Safeguarding Policy

The WLZ Group regards the health, safety and welfare of all young people and adults at risk engaged in its programmes and other activities as one of its highest priorities. The organisation recognises and fully accepts its moral and statutory duty to safeguard and promote the welfare of children, young people and adults at risk, and its duty to protect staff from unfounded allegations of abuse.

WLZ Group understands that some of its learners will be vulnerable, either because of special educational needs or as a result of being out of mainstream education, and accepts that this can bring additional risk of harm and abuse.

This Safeguarding Policy should be read in conjunction with the following policies:

• Health and Safety Policy
• Whistleblowing Policy
• Safe Recruitment and Selection Policy
• Staff Code of Conduct
• Managing Allegations Policy
• Learner Code of Conduct

This policy applies to all staff, including senior managers, paid staff, consultancy staff, agency staff, or anyone working on behalf of WLZ Group (hereafter referred to as staff).

The WLZ Group incorporates tuition centres at Worcester and Kidderminster. This policy applies to staff working at both centres and any future tuition centres acquired by the WLZ Group. This policy serves to provide guidance to all staff as they work with colleagues to address any safeguarding concerns and to promote successful multi-agency working.

Everyone, including children and adults at risk, has the right to be protected from abuse. WLZ Group recognises the need to ensure their welfare when those individuals come into contact with the services we provide. Children and adults at risk are best protected when professionals are clear about what is required of them individually and how they need to work together.

Effective safeguarding arrangements in every local area should be underpinned by two key principles:

• Safeguarding is everyone’s responsibility; for services to be effective, each professional and organisation should play their full part.

• A person-led approach; for services to be effective they should be based on a clear understanding of the needs and views of individuals.

WLZ Group will take all reasonable measures to ensure that any risk of harm to learners’ physical and mental health is minimised and will take all possible action to address concerns about the welfare of any learner in full partnership with other agencies.

We will ensure:

• A safe environment for all learners and staff.
• Those suffering or at risk of suffering significant harm or abuse are identified and referred to the necessary agencies as appropriate.
• All learners are taught about safeguarding, our safeguarding procedures, and how to keep themselves and others safe.

• Appointing and training a Designated Safeguarding Lead (DSL).
• Ensuring all staff working with learners are trained in safeguarding.
• Raising awareness of the increased risk to specific groups of learners, for example, those with SEN, looked-after children, learners with English as a second or other language, unaccompanied asylum seekers, learners from a travelling background, and those with adverse childhood experiences.
• Ensuring that all staff are recruited safely and in compliance with safer recruitment guidance.
• Ensuring all staff involved in the education programmes read and understand the most recent version of ‘Keeping Children Safe in Education’ (Part 1).
• Ensuring staff recognise the signs of abuse or that an individual may be at risk of significant harm.
• Promoting a safe learning environment in the workplace and in the classroom.
• Ensuring that all centres are secure and that visitors are required to sign in before entering the buildings and are escorted at all times and not left alone with learners.
• Engaging with WLZ Group’s partners to ensure their commitment to safeguarding in the workplace and other learning environments.
• Working with other agencies as appropriate (e.g. safeguarding partners) where an individual is being, or at risk of being, significantly harmed.
• Providing a framework (procedure) for reporting and dealing with concerns and disclosures.
• Ensuring that all disclosures and concerns are securely recorded and acted upon as appropriate.
• Ensuring that safeguarding is discussed with learners in lessons as appropriate.
• Establishing clear procedures for the reporting and handling of allegations of abuse against staff.
• Requiring staff to undertake mandatory safeguarding training upon employment.

The legislative frameworks that support our policy are:

• Working Together to Safeguard Children 2023 reaffirms safeguarding as everyone’s responsibility and the importance of sharing information between agencies.
• Keeping Children Safe in Education 2024 requires all staff to read and understand their responsibilities if engaged in regulated activities with young people.
• The Prevent Duty 2023 requires specified authorities, including education, in the exercise of their functions to have due regard to the need to prevent people from being drawn into terrorism.
• Children’s Act 1989/2004 provides the legislative framework for child protection in England.
• Education Act 2002 introduced the requirement of safeguarding children and young people from abuse or neglect and sets out the responsibilities of teachers and those with designated responsibility for child protection.
• The Care Act 2014 sets out the six principles of adult safeguarding and encourages caregivers to take a person-centred approach when protecting adults at risk.
• Safeguarding Vulnerable Groups Act 2006 helps avoid harm or risk of harm by preventing people who are deemed unsuitable to work with children and adults at risk from gaining access to them through their work.
• Sexual Offences Act 2003 makes it an offence for a person over 18 (for example, a teacher or other member of staff) to have a sexual relationship with a child under 18 where that person is in a position of trust in respect of that child, even if the relationship is consensual.
• Special Educational Needs and Disability Act 2001 ensures that schools and colleges make reasonable provisions to ensure people with disabilities or special needs are provided with the same opportunities as those who are not disabled.
• Protection of Freedoms Act 2012 changed the definition of regulated activity, including who is eligible for a barred list check.
• Mental Capacity Act 2005 is designed to protect and empower people who may lack the mental capacity to make their own decisions about their care and treatment. It applies to people aged 16 and over.

• Safeguarding – Protecting children, young people, and adults at risk from maltreatment, preventing impairment of their physical and mental health or development, and ensuring they are growing up in circumstances consistent with the provision of safe and effective care.
• Child Protection – Any activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.
• Child/Young Person – Children and young people are defined as those aged under 18.
• Adult at Risk – (Previously referenced as vulnerable adult) For the purposes of this policy, an individual under the age of 25, with specific personal or situational needs, which increase their risk of suffering significant harm.
• Significant Harm – The Children’s Act introduced the concept of significant harm as the threshold that justifies compulsory intervention in family life in the best interests of the children. Some children may need help because they are suffering or likely to suffer significant harm.

The following are all types of abuse that can occur in children and adults at risk:

Physical Abuse – May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm. Physical harm may also occur when a parent or carer fabricates or induces illness in a child, young person, or vulnerable adult.

Emotional Abuse – Includes threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyberbullying, isolation, or unreasonable and unjustified withdrawal of services or supportive networks.

Sexual Abuse – Involves forcing or enticing a child, young person, or vulnerable adult to take part in sexual activities, whether or not they are aware of what is happening. The activities may involve physical contact, including assault by penetration or non-penetrative acts such as kissing, rubbing, or touching outside clothing. It may also include non-contact activities, such as involving children or young people in looking at or witnessing the production of sexual images, watching sexual activities, or encouraging inappropriate sexual behaviour.

Neglect – The persistent failure to meet a child, young person, or vulnerable adult’s physical and/or psychological needs, likely to result in serious impairment of health or development. Neglect may occur during pregnancy as a result of substance misuse or abuse.

Neglect and Acts of Omission – Includes ignoring medical, emotional, or physical care needs; failure to provide access to appropriate health, care, support, or educational services; and withholding necessities such as medication, adequate nutrition, and heating. It also includes failure to follow agreed processes.

Sexual Violence – Includes rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, exposure to pornography, witnessing sexual acts, sexual assault, or any sexual act without consent or where the individual has been coerced.

Financial or Material Abuse – Includes coercion to take extortionate loans, threats to recover debt, theft, fraud, internet scamming, coercion regarding an adult’s financial affairs or arrangements, misuse or misappropriation of property, possessions, or benefits.

Modern Slavery – Encompasses slavery, human trafficking, forced labour, and domestic servitude. Traffickers and slave masters use coercion, deception, or force to exploit individuals.

Discriminatory Abuse – Includes harassment, slurs, or similar treatment because of race, gender and gender identity, age, disability, sexual orientation, or religion.

Organisational Abuse – Includes neglect and poor care practice within an institution or care setting such as a hospital, care home, or in a person’s own home. This may range from one-off incidents to ongoing ill-treatment resulting from poor structures, policies, or practices.

Self-Neglect – Covers behaviour neglecting personal hygiene, health, or surroundings, including hoarding, that causes a risk of harm.

Extremism and Radicalisation – Extremism is 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. Radicalisation is the process by which a person comes to support terrorism and encourages others to adopt similar views.

Child Sexual Exploitation – A form of child sexual abuse where an individual or group exploits an imbalance of power to coerce, manipulate, or deceive a child or young person under 18 into sexual activity, either in exchange for something they need or want, or for the perpetrator’s financial or social gain.

Child Criminal Exploitation – A geographically widespread form of harm often linked to county lines criminal activity. Gangs or networks groom and exploit children and young people to carry drugs and money from urban to rural or coastal areas.

Child on Child Abuse – Children can abuse other children in many forms, including bullying (including cyberbullying), physical abuse (such as hitting, kicking, shaking, biting, hair pulling), youth-produced sexual imagery, and initiation or hazing violence and rituals.

Sexual Violence and Sexual Harassment – Sexual violence and harassment can occur between two children of any age and sex, in person or online. All reports and concerns must be taken seriously, with appropriate support for both the victim and the perpetrator.

Domestic Abuse – Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence, or abuse between those aged 16 or over who are, or have been, intimate partners or family members. Children who witness domestic violence are victims of emotional abuse.

Drugs and Alcohol – The health and wellbeing of a child, young person, or vulnerable adult can be seriously affected by their own dependence on alcohol and illegal substances, or by the dependence of those responsible for their care.

Forced Marriage – A marriage in which one or both parties are married without their consent or against their will. This differs from an arranged marriage, where both parties consent.

Female Genital Mutilation – All procedures involving partial or total removal of the external female genitalia for non-medical reasons. FGM is illegal in England and Wales under the FGM Act 2003.

Fabricated or Induced Illness – A form of child abuse where a parent or carer exaggerates or deliberately causes symptoms of illness in a child.

Hate Crime – Any incident that constitutes a criminal offence and is motivated by prejudice.

Mental Health – Mental health problems can, in some cases, indicate that a child has suffered or is at risk of abuse, neglect, or exploitation. Only appropriately trained professionals should make a diagnosis, but staff are well placed to observe and identify concerns. Abuse, neglect, or other adverse childhood experiences can have a lasting impact on mental health, behaviour, and education.

Learners missing from education are at significant risk of being victims of criminal and sexual exploitation or radicalisation. Staff understand that all absences, whether notified or not, may indicate that the learner is at risk. Staff will follow Department for Education (DfE) guidelines for any learner they are concerned about. This includes vulnerable adult learners who are absent without notification.
The Designated Safeguarding Lead (DSL) will be responsible for liaising with the local authority regarding any learners who are classed as missing or who raise concerns.

WLZ Group recognises the significant harm caused by child sexual exploitation and will work closely with the local authority to identify and minimise risk. WLZ Group has appointed the DSL as the designated lead for child sexual exploitation. The DSL will be appropriately trained and will work in partnership with the local authority and other designated leads across the county to share good practice and support children and young people who may be at risk of exploitation.

Consideration of mental capacity is crucial at all stages of safeguarding, as it provides a framework for decision making that balances independence and protection. This includes determining:

• The ability of a vulnerable adult to make lifestyle choices, even when those choices may place them at risk of abuse.
• Whether a particular act or transaction is abusive or consensual.
• How much a vulnerable adult can be involved in making decisions about their care and protection.

If a vulnerable adult at WLZ Group is unable to make a decision and is deemed to be at risk, appropriate action will be taken on their behalf to ensure their safety and that concerns are reported. This practice is guided by the Mental Capacity Act 2005, which provides a statutory framework to empower and protect individuals who may not be able to make their own decisions. Capacity should not be viewed as a barrier to safeguarding; however, care must be taken not to contravene an individual’s wishes, feelings, and rights.

WLZ Group understands that looked after children are at greater risk of abuse. The DSL will act as the Designated Teacher to ensure that the attendance and progress of all looked after children are monitored and reported in accordance with local authority requirements. WLZ Group will also report any child known to be in a private fostering arrangement to the local authority immediately.

Many WLZ Group learners are vulnerable and may require support during meetings and interviews. When a parent, carer, or family member is unavailable, an appropriate adult (usually a member of staff) will be present to support the learner. This includes meetings with social workers, the police, or other agencies.

Safeguarding is everyone’s responsibility and all staff involved in the delivery and support of our programmes have a role to play. All staff employed by WLZ Group will undergo safeguarding training at induction, advanced training (as appropriate) and will receive regular updates throughout the year through bulletins and organised CPD sessions.

The CEO has leadership and management responsibility for WLZ Group’s safeguarding arrangements and will ensure that:

1. All staff are DBS checked in accordance with statutory guidance.
2. All staff are trained in safeguarding and understand their responsibilities.
3. A suitably qualified and experienced Designated Safeguarding Lead (DSL) is appointed and that their responsibilities are explicit in their job description/contract.
4. Safeguarding is an agenda item at all senior management meetings and senior managers are provided with regular updates in terms of cases, trends, training, safe recruitment etc.
5. Any required local authority safeguarding audits are carried out, approved at senior management level and submitted by the set deadline (Local Authority Sec 11 Audit).

1. Being the first point of contact for all staff to go to if they are concerned about a learner.
2. Ensuring the organisation’s policies reflect prevailing legal and contractual requirements.
3. Ensuring that HR maintains a Single Central Register (SCR) of all staff employed by WLZ Group and that any concerns are raised with the CEO.
4. Managing the referral of cases of suspected abuse or allegations to the relevant agencies.
5. Keeping detailed, accurate, secure written records of concerns and referrals and ensuring that any child protection files and information are requested from the local authority/referring organisation and shared with destination colleges in accordance with KCSIE.
6. Referring concerns around Prevent to the DfE Prevent Co-ordinator and/or the local authority’s Prevent Officer.
7. Carrying out risk assessments for ‘high risk’ learners to ensure adequate support is in place.
8. Understanding the ‘Early Help’ process and how to refer learners.
9. Attending case conferences and review meetings if required and as appropriate.
10. Ensuring that the organisation’s IT infrastructure is secure and that robust filtering and monitoring processes are in place.
11. Communication of the policy and arrangements to all relevant parties including but not limited to children, young people and adults at risk, their parents and families, staff and volunteers.
12. Engaging with local authorities and other agencies as appropriate.
13. Establishing the contact details of relevant statutory agencies e.g. Children’s Social Work Services, Police, Local Safeguarding Boards, and the Local Authority Designated Officer.
14. Escalating concerns where they have not been followed up or managed correctly.
15. Ensuring that staff receive safeguarding training appropriate to their roles and regular updates.
16. The safety of all learners, including when a young person or vulnerable adult is absent or missing, without explanation.
17. Acting as a source of support, advice and expertise for staff.

1. Adhering to safe recruitment guidelines at all times and ensuring that all processes associated with recruitment are in line with WLZ Group’s Safe Recruitment and Selection Policy.
2. Maintaining a Single Central Register (SCR) of all staff employed by WLZ Group and ensuring that any concerns are raised with the DSL.
3. Ensuring that staff responsible for recruitment are trained in ‘safer recruitment’.
4. Requesting DBS checks in line with national and local guidance.
5. Ensuring safeguarding responsibilities are reflected in all job descriptions.
6. Supporting the CEO and DSL with any staff investigations where a safeguarding complaint/allegation has been made.
7. Ensuring that all new staff follow a robust induction programme which sets out their safeguarding responsibilities, the key policies and the details of the DSL.

1. Understanding safeguarding and their responsibilities to report concerns and disclosures.
2. Undertaking appropriate training.
3. Understanding risks and the signs to look for.
4. Understanding that some learners will be more vulnerable to abuse.
5. Listening actively to learners and clients and taking their concerns seriously.
6. Reporting and recording any concerns using the safeguarding form held on ‘Tutorbird’.
7. Reporting any concerns they have about other members of staff using the organisation’s Whistleblowing Policy.

WLZ Group operates safer recruitment and employment practices and has a separate policy to manage this process. Managers responsible for recruitment will undergo ‘safer recruitment training’ to understand their responsibilities and the legal requirements when employing staff to work with learners.

Information sharing is crucial in order to safeguard the welfare of children and adults at risk. Information must only be shared with staff that “need to know” and then only the details required to enable the safeguarding team to make an informed decision.
WLZ Group uses a secure safeguarding reporting and recording system, CPOMS, which all staff should use to report concerns and disclosures. In all cases, reports should be clear and concise and staff should understand that their reports may be shared with other agencies and/or required as evidence.
If a member of staff is asked to share safeguarding information, they must first contact the DSL to ask for advice.

WLZ Group has a separate policy for managing allegations of abuse. The Staff Code of Conduct provides staff with clear guidelines on how to behave and how to avoid unfounded allegations. Breaches of this Code of Conduct may result in disciplinary proceedings.
The primary concern in the event of an allegation is to ensure the safety of the young person or vulnerable adult. In all cases, action will be taken quickly, confidentially, and professionally, with all parties clear that suspension is not an indicator of guilt, but a required part of a process.
In the event that a member of staff suspects any other member of staff of abusing a learner, it is their responsibility to report these concerns to the DSL, except when they are the person against whom the allegation is being made. In this instance the report should go to the Local Authority Designated Officer (LADO).
The DSL will contact the Local Authority and seek the advice of the Designated Officer in all situations where a member of staff has been accused of or is suspected of abuse. The DSL will also contact the DBS to advise them of any subsequent dismissals, regardless of prosecution.

It is a statutory requirement under the Children Act 2004 (Section 11) that all individuals who work with vulnerable children and adults, both permanent staff, volunteers and contractors, should be trained and competent and be alert to the risk of abuse. This requirement is reinforced in Keeping Children Safe in Education. The Care Act 2014 also requires staff working with adults at risk to be trained in safeguarding and spotting the signs of abuse. This includes being able to recognise when a child or a vulnerable adult may require safeguarding from abuse and knowing what to do in response to a concern about their welfare.
WLZ Group will ensure that all staff undergo basic safeguarding awareness training including Prevent and that this training is updated every three years. Staff will be given regular updates on prevailing safeguarding concerns and local issues as appropriate. The DSL will be trained to the required level.
WLZ Group encourages and supports staff to undergo additional safeguarding training as required, for example, Child Sexual Exploitation and Trauma-Informed Practice.
Training compliance will be monitored regularly and reported to various stakeholders. Individual personnel compliance will be reviewed at the annual review. Those members of staff who fail to comply with the training requirements will have restrictions imposed on working practices until training requirements are met. Furthermore, disciplinary action may be considered if an individual continues to show non-compliance and there are no mitigating circumstances.

Please bear in mind that most young people and adults at risk who you have contact with through your work are likely to experience a perfectly safe and happy life. It is recognised, however, that a small percentage of the young people and adults at risk that you meet will, through the nature of their experiences, demonstrate behaviours that might be indicators of abuse, so it is important that staff take action. Many factors associated with disadvantage can also result in a young person or vulnerable adult's behaviour being affected, and this should be considered alongside any disciplinary action.

Staff are not expected to become experts in the protection of young people and adults at risk, nor are they expected to investigate abuse. They are, however, expected to do the right thing and report all concerns or disclosures of abuse.

The management of WLZ Group is responsible for ensuring that all staff and volunteers for whom they are responsible are aware of and understand the importance of implementing these procedures.

1. Staff and volunteers who, for any reason, become concerned that a young person or vulnerable adult may be at risk of abuse, is being, or has been abused, must immediately report that concern to a member of the Safeguarding Team. No matter how small the concern is, it is important to report it.
2. The concern should then be recorded on the appropriate concern form, which can be found on TutorBird.
3. If the concern is urgent and you need assistance or a response immediately, contact the deputy DSL.
4. The Safeguarding Team will discuss your concerns with you to clarify their cause and obtain all the known relevant information. They will then decide on further action. They may refer the matter straight to Children’s Services or Adult Services or liaise with other agencies, e.g. School DSL, DfE Prevent Co-ordinator. The DSL will record the incident/concern on the Safeguarding Concerns Log. This information is held securely and will be passed on to the relevant authorities if required.
5. If the concern is about the DSL, then the matter should be reported to the CEO.
6. Staff must make sure that any written notes are handed to the DSL, as they may be required in evidence if the matter leads to a prosecution.
7. If the child, young person, or vulnerable adult is at immediate risk of harm, call the police on 999.

1. Children, young people, and adults at risk will occasionally disclose abuse to an individual they have come to feel they can trust. This happens for many reasons, but the important thing to remember is that if they do tell you, they are doing so in the hope that you will act to stop it happening, even if they ask you not to do anything with the information.
2. It is important to remember too, that it can be more difficult for some to disclose than for others. Children, young people, and adults at risk who have experienced prejudice and discrimination through racism may well believe that people from other ethnic groups or backgrounds don't really understand or care about them. They may have little reason to trust those they see as authority figures and may wonder whether you will be any different.
3. Children, young people, and adults at risk with a disability will have to overcome barriers before disclosing abuse. They may well rely on the abuser for their daily care and have no knowledge of alternative sources. Sadly, some may have come to believe they are of little worth and simply comply with the instructions of adults.
4. If a young person or vulnerable adult discloses abuse to you in the course of your work, it is important to react appropriately.

• Remain calm and listen without interrupting
• Only ask questions to seek clarification and use open, non-leading questions
• Reassure the child, young person, or vulnerable adult that they have done the right thing and that it is not their fault
• Make notes if you can do so without worrying the child, young person, or vulnerable adult
• Thank them for telling you and reassure them that you will report it so that they start to get help
• Remember that the child may be frightened or embarrassed, and they may be worried about getting someone they care for into trouble

• Interrogate or ask leading questions
• Panic or show your emotion in any way
• Make assumptions about what might have happened or speculate
• Promise to keep it a secret – you must pass the information on
• Make negative comments about the alleged abuser

Following a disclosure, staff must immediately report the matter to the DSL. Staff must make sure that any written notes are handed to the DSL, as they may be required in evidence if the matter leads to a prosecution.
If the child, young person, or vulnerable adult is at immediate risk of harm, call the police on 999.

http://www.worcestershire.gov.uk/info/20559/refer_to_childrens_social_care/1659/are_you_worried_about_an_adult_who_works_with_children

Child Safeguarding Team (Family Front Door)
Telephone: 01905 822666

Adult Safeguarding Team
Telephone: 01905 843189

Local Authority Designated Officer

Telephone: 01905 846221

Visit: www.worcestershire.gov.uk