Child and Individuals Protection and Safeguarding Policy

Contents:

Policy Statement

Purpose of policy
Safeguarding Children and Individuals
Legislation and Guidance
Responsibilities
Child Protection – Procedures
Prevent duty-safeguarding children and individuals who are vulnerable to extremism
Safeguarding children and individuals who are vulnerable to exploitation, child sexual exploitation, honour-based abuse (forced marriage, female genital mutilation).
Procedure for children and individuals identified as being ‘at risk’ or vulnerable to exploitation, child sexual abuse and at risk from or involved with violent crime and peer-on-peer abuse.
Domestic Abuse
Online safety
Opportunities to teach safeguarding
Looked after children
Children with a social worker
Children who harm other children (peer on peer abuse, sexual abuse or sexual harassment)
Confidentiality and Record Keeping
Working with Parents and carers
Health and Safety
Equal Opportunities
Monitoring and review of this policy, staff guidance information on child abuse and categories of abuse.

Policy Created by Katharine Jennings Fine Art

Key Contacts for Safeguarding and Child Protection at Katharine Jennings Fine Art (KJFA):

Designated Safeguarding Lead (DSL) – Katharine Jennings

Deputy Safeguarding Lead (DDSL) – Megan Miles

Local Authority Designated Officer (LADO) – Eastsussex.gov.uk

Single Point of Advice (SPOA) – Childrens Services, East Sussex County Council (Eastsussex.gov.uk), Telephone: 01323 464 222
Monday to Thursday 8.30am to 5pm and Friday 8.30am to 4.30pm.

Out of hours:

Telephone: 01273 335 906 or 01273 335 905

Contact our Emergency Duty Service (EDS) with serious concerns that cannot wait until the next working day.

EDS operates Monday to Thursday 5pm to 8.30am and
Fridays, weekends and bank holidays, 4.30pm to 8.30am.

If you are concerned about extremism, or if you think a child or individual might be at risk of extremism, contact the helpline on 0207 340 7264 or counter.extremism@education.gov.uk

2. Purpose of Policy

KJFA fully recognises its responsibilities for safeguarding children and vulnerable adults. Our customers welfare and safety are at the heart of our ethos and in everything we do.

In this policy, a ‘child’ means all children and young people below the age of 18 years of age.

In this policy an ‘individual’ means all people over the age of 18.

In accordance with relevant law and guidance, as set out below in the Second Section, this policy details our procedures for safeguarding and child protection.

It is applicable to the community. Safeguarding and promoting the welfare of children and individuals is everyone’s responsibility, whether they work or volunteer in The Business. Everyone has a role to play in child protection and safeguarding.

All staff, contractors and volunteers will ensure their approach and actions are child-centred during childrens clubs, sessions and classes and are vigilant at all times. This means that they will consider, at all times, what is in the best interests of the child or individual.

KJFA ensures that arrangements are in place to safeguard and promote the welfare of all children and individuals who are in their care by:

Creating and maintaining an environment where all children and individuals feel secure, are encouraged to communicate and are listened to.
Making sure that all children and individuals know which adults they can approach if they have any worries by addressing this at the start of each course, workshop or club.
Appointing members of staff to the roles of Designated and Deputy Safeguarding Leads.
Providing effective, relevant and ongoing training and development for all staff. We do this through a number of external providers, including the local authority.
Swiftly and effectively addressing any concerns and ensuring robust, timely referrals are made to other agencies. Ensuring effective links with relevant agencies in all matters regarding safeguarding and child protection.
Keeping meticulous, written records or concerns about customers within GDPR legislation, even where there is no need to refer the matter immediately (this includes recording dates, times, people responsible and actions), and ensuring all records are kept securely and shared appropriately.
Ensuring the suitability of all staff and contractors through safe recruitment practice and carrying out DBS checks.
Making sure that all staff, contractors and volunteers understand their responsibilities with regard to safeguarding and child protection.
Ensuring that parents and carers also have an understanding of the responsibility placed on KJFA and it’s staff, contractors and volunteers for safeguarding and child protection.
Maintaining clear procedure in line with the latest guidance for reporting allegations against staff members, contractors and volunteers.

Furthermore, KJFA recognises that:

Some Children and individuals are at increased risk of abuse
Some children and individuals face additional barriers with respect to recognising or disclosing abuse.

We are committed to recognising diversity and ensures anti-discriminatory practices. We ensure that all children have the same protection. We give special consideration to children who :

Have special educational needs (SEN) or disabilities (further information is in Section 9).
Are young carers
Show signs of mental health problems
May experience discrimination due to their race, ethnicity, religion, gender identification, or sexuality.
Are at risk of FGM, sexual exploitation, force marriage or radicalisation.
Are asylum seekers
Have English as an additional language
Are known to be living in difficult situations e.g. where there are issues at home, such as, substance abuse/misuse or domestic violence or where a family member has mental health needs.
Are at risk due to either their own or a family members mental health needs.
Are within the care system and are looked after or have been previously looked after or have a social worker.

3. Safeguarding Children and Individuals

3.1 KJFA recognises that safeguarding covers a broad range of areas and it aims to achieve the following:

Protecting children and individuals from maltreatment
Preventing impairment of children’s and individuals mental and physical health and/or development
Ensuring children are growing up in circumstances consistent with the provision of safe and effective care.
Undertaking that role so as to enable children to have optimum life chances, so they can enter adulthood successfully and enable individuals optimum life chances.

3.2 As part of meeting a child’s or individuals needs, KJFA:

Recognises that sharing information, particularly with safeguarding partner agencies and other professionals, in a timely manner is crucial in identifying and tackling all forms of abuse and neglect. Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare and protect the safety of children. The Data Protection Act (DPA) 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children individuals safe.
Recognises that, to facilitate the sharing of ‘special category personal data, ‘the DPA 2018 contains’ safeguarding of children and individuals at risk as a processing condition that allows practitioners to share information without consent if it is not possible to gain consent it cannot be reasonably expected that a practitioner gains consent, or if to gain consent would place a child at risk.
Will identify children who may benefit from the Early Help process and make timely disclosures to the Local Authority to enable that process to begin. Working with safeguarding partners and other professionals to assist with these assessments and work flowing from these assessments .
Recognises that mental health issues can be an indicator of abuse and neglect and will share any such concerns appropriately.
Will identify children who need extra help and make appropriate referrals, including Early Help service, to prevent concerns escalating.

3.3 KJFA also understands the importance of contextual safeguarding i.e. that incidents or behaviours can be associated with factors outside KJFA and can occur between children outside of KJFA. All staff should be considering the context within which such incidents and behaviours occur. This is known as contextual safeguarding and simply means that assessments should consider whether wider environmental factors are present in a child’s life that are a threat to their safety and/or welfare.

4. Legislation and Guidance

This policy for KJFA is derived from a variety of legislative provisions and statutory guidance. In particular, it is based on good practice found in:

Keeping Children Safe in Education (2020)
Working Together to Safeguard Children (2018)
Governance Handbook

The following legislation is also incorporated into this policy:

The Children Act 1989 (and amendment 2004), which gives a broad framework for the care an protection of children and includes provisions for Local Authority inquiries, care proceedings and emergency provisions.
Female Genital Mutilation Act 2003 S5B (11), as inserted by S74 of the Serious Crimes Act 2015, places a statutory duty on The Business and all its staff to report to the police where they discover/find that female genital mutilation (FGM) appears to have been carried out on a girl under 18. Responsibilities for safeguarding and supporting girls affected by FGM are found in Statutory guidance on FGM.
The rehabilitation of Offenders Act 1974 outlines the provisions for when people with criminal convictions can work with children
Regulated activity in relation to children is found in Schedule 4 of the Safeguarding Vulnerable Groups Act 2006
Schools ‘PREVENT’ duties under the Counter-Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism can be found in Statutory guidance on the Prevent duty.

Other statutory provisions relevant to child protection and safeguarding include:

The Education Act 2002 (Section 175/157)
The Education (pupil information) (England) Regulations 2005
Prevent Duty guidance for England and Wales – Septemember 2015
The Sexual Offences Act 2003, Home Office.

4.1 Related Policies:

Safeguarding covers more than the contribution made to child protection in relation to individual young people. It also encompasses issues such as staff conduct, health and safety, bullying, online safety, arrangements for meeting medical needs, providing first aid and/or intimate care, drugs and substance misuse/abuse, positive behaviour management and the use of physical intervention and restraint.

This document must therefore be read, used and applied alongside policies and procedures referred to below:

Vetting checks for all staff and volunteers
The Staff recruitment and selection process
Local Authority policies on dealing with allegations against members of staff
Data Protection Policy
The Health and Safety Policy

5. Responsibilities

KJFA recognises that safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who comes into contact with children and their parents or carers has a role to play in safeguarding children.

All staff working (including visiting staff) at KJFA are required to:

Be aware of our child protection and safeguarding policy and procedures, including referrals to statutory agencies. They must understand the role of the DSL.
Attend all the relevant training and development and be aware of all their responsibilities in line with Keeping Children Safe in Education 2020.
Know how to deal with a disclosure. If a child discloses to a member of staff that they are being abused , the staff member should follow the guidance set out in this policy.
Report instances of actual or suspected child abuse or neglect to the DSL or, in their absence, the DDSL, in line with Child Protection Procedures and legal duty for reporting FGM as set out in this policy.
Understand our management policy and procedure and know what to do in the event of an allegation made against someone working with children.
Be alert to the signs of harm and abuse, including issues that can manifest themselves due to peer on peer abuse. This is most likely to include, but not limited to , bullying (including cyber bullying), gender-based violence/sexual assaults and sexting. Staff should follow the Child Protection Procedures with regards to Peer on peer abuse as outlined in this policy.
Know the DSL and DDSL’s name and contact details, including telephone numbers and email.
Be aware of the early help process. This includes indentifying emerging problems, liaising with the DSL, sharing information with other professionals to support early identification and assessment and, in some cases, acting as the lead professional in undertaking an early help assessment.

Katharine Jennings, business owner, will:

Be responsible for the implementation of this and all related policies and procedures, ensuring the outcomes are monitored.
Ensure that whilst the activities of the DSL can be delegated to appropriately trained DDSL’s , the ultimate responsibility for safeguarding and child protection , as set out below, remains with the DSL
If the DSL is someone other than Katharine Jennings, to meet regularly with the DSL.
Ensure that the DSL has appropriate time, funding and training and resources to fulfill all of their functions and ensure adequate cover in the event that the DSL is not available.
Ensure that everyone connected to The Business is aware of this policy including the safeguarding and child protection procedures.
Ensure that all staff are vigilant to harm and abuse, are able to identify those students for whom there are child protection concerns, and can make appropriate referrals, including to early help services.
Be alert to the signs of harm and abuse and specific safeguarding issues includings but not limited to: Child Sexual Exploitation (CSE); Child Criminal Exploitation including County Lines Activity; serious violent crime including serious violent sexual offences; peer on peer abuse, FGM, and radicalisation. Peer on peer abuse can manifest itself in many ways but often in bullying (including Cyber bullying) gender based violence/sexual assaults and sexting. Staff should follow the Child Protection Procedures with regards to peer on peer abuse as outlined in this policy.
Communicate clearly to visitors, parents and students, so everyone understands The Businesses safeguarding policy and procedures.
Appoint a DSL and DDSL giving consideration to the range of responsibilities the DSL undertakes, eg. the DSL needs to have flexibility to act immediately on a referral that requires an urgent response and time to attend lengthy meetings and case conferences.
Ensure that contact and role details of the DSL and DDSL are clearly displayed in staff online areas and the website (along with this policy)
Ensure safe recruitment practice is followed when recruiting for posts, and ensure appropriate action is taken when an allegation is made against a member of staff
Ensure all appropriate checks are made in relation to staff, volunteers and visitors
Ensure The Business offers a safe environment via a robust health and safety policy and procedure to meet the statutory responsibilities for the safety of the children and staff
Ensure the relevant staffing ratios are met, where applicable.

The DSL is responsible for:

Being available for all staff to discuss any safeguarding issues or concerns
Ensuring all staff are aware of the DSL and DDSL contact details
Ensuring all cases of suspected or actual problems associated with child protection or safeguarding concerns (including cases where early help process may be appropriate) are referred to the appropriate agencies in line with procedures set out in this policy, keeping the DSL appraised.
Ensuring the safeguarding policy and practice is relevant and consistent with the most recent statutory guidance.
Being aware of the latest national and local guidance and requirements and keeping all staff informed as appropriate
Attending accredited, enhanced training each year, as required to fulfill the role.
Ensuring that appropriate training for staff (including periodic updates via e-bulletins, email, or as part of staff meetings) is organised according to the agreed programme with Katharine Jennings and renewed through ongoing professional development
Ensuring that effective communication and liaison takes place between The Business and the Local Authority or partner agencies and any other relevant agencies, where there is a safeguarding concern in relation to a child.
Ensuring that all staff have an understanding of child abuse, neglect and peer on peer abuse (including serious violence and serious sexual violence, Child Criminal Exploitation, FGM) and their main indicators, including for looked after children and additional vulnerabilities of children with special educational needs and disabilities (SEND)
Dealing with allegations of abuse, in accordance with local and statutory procedures
Supporting the staff member in liaising with other agencies.
Ensuring that adequate reporting and recording systems are in place
Being aware of children who are or who may be living in a private fostering arrangement an ensures liaison to support the welfare and safety of the child.
Referring suspected cases, as appropriate, to the relevant body (local authority childrens social care, Disclosure and Barring service, and/or police), and support staff who make such referrals directly.
Contributing and helping other staff to contribute to early help assessments
Meeting regularly with each other to discuss safeguarding issues including outcomes and implementation of action relating to case conferences and core groups and all current case work. Safeguarding matters arising will be discussed routinely at each staff meeting.

6. Child Protection Procedures

6.1 Staff at KJFA will follow the necessary child protection procedures if an incident occurs. They will be made aware that:

Where a child is in immediate danger or at risk of harm, a referral should be made to childrens social care and/or the policy immediately.
Anyone can make a referral
Staff should not assume that somebody else will take action/share information that might be critical in keeping children safe
Where referrals are not made by the DSL, the DDSL should be informed as soon as possible that a referral has been made.
The reporting of concerns relating to FGM to the police is mandatory.
The DSL and DDSL will always be available to discuss safeguarding concerns.
Refer to the ‘Continuum of Need’ guide on East Sussex County Councils website.
To contact East Sussex SPOA if assessment concludes necessary.
When a member of staff at KJFA suspects that any child may have been subject to abuse, or a child has suggested that abuse has taken place either to themselves or another child, the allegation must be reported immediately to the DSL.

The DSL or DDSL will:

Ensure the allegation is acted on within the same day.
Ensure that Katharine Jennings is informed of all allegations unless the allegation is against Katharine Jennings, in which case the appropriate authority, LADO, will be informed.
Deal with the allegation in accordance with the agreed procedures. In the case of violent sexual assault or sexual harassment matter, The Business will follow the latest procedures as set out in Keeping Children Safe in Education 2020.
Be best placed to carry out a risk assessment of the issue and determine the escalation and timescales for dealing with the allegation

It is best practice to ensure all colleagues who are involved in the allegation are informed of the outcome, so there is closure or continual vigilance as necessary.

6.2 FGM

The FGM Mandatory Reporting Duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crimes Act 2015). The legislation requires staff to make a report to the policy where, in the course of the professional duties, they either:

Are informed by a girl under 18 that an act of FGM has been carried out on her;
or they observe signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girls physical or mental health or for purposes connected with labour or birth.

6.3 Allegations Against Members of Staff

All allegations of abuse made against a member of staff (including volunteers) in relation to a child, must be brought to the attention of the DSL immediately.

In the event that Katharine Jennings is the subject of the allegation, the DDSL will report to the Local Authority Designated Officer (LADO) the same day:

They have behaved in a way that has harmed a child, or may have harmed a child
They possibly committed a criminal offence against or related to a child
They have behaved towards a child or children in a way that indicates he/she is unsuitable to work with children
They have behaved towards a child or children in a way that indicates they pose a risk of harm to children

for other allegations, the DSL will decide if further enquiries are required prior to referral to the LADO.

Where Katharine Jennings considers that a referral may be warranted under Child Protection Procedures and an allegation appears to meet the criteria, she will inform SPOA and/or LADO if advised to do so.

The LADO must be informed of all allegations that come to the staff at KJFA’s attention that meet the criteria, so that he/she can consult the police and social care colleagues as appropriate. The LADO should also be informed of any allegations that are made directly to the police or to childrens social care. All alleged physical injuries must be investigated by the appropriate external agencies.

6.4 Whistleblowing

Where a staff member at KJFA feels unable to raise an issue with their employer, or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them.

General guidance on whistleblowing can be found at http://www.gov.uk/whistleblowing. The NSPCC’s ‘what you can do to report abuse’ dedicated helpline is available as an alternative route for staff who do not feel able to raise concerns regarding child protection failures internally or have concerns about the way a concern is being handled by the business. Staff can call 0800 028 0285, which is available from 8.00am to 8.00pm, Monday to Friday and email help@nspcc.org.uk.

6.5 Training for Staff

Katharine Jennings Fine Art ensures that all staff complete safeguarding and child protection training or have done within the last two years. The Business also has a commitment to updating training for all staff, whenever necessary, but at least every two years. To acheive this :

Time will be given to enable this commitment to be met.
The DSL and DDSL will receive relevant training on updates in law regularly during staff meetings and every two years to update certificates
All staff and volunteers new to The Business will be given appropriate safeguarding training as part of their induction programme. Updates will feature regularly in staff meetings, as appropriate.
Newly recruited staff will complete the online training at two yearly intervals.

6.6 Suitability of Staff and Safe Recruitment Practices

KJFA recognises that safe recruitment practices are an essential part of creating a safe environment for children and young people. Consequently, we will ensure that staff and volunteers are suitable to do so and therefore do not pose any kind of risk to the children who attend our premises.

6. Reducing Risks of Extremism

KJFA will assess the level of risk within The Business and put actions in place to reduce that risk.

Actions will include consideration of:

The content of lessons, which may include religion and beliefs

Risk assessments may include:

Integration of students by gender and SEND
Other issues specific to The Business profile and community

There is no single way of identifying an individual who is likely to be susceptible to a terrorist/radical ideology. As with managing other safeguarding risks, all staff will be vigilant to changes in the children’s behaviour, which could indicate that they may be in need of help or protection. It is commonly recognised that children at risk of radicalisation may display changes in behaviour, show different signs or seek to hide their views. Staff are advised to use their professional judgement in identifying students who might be at risk of radicalisation and always act proportionately and seek support if they are concerned.

KJFA recognises that the Prevent duty does not ask staff to carry out unnecessary intrusions into family life, but as with any other safeguarding risk, they must act when they observe behaviour of concern.

6.1 Potential signs of Radicalisation and Extremism

There is no limit to the signs that you might notice – every child is different. However, some of the indicators staff should look out for, include:

Vulnerability: identity crisis, personal crisis, migration, unmet aspirations and history of criminality.
Access to extremist influences: friendship groups, internet activity, activities abroad i.e. military camps and vocalised support of illegal or extremist militant groups.
Experiences and influences: social rejection, personal impact from civil unrest and wide spread media coverage of international events, change in appearance and behaviour, family conflict over religious views and verbal or written evidence of support of terrorist activities.
Travel: pattern of regular extended travel, evidence of falsifying identity documents, and unexplained absences.
Social Factors: disadvantaged background, lack of empathy and/or affinity with others, severe learning difficulties or mental health, being a child of a foreign national refugee, experience of trauma or sectarian conflict, and extremist views of a significant other.

It is always worth remembering that numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most children or 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 issues.

6.2 Response

It is expected that if a member of staff identifies an individual vulnerable to radicalisation, they will contact the DSL first to discuss the case internally. They should be asked to record their concerns and raise it, as they would with any other safeguarding concern, with the Local Authority. If deemed suitable, the staff member will be asked to complete a written report to be handed to the DSL. At no point will the person be recorded on a criminal records system as a result of being involved in this.

7. Safeguarding Children who are Vulnerable to Exploitation, Child Sexual Exploitation, Honour Based Abuse (forced marriage and FGM), and at risk from or involved in Violent Crime and Peer-on-Peer Abuse

All staff at KJFA will be provided with an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and sexting (also known as youth produced sexual imagery) put children in danger.

7.1 Child Criminal Exploitation

Child Criminal Exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity, in exchange for something the victim needs or wants, and/or through violence or threat of violence.

The abuse can be perpetrated by males and females, and children or adults. It can be a one-off occurance or a series of incidents over time, and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. For example, young people may be forced to work, forced to shoplift or pickpocket, or to threaten other young people.

Staff should make themselves aware of the issues surrounding County Lines. How do you know if County Lines drug dealing is happening in your area?

Some signs to look out for include:

An increase in visitors and cars to a house or flat
New faces appearing at the house or flat
New and regularly changing residents (eg. different accents compared to local accent)
Change in residents mood and/or demeanor (eg. secretive/withdrawn/agressive/emotional).
Substance misuse and/or drug paraphernalia.
Changes in the way young people you might know dress.
Unexplained, sometimes unaffordable new things (eg. clothes, jewellry, cars, etc)
Residents or young people you know going missing, potentially for long periods of time.
Young people seen in different cars/taxis driven by unknown adults
Young people seeming unfamiliar with your community or where they are.
Truancy, exclusion and disengagement from school
An increase in anti-social behaviour in the community
Unexplained injuries

All staff should be aware of the associated risks and understand the measures in place to manage these.

All staff at KJFA will be made aware of the indicators that may signal children at risk from, or are involved with, serious violent crime.

Signs may include:

Increased absence
Change in friendships
New relationships with older individuals or groups
A significant decline in performance
Signs of self-harm
Significant change in wellbeing
Signs of assault
Unexplained injuries
Unexplained gifts or new possessions

These could indicate that children have been approached by, or are involved with individuals associated with criminal networks or gangs.

Indicators of CCE can include a child:

Appearing with unexplained gifts or new possessions
Associating with other young people involved in exploitation
Suffering from changes in emotional wellbeing
Misusing drugs and alcohol
Going missing for periods of time or regularly coming home late

If a member of staff suspects CCE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

7.2 Child Sexual Exploitation (CSE)

Child Sexual Exploitation is a form of child sexual abuse. It occurs when an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity:

a) in exchange for something the victim needs or wants; and/or

b) for the financial advantage or increased status of the perpetrator or facilitator.

The victim may have been sexually exploited even if the activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

The following list of indicators is not exhaustive or definitive, but it does highlight commons signs which can assist professionals in identifying children or young people who may be victims of CSE.

Signs include:

Underage sexual activity
Inappropriate sexual or sexualised behaviour
Sexually risky behaviour, ‘swapping’ sex
Repeat sexually transmitted infections
In girls, repeat pregnancy, abortions and miscarriage
Receiving unexplained gifts or gifts from unknown sources
Having multiple mobile phones and worrying about losing contact via mobile.
Having unaffordable new things (clothes, a mobile phone, etc), or expensive habits (alcohol, drugs, etc)
Changes in the way they dress
Going to hotels or other unusual locations to meet friends
Seen a known places of concern (eg. brothels)
Moving around the country, appearing in new towns, cities, not knowing where they are.
Getting in/out of different cars driven by unknown adults
Having older boyfriends/girlfriends
Contact with known perpetrators
Involved in abusive relationships, intimidated and fearful of certain people or situations.
Hanging out with groups of older people, or anti-social groups, or with other vulnerable peers.
Associating with other young people involved in sexual exploitation
Recruiting other young people to exploitative situations
Truancy, exclusion, disengagement.
Unexplained changes in behaviour or personality (chaotic, aggressive, sexual, etc)
Mood swings, volatile behaviour, emotional distress
Self harming, suicidal thoughts, suicide attempts, overdosing, eating disorders.
Drug or alcohol misuse
Getting involved in crime
Police involvement or policy records
Involved in gangs, gang fights, gang membership
Injuries from physical assault, physical restraint, sexual assault.

7.3 Honour-based Abuse: Forced Marriage (FM)

This is an entirely separate issue from arranged marriage. It is a human rights abuse and falls within the Crown Prosecution Service definition of domestic violence.

Young men and women can be at risk in affected ethnic groups. Evidence shows that the issue of forced marriage affect certain sectors of communities, typically girls in the age range of 14-16 years old originating from Pakistan, India an Bangladesh (approx 60% of the cases) together with a percentage of cases of children originating from the Middle-East and African countries. A signal of FM is the removal of children from school and lengthy absence which is often unexplained. Other indicators may be detected by changes in adolescent behaviours. Whistleblowing may come from younger siblings.

Any member of staff at KJFA with any concerns, should report this immediately to the DSL, who should raise the concern with the Local Police Safeguarding Unit by email or phone. Never attempt to intervene directly as a business or organisation or through a third party. Whilst the onus of he investigation for criminal offences will remain with the Police, the DSL should co-operate and liaise with the relevant agencies in line with current child protection responsibilities.

7.4 Honour-Based Abuse: Female Genital Mutilation (FGM)

There is a specific legal duty on all organisations with, and on, teachers regarding FGM. If, during the course of their work, a member of staff discovers that an act of FGM appears to have been carried out on a girl under the age of 18 years, then they must report it to the police. All staff at KJFA will recognise this responsibility.

The ‘One Chance’ Rule

As with forced marriage, there is the ‘One Chance’ rule regarding FGM. This refers to staff potentially only having one chance to speak to a potential victim and thus may only have one chance to save a life. It is essential that staff take action without delay.

What is FGM?

Female Genital Mutilation involves procedures that intentionally alter/injure the female genital organs for non-medical reasons.

Why is it carried out?

It is often based on a belief that FGM:

Brings status/respect to a girl -social acceptance for marriage. Preserves the girls virginity.
Is part of being a woman/rite of passage.
Upholds family honour
Cleanses and purifies the girl
Gives a sense of belonging to a community. Fulfills a religious requirement.
Perpetrates a custom/tradition
Helps girls be clean/hygenic
Is cosmetically desirable.
Is mistakenly believed to make childbirth easier.

FGM IS A CRIMINAL OFFENCE. There is no justification for this procedure. All staff at KJFA will be made aware of FGM practices and the need to look for signs and symptoms and other indicators of FGM. All staff have a mandatory responsibility to report FGM if they discover it (through disclosure, not physical examination) to the police and informing the DSL immediately who will support them, (the DDSL will take responsibility if the DSL is not available).

Circumstances and occurrances that may point to FGM happening include:

The child talking about getting ready for a special ceremony.
The child and their family taking a long trip abroad
The child’s family being from one of the ‘at risk’ communities for FGM (Kenya, Somalia, Sudan, Sierra Leon, Egypt, Nigeria, Eritrea, as well as non-african communities incuding Yemen, Afghanistan, Kurdistan, Indonesia and Pakistan).
Knowledge that the child’s sibling has undergone FGM
The child talking about going abroad to be ‘cut’ or to prepare for marriage.

Signs that may indicate a child has undergone FGM:

Prolonged absence from school or other activities
Behaviour change on return from a holiday abroad, such as being withdrawn and appearing subdued.
Bladder or menstrual problems.
Finding it difficult to sit still and looking uncomfortable
Complaining about pain between the legs
Mentioning something somebody did to them that they are not allowed to talk about
Secretive behaviour, including isolating themselves from the group
Reluctance to take part in physical activity
Repeated urinal infection
Disclosure

Further guidance and information are available from:

NSPCC FGM helpline, Contact days and times: 24 hours, TEL: 0800 028 3550

Email: fgmhelp@nspcc.org.uk

7.6 Peer-on-Peer abuse

All staff at KJFA will be made aware that children can abuse other children (referred to as peer-on-peer). This is most likely to include, but not limited to:

Bullying (including cyber bullying)
Physical abuse, such as hitting, biting, kicking, shaking, hair-pulling, or causing physical harm.
Sexual violence, such as rape, assault by penetration, and sexual assault
Sexual harrassment, such as sexual comments, remarks, jokes and online sexual harrassment, which may be stand-alone or part of a broader pattern of abuse.
Upskirting, which is a form of abuse that has been high on school and court agendas for a number of years and is a criminal offence in its own right under the Voyeurism (Offences) Act 2019. Unskirting occurs when someone takes a picture under a persons clothing, with or without underwear, without them knowing or without permission, with the intention of viewing their genitals or buttocks, to obtain sexual gratification or cause the victim humiliation, distress or alarm. It is a common aspect of peer-on-peer abuse and can happen to any gender.
Sexting (also known as youth produced sexual imagery)
Initiation/hazing type violence and rituals.

7.7 Sexting

Your responsibilities when responding to an incident:

If you are made aware of an incident involving sexting, you must report it to the DSL immediately.

You must not:

View, download or share the imagery yourself, or ask a pupil to share or download it. If you have already viewed the imagery by accident, you must report this to the DSL.
Delete the imagery or ask the pupil to delete it.
Ask the pupil(s) who are involved in the incident to disclose information regarding the imagery (this is the DSL’s responsibility)
Share information about the incident to other members of staff, the pupil(s) it involves, or their or other parents and/or carers
Say or do anything to blame or shame any young person involved.

You should explain that you need to report the incident, and reassure the pupil(s) that they will receive support and help from the DSL.

This policy on sexting should also be shared with the young people who use The Business’s services, so they are aware of the procedures that will follow an incident.

8. Procedure for Children identified as being ‘at risk’ or Vulnerable to Exploitation, Child Sexual Exploitation, Honour-based Abuse (forced marriage, FGM), Children who are at risk or involved in Violent Crime and Peer-on-Peer Abuse

Where risk factors are present but there is no evidence of a particular risk, the DSL/SPoA will advise staff on preventative work that can be done within The Business to engage the student into mainstream activities and social groups.

The DSL may well be the person who talks to the childs family whre appropriate, sharing their concerns about the childs vulnerability and how the family and The Business can work together to reduce the risk.

In this situation, depending on the level of concern and agreement with the parent and the child (as far as possible):

The DSL can decide to notify the Multi-Agency Safeguarding Hub (MASH) of the decision so that a strategic overview can be maintained and any themes or common factors can be recognised; and
The Business will review the situation after taking appropriate action to address the concerns. The DSL will also offer and seek advice about undertaking an early help assessment and/or making a referral to Social Services or involving the local safeguarding children’s board. If the concerns about the child are significant and meet the additional needs/complex need criteria, he/she will be referred to the MASH. This includes concerns about a child who is affected by the behaviour of a parent or other adult in their household.

9. Domestic Abuse

Domestic violence and abuse refer to 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, regardless of gender or sexuality.

All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children.

Operation Encompass

This initiative helps police and schools work together to provide emotional and practical help to children who have been involved in domestic abuse. When the police are called to an incident of domestic abuse, where there are children in the household who have experienced the domestic incident, the police wil inform the key adult (usually DSL) before the child or children arrive at school the next day. This ensures that the school has up to date and relevant information about the child’s circumstances and can enable support to be given to the child according to their needs.

Police forces not signed up to operation encompass will have their own arrangements in place.

10. Looked After Children

All staff at KJFA will have an awareness of issues around safeguarding looked after children. Katharine Jennings will ensure that staff have the skills, knowledge and understanding necessary to keep looked after children safe.

Staff will be aware of the legal status of a looked after child’s care arrangements. In particular, they will ensure that appropriate staff have the information they need in relation to a students looked after status (whether they are looked after under voluntary arrangements with consent of parents or an interim or full care order) and contact arrangements with birth parents or those with parental responsibility. The DSL will have details of the child’s social worker.

11. Children who Harm Other Children (Peer on Peer Abuse)

KJFA recognises that children are capable of abusing their peers. Examples of this may include when children are violent or cause danger towards other children.

It can also be when children sexually abuse or sexually harrass other children.

12. Confidentiality and Record Keeping

Staff at KJFA have a professional duty to share relevant information about the protection of children with the DSL and potentially external investigating agencies, where possible, under the guidance of the DSL.

If a child confides in a member of staff and requests thatthe information is kept secret, it is important that the member of staff tells the child sensitively that he/she has a responsibility to refer the matter to the DSL.

Accurate, signed and dated written notes must be kept of all incidents or Child Protection concerns relating to the child. If a member of staff has a child protection concern, they should inform the DSL or DDSL as soon as possible. These will be kept on the childs Child Protection File.

Child Protection records must be retained securely. Arrangement for Child Protection documentations must comply with the business Data Protection Policy together with data protection law and regulation applicable at the time. The DSL will ensure that all Child Protection records are held separately from other records. Child Protection files and documents will be stored securely, by encryption and/or password protecting electronic files or ensuring that paper records are in a locked cabinet with restricted access. Information from child protection files will only be shared with the relevant staff when it is necessary to do so and in a manner that is consistent with data protection law.

If The Business receives a request or direct access to, or copies of, documentation held on a Child Protection file, Katharine Jennings and/or the DDSL will be informed and a decision taken on the appropriate way forward in accordance with the Data Protection Policy (which is available on this website also).

13. Working with Parents/Individuals with Parental Responsibility

KJFA recognises the importance of working, where appropriate, in partnership with parents and carers to ensure the welfare and safety of the children.

We will therefore:

Make parents aware of our statutory role in safeguarding and promoting the welfare of children, including the duty to refer children on, where necessary, by making all policies available on the website and on request.
Work with parents to support the needs of the child.
Consider the safety of the child and, should a concern arise, the DSL has the responsibility to seek advise prior to contacting parents.
Aim to help parents understand that we have a responsibility for the welfare of all children and has a duty to refer cases to the Local Authority in the interests of the child as appropriate.
Ensure a robust complaints system is in place to deal with issues raised by parents and carers.
Provide advice and signpost parent and carers to other services where child need extra support.

14. Health and Safety

KJFA will ensure that there is a robust, up to date Health and Safety Policy and Procedure to meet the statutory responsibility for the safety of the children and staff. Katharine Jennings will identify and manage health and safety through the use of risk assessments, which are carried out:

On an annual basis for the space and environment indoors and outdoors
When there are any changes to the premises or practices
Following a serious accident in relation to staff and/or customers and/or children
When there is a high-level risk associated with contact with parents
To maintain effective security of the premises including protection from intruders, trespassers and/or criminal damage.

Visitors and contractors will be expected to be made aware of the arrangements for safeguarding and health and safety.

15. Monitoring and Reviewing of this Policy

The DSL will monitor the working of this policy and will report as required. It will be reviewed annually.

Appendix 1 – Staff Guidance

A. Procedures in respect of Child Abuse

Child abuse exists where children have been physically or emotionally abused or severely neglected. Abuse of children is likely to be noticed by staff and health workers or Education Welfare Officers. It is essential, therefore, that al those whos work brings them into contact with children and their families know the signs of child abuse and are aware of the procedures that they must follow the safeguard the child.

Part one of Keeping Children Safe in Education 2020 should be referred to for a list of those children who may need safeguarding support.

KJFA has the role of recognising and responding to potential indicators of abuse and neglect. All other action should be taken by those with statutory powers to help the child. Early contact and close liaison with such agencies are therefore regarded as essential by KJFA.

In the event of an actual or suspected case of child abuse by adults, parent, teachers or any other adult, it is the responsibility of staff to report this to the DSL as soon as possible. The DSL is responsible for ensuring that children are identified an the appropriate agency is involved. The DSL or Designated Safeguarding Officer (DSO) will attend any reviews called for by the Local Authority, and may call on appropriate members of staff for reports. It is important that if staff overhear children discussing abuse or neglect, that this information is relayed for investigation. Staff should not assume that somebody else will take action and must share information which might be critical in keeping children safe.

Guidance for all staff on dealing with disclosure/suspected abuse/neglect/sexual harrassment/sexual assault/violence/honour based abuse (FM or FGM)/children who are at risk from or involved with violent crime and peer-on-peer abuse

Dealing with disclosures of abuse

Always listen carefully and quietly. Do not press for any evidence at all.
Remain calm and reassuring. Do not dismiss the disclosure and do not show distress or concern.
Show that you care through open and reassuring facial expressions and body language.
Do not interrogate or ask leading questions (it could undermine a case later)
Ensure you take a written verbatim account of the child’s disclosure
Staff should be aware that written accounts could become part of a statutory assessment or criminal investigation.
Where there is an online element, the key consideration is for staff not to view or forward illegal images of a child. Where viewing images is unavoidable, the following link provides advice on how to respond: Overview_of_Sexting_Guidance.pdf (publishing.service.gov.uk)

2. At this point, staff should take the following steps:

Explain to the student that the disclosure must be reported – emphasise your trust in them.
Do not promise to keep the allegation secret or that ‘everything will be alright’.
Reassure them by telling them that they have done the right thing in telling you. Do not offer physical reassurance.
Do not admonish in any way e.g. ‘I wish you had told me sooner’
Inform the DSL immediately, initially verbally.
Under no circumstances discuss the matter with any other person. If the allegations prove to be untrue, any such discussion would be deemed defamatory. Information to staff is on a ‘need to know’ basis at the discretion of the DSL.
If the child agrees and it is appropriate, take them with you to the DSL
With the DSL, prepare a detailed report itemising:
- The information revealed by the child. It should not contain any opinion whatsoever
- Actions taken by yourself, including when the suspicions were reported, to whom the suspicions were reported and follow-up action taken within The Business
- Date and sign any written record or events and action taken and keep confidential and secure.
You must keep, in absolute confidence, a copy of the report, as will the DSL.
The DSL keeps Child Protection records centrally and securely and are not kept in the childs file.
The DSL is responsible for passing on these concerns to Children’s Services
Accurate records are essential in the event of further investigations.

3. If you see or hear something that is concerning:

don’t ignore it or assume that it is someone else’s responsibility to report it
Seek advice immediately from the DSL or DDSL

Don’t feel silly – if it worries you, someone else needs to know.
If it is something related to safeguarding, but not a child whose safety is immediately at risk, inform the DSL or DDSL in person and follow-up with a one-line email notifying the DSL that there is a safeguarding concern.
If it is related to a child being at risk, see the DSL or DDSL immediately and definitely before the child goes home that day, where possible.
All staff may raise concerns directly with Children’s Services if they feel an incident is not being dealt with appropriately or they are unable to locate the relevant staff.
Concerns about adults at KJFA should be made directly to the DSL, DDSL or if the DSL/DDSL are the subject of the concern, to report to the LADO.

4. Child Protection Procedures – Points of Action

4.1 If anyone discovers or suspects child abuse/peer on peer abuse/sexual vionlence/sexual harrassment, they must inform the DSL. The DSL will, in the appropriate manner and according to procedures, assess the situation.

4.2 The DSL will, if appropriate, take the following steps:

Where there is a report of peer on peer sexual violence, the DSL will make an immediate risk and needs assessment in accordance with part 5 of Keeping Children Safe in Education 2020. Where there is a report of sexual harrassment, the need for a risk assessment will be considered on a case by case basis.

Where it is clear that a Child Protection Referral (significant harm) is needed, they will contact Social Services without delay.

Where the DSL is not sure whether it is a Child Protection issue, or where the DSL needs to check the Child Protection register, they may seek advice from MASH (Multiagency Safeguarding Hub).

They will follow locally agreed protocols which can be found on the Local Authority Safeguarding Children’s Board (East Sussex Social Care Partnership or ESSCP website).

Appendix 2 – Information on Child Abuse and Categories of Abuse

All staff at KJFA should be aware that abuse, neglect and safeguarding issues are rarely stand alone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another.

Abuse

Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or n an institutional or community setting by those known to them or, more rarely, by others (eg. via the internet). They may be abused by an adult or adults or another child or children (peer on peer abuse).

In a situation where abuse is alleged to have been carried out by another peer, the child protection procedures outlined in this policy should be adhered to for both the victim and the alleged abuser. That is, it should be considered a child care and protection issue for both children.

All abusers must be held accountable for their behaviour and work must be done to ensure that abusers take responsibility for their behaviour and acknowledge that the behaviour is unacceptable. If there is any conflict of interest between the welfare of the alleged abuser and the victim, the victim’s welfare is of paramount importance.

Abusive behaviour that is perpetrated by peers must be taken seriously. It is known that some adult abusers begin abusing during childhood and adolescence, that significant numbers will have suffered abuse themselves, and that the abuse is likely to become progressively more serious. Early referral and intervention are therefore essential in line with paragraph 2 of this policy.

2. Peer on Peer abuse

Peer on peer abuse can manifest itself in many ways. All staff should be aware that children can abuse other children. This is most likely to include, but may not be limited to :

Bullying (including cyber bullying)
Physical abuse, such as hitting, biting, kicking, shaking, hair-pulling, or causing physical harm.
Sexual violence, such as rape, assault by penetration, and sexual assault
Sexual harrassment, such as sexual comments, remarks, jokes and online sexual harrassment, which may be stand-alone or part of a broader pattern of abuse.
Upskirting, which is a form of abuse that has been high on school and court agendas for a number of years and is a criminal offence in its own right under the Voyeurism (Offences) Act 2019. Unskirting occurs when someone takes a picture under a persons clothing, with or without underwear, without them knowing or without permission, with the intention of viewing their genitals or buttocks, to obtain sexual gratification or cause the victim humiliation, distress or alarm. It is a common aspect of peer-on-peer abuse and can happen to any gender.
Sexting (also known as youth produced sexual imagery)
Initiation/hazing type violence and rituals.

It could be through sexting using online communications, text, or image messaging. Please refer to the online safety policy for further information, referred to above.

3. Emotional Abuse

Emotional Abuse is the persistent emotional maltreatment of a child that causes the severe and persistent adverse effects on a childs development. It may involve conveying to children 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 child opportunity to express their views, deliberately silencing them, or making fun of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children.

These may include interactions that are beyond the child’s development capability, as well as over protection and limitation of exploring or learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying) causing children to frequently feel frightened or in danger, exploitation, or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

4. Sexual Abuse

Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may include 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 encouraging children looking at, or in the production of sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child 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 other children.

5. Neglect

Neglect is the persistant failure to meet a child’s basic or physical and/or psychological needs, which is likely to result in serious impairment of the child’s 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)
Protection from physical and emotional harm or danger
ensure adequate supervision (including the use of inadequate care givers)
Ensure access to appropriate medical care or treatment.

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

All staff and volunteers should be concerned abou a child if he/she presents indicators of possible significant harm. Training will be provided to all staff on the ‘signs of abuse’.

6. Signs of Abuse

The following non-specific, broad signs may indicate something is wrong:

Significant change in behaviour
Extreme anger or sadness
Aggressive and attention seeking behaviour
Suspicious bruises with unsatisfactory explanations
Lack of self-esteem
Self-injury
Depression
Inappropriate sexual behaviour
Child sexual Exploitation

7. Risk Indicators

The factors described in this section are frequently found in cases of child abuse. Their presence is not proof that abuse has occurred, but they:

must be regarded as indicators of the possibility of significant harm
Justify the need for careful assessment and discussion with the DSL.
May require consultation with and/or referral to Children’s Services

The absence of such indicators does not mean that abuse or neglect has not occurred. In an abusive relationship the child may:

Appear frightened of the parent/carer
Act in a way that is inappropriate to her/his age and development (though full account needs to be taken of different patterns of development and different ethnic groups). The parent or carer may:
- Persistently avoid child health promotion services and treatment of the child’s episodic illnesses.
- Have unrealistic expectations of the child, frequently complain about/to the child, and may fail to provide attention to or praise (high criticism/low warmth environment)
- Be absent or misusing substances
- Persistently refuse to allow access on home visits
- Be involved in domestic abuse

Staff should be aware of the potential risk to children when individuals, previously known or suspected to have abused children, move into the household.

8. Recognising Physical Abuse

The following are often regarded as indicators of concern:

An explanation which is inconsistent with an injury
Several different explanations provided for an injury
Unexplained delay in seeking treatment
The parents/carers are uninterested or undisturbed by an accident or injury
Parents are absent without good reason when their child is presented for treatment
Repeated presentation to minor injuries (which may represent a ‘cry for help’ and if ignored could lead to more serious injury)
Family use of different doctors and A&E departments
Reluctance to give information or mention previous injuries

9. Bruising

Children can have accidental bruising, but the following must be considered as non-accidental unless there is evidence or an adequate explanation provided:

Two simultaneous bruised eyes (rarely accidental, though a single bruised eye can be accidental or abuse)
Variation in colour possibly indicating injuries caused at different times
The outline of an object used eg. belt, handprints or a hairbrush
Bruising or tears around or behind, the earlobe(s) indicating injury by pulling or twisting.
Bruising around the face
Bruising on the arms, buttocks and thighs may be an indicator of sexual abuse

10. Bite Marks

Bite marks can leave clear impressions of teeth. Human bite marks are oval or crescent shaped. Those over 3cm in diameter are more likely to have been caused by an adult or older child. A medical opinion should be sought where there is any doubt over the origin of the bite.

11. Burns and Scalds

It can be difficult to distinguish between accidental and non-accidental burns and scalds and will always require experienced medical opinion. Any burn with a clear outline may be suspicious eg.:

Circular burns from cigarettes (but may be friction burns if along the bony protruberance of the spine)
Linear burns from hot metal rods or electrical fire elements
Burns of uniform depth over a large area
Scalds that have a line indicating immersion or poured liquid (a child getting into hot water of his/her own accord will struggle to get out and cause splash marks)
Old scars indicating previous burns/scalds which did not have appropriate treatment or adequate explanation.

12. Fractures

Fractures may cause pain, swelling and discolouration over a bone or joint. There are grounds for concern if:

The history provided is vague, non-existent or inconsistent with the fracture type.
There are associated old fractures
Medical attention is sought after a period of delay when the fracture has caused symptoms such as swelling, pain or loss of movement

13. Scars

A large number of scars, scars of different sizes or ages, and scars on different parts of the body may suggest abuse.

14. Recognising Emotional Abuse

Emotional abuse may be difficult to recognise, as the signs are usually behavioural rather than physical. The manifestations of emotional abuse might also suggest the present of other kinds of abuse.

The following may be indicators of emotional abuse:

Developmental delay
Abnormal attachment between a child and parent/carer eg anxious, indiscriminate, or not appropriate attachment
Indiscriminate attachment or failure to attach
Aggressive behaviour towards others
Scapegoating within the family, such as parent blaming the child for something bad that happened to them (eg. losing a job)
Frozen watchfulness
Low self-esteem and lack of confidence.
Withdrawn or seen as a ‘loner’ – difficulty relating to others
The indicators of emotional abuse are often also associated with other forms of abuse.

15. Recognising Signs of Sexual Abuse

Boys and girls of all ages may be sexually abused and are frequently scared to say anything due to guilt and/or fear. This is particularly difficult for a child to talk about and the full account should be taken of the cultural sensitivities of any individual child/family. Recognition can be difficult, unless the child discloses and is believed. There may be no physical signs and indications are likely to be emotional/behavioural.

Some behavioural indicators associated with this form of abuse are:

Inappropriate sexualised conduct
Sexually explicit behaviour, play or conversation, inappropriate to the child’s age.
Continual and inappropriate or excessive masturbation
self-harm (including eating disorder), self mutilation and suicide attempts.
Involvement in prostitution or indiscriminate choice of sexual partners.
An anxious unwillingness to remove clothes eg for sports events (but this may be related to cultural norms or physical difficulties).

Some physical indicators associated with this form of abuse are:

Pain or itching of genital area
Blood on underclothes
Pregnancy in a younger girl where the identity of the father is not disclosed.
Physical symptoms such as injuries to the genital or anal area, bruising to the buttocks abdomen, and thighs and sexually transmitted disease.

16. 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. This may also include online sexual harrassment. This may be stand alone or part of a wider pattern of sexual harrassment and/or sexual violence .

It may include:

Non-consensual sharing of sexual images and videos
Sexualised online bullying
Unwanted sexual comments and messages, including on social media
Sexual exploitation
Coercion and threats.

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, inappropriate 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 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 includes any behaviour involving coercion, threats, or aggression together with secrecy, or where one participant relies on an unequal power base.

17. Assessment

In order to more fully determine the nature of an incident and the presence of exploitation, the following actors should be given consideration:

Equality – consider differentials of physical, cognitive and emotional development, power and control and authority, passive and assertive tendancies.
Consent – consider whether an incident appeared consensual or non-consensual, keeping in mind that consent means willing agreement. This requires consideration of all the following:
- Understanding that is 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 competance
Coercion – a 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 regarding of victim resistance.

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

18. Recognising Neglect

Evidence of neglect is built up over a period of time and can cover differnt aspects of parenting.

Indicators include:

Failure by parents or carers to meet the basic essential needs eg. adequate food, clothes, warmth, hygiene and medical care
A child seen to be listless, apathetic, and irresponsive with no apparent medical cause.
Failure of the child to grow within normal expected pattern, with accompanying weight loss.
Child thrives away from home environment
Child frequently absent from school
Child left with adults who are intoxicated or violent
Child abandoned or left alone for excessive periods.

Appendix 3 – Statutory Duty and Guidance Documents

This policy sets out how KJFA will meet it statutory duty to safeguard and promote the welfare of children who use our services. It has been developed in accordance with the law and guidance found a http://www.gov.uk that seeks to protect children.

Further guidance in relating to safeguarding topics covered in this policy include:

Keeping Children Safe in Education
Working Together to Safeguard Children
Multi-agency Statutory Guidance on FGM
Teaching online Safety
Information about mandatory reporting of FGM
Protecting Children from Radicalisation: The Prevent Duty
Prevent Duty Guidance: England and Wales
Inspecting Safeguarding in early years, education and skills settings
Competence Still Matters: Safeguarding Training for staff and volunteers
Preventing Youth Violence and Gang involvement
Safeguarding Best Practice

The laws and statutes that apply are:

Keeping Children Safe in Education 2020
Working Together to Safeguard Children (2018)
Governance Handbook
Data Protection Act 2018
The Children Act 1989 (Amendment 2004)
Female Genital Mutilation Act 2003, Section 5B(1)
Section 74, Serious Crime Act 2015
The Rehabilitation of Offenders Act 1975
Section 4, Safeguarding Vulnerable Groups Act 2006
PREVENT Duties under the Counter Terrorism and Security Act 2015
Sexual Offences Act 2003

If anyone wishes to seek further information or guidance, they can refer to the above documents.

Appendix 4 – Summary of procedures and guidance for cases involving child on child sexual violence and sexual harrassment from the Keeping Children Safe in Education Act 2020

The following is taken from Part 5 of the Keeping Children Safe in Education Act 2020 and is guidance for staff of KJFA to follow when discussing and reporting concerns and talking to the children of concern.

When talking to a child of concern, who you suspect has been the subject of sexual violence, harrassment or abuse:

Don’t promise confidentiality at this initial stage, as it is very likely a concern wil have to be shared further (for example, with the DSL or Children’s social care) to discuss the next steps.
Only shar the report with those people who are necessary in order to progress it.
Ensure the victim understands what the next steps will be and who the report will be passed to.
Recognise that a child is likely to disclose to someone they trust, so be supportive and respectful of the child.
Listen carefully in a non-judgemental way, being clear about boundaries and how the report will be progressed.
Don’t ask leading questions
Consider the best way to make the report. Write up the report after the conversation with the child and not during.
Only record the facts without opinion and without using statements, such as ‘appropriate’ or ‘inappropriate’.
Do not view or share any illegal images and if this is unavoidable due to accidentally viewing them, inform the DSL immediately.
Report to the DSL in all instances and if they are not available to the DDSL.
If the DSL is the subject of concern, or the DDSL, seek advice from LADO.
When reporting sexual violence, harrassment or abuse, ensure the DSL makes an immediate risk and need assessment. This should consider the victim, especially their protection and support, the alleged perpetrator and all the other children at the setting.
Risk assessments should be kept and reviewed annually.
All reports should include the childs name, age, ethnicity and factual details of the conversation and should be dated and signed by the staff member reporting.
All reports must be directed to the DSL or DDSL, whoever is available, and kept securely either electronically with password or pin or within a locked cabinet.

This policy is dated 9th March 2023 and will be reviewed in March 2024.

Katharine Jennings Fine Art