behaviour may consist of the following, but is not limited to:

• Verbal abuse
• Harassment
• Bullying
• Actual or threatened violence
• Damage to personal property

The following actions also constitute abusive behaviour:

1. Deliberate unkindness or any action that causes hurt or upset will not be tolerated from any student, staff member or visitor.
2. It is a form of abusive behaviour to write notes, make phone calls or send electronic messages that are offensive, hurtful, annoying, or worrying.
3. Abusive behaviour can also include Cyberbullying; use of information technology to repeatedly harm or harass other people in a deliberate manner, e.g. sending, forwarding or posting harmful material using a cell phone or the internet. Cyberbullying can also take place in the workplace or on company web sites, blogs, or product reviews.
4. Students, staff members and visitors have a right to privacy of property and personal information in school. It is dishonest and can be a form of abuse to go into another person’s pocket or bag, read a private document or electronic message.

The appropriate and proportionate response to incidents is dependent on the circumstances, but the following steps are advised as necessary.

1. The misbehaviour is first brought to the attention of the student by an adult so that the student can correct it themselves.
2. A member of DSS reminds the student of the code of conduct (and the later steps of dealing with it) and asks the student to sign a customised and relevant code of conduct declaration.
3. A final warning is given.
4. As a last resort, in consultation with all parties, the course / accommodation services may be cancelled without refund.

The following steps may be taken when dealing with incidents of abusive behaviour:

1. If abusive behaviour is suspected or witnessed, a clear account of the incident must be reported to a member of DSS who must deal with it immediately.
2. The member of DSS/s will interview everyone who was involved and will further record the incident.
3. Parents, guardians and/or agents will be kept informed, where necessary.
4. Punitive measures will be used as appropriate and in consultation with all parties concerned. This may lead to permanent exclusion from the course and any other services (e.g. accommodation). No refund or alternative arrangements will be made.

Students, staff members or visitors who have been a victim of abusive behaviour will receive full support from UKCE by:

• offering an immediate opportunity to discuss the experience with DSS
• offering continuous support and reassurance
• working on restoring self-esteem and confidence
• taking measures to ensure no further abusive behaviour occurs

The accused student, staff member or visitor will also receive full support from UKCE by:

• being given the opportunity to discuss the events
• discovering why s/he/they became involved
• establishing the wrongdoing and the need to change behaviour
• Advising and supporting him/her to seek professional help
• If they are a student, inform parents, guardians and/or agents to help change the attitude, where necessary
• If they are a staff member, informing their line manager to help change the attitude, where necessary. Should the offence be of a serious nature, disciplinary procedures will be followed.

When protecting U18 students on our campus there are procedures in place for when persons visit the campus. Reception staff are aware of procedure and enforce this with all visitors.

• Visitors are first asked to sign in the visitor logbook giving their full name(s), date and reason for their visit.
• They are then given a visitors lanyard, with a yellow ribbon to show they are visitors. This lanyard should be worn at all times around their neck. A condensed Safeguarding Policy is also printed on the back of each card.
• The College Safeguarding Policy is then pointed out to them, and they are made aware of U18 students on the campus. Including being made aware that if they have any concerns when walking around the building to inform us straight away.
• Before they leave, the visitor must sign out of the logbook and also return the visitor lanyard to reception.

Fire safety risk assessments make provision for U18s in terms of additional precautions, such as awaking younger students in residential accommodation. Homestay hosts are required to complete their own fire safety risk assessments.

Transfers are completed through companies that have completed DBS checks on their drivers. U18 students are accompanied by group leaders during their flights and transfers.

Designated staff should be careful not to confuse Special Educational Needs with warning signs of abuse. To avoid this, they should be made aware of which students have special needs through the enrolment process and registration form. Their details are then added to the enrolment database so Academic managers are aware and this information be passed on to teachers. These students may be especially vulnerable.

Designated safeguarding staff should be aware of any students in attendance at the College. DSS should also be trained on how to deal with any students who are LGBTQ in the event the student may face persecution or hate towards them either in the College or outside of it. Inclusivity is promoted in the College and all teachers have a duty to ‘actively promote’ the fundamental British values of democracy, the rule of law, individual liberty, and mutual respect and tolerance of those with different faiths and beliefs which were first set out by the government in the ‘Prevent’ strategy in 2011.

If an U18 is placed with a host family for 28 days or more (as defined under the Children Act 1989), the arrangement changes and is subject to a private fostering agreement, with the agreement of the local council (City of London for Eastgate House). The local authority must be notified at least 6 weeks before the arrangement begins (or immediately if already begun).

The Data Protection Act 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe. Private data regarding staff and student identification is held securely within databases with restricted access and kept securely when in hard copy. For safeguarding purposes, relevant staff may have access to student phone numbers for the purpose of maintaining contact. These are kept on school phones and deleted as soon as they are no longer required. A paper folder is used to keep records of concerns and allegations and is kept securely in the Academic Management offices of Eastgate House for their respective reports.

This Safeguarding Policy will be kept under continuous review. We update it annually or as often as required. Any changes we may make to this Policy in the future will be posted on our website and in this document.

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