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|Author :||Emma Silvestri-Fox|
|Reviewed By :||Simon Milner|
|Date :||September 2021|
|Shared with Staff :||September 2021|
|Shared with Governors :||September 2021|
|Next Review :||September 2022|
Keeping children safe in education, schools and colleges is everyone’s responsibility...at all times, the child’s best interests is the paramount consideration.
The College will take all reasonable measures to:
All students should have the opportunity to excel in their learning and achievement. Outcomes that are key to students’ wellbeing are to:
To achieve these aims our policies, systems and procedures are designed to:
‘All staff should be aware of the importance of an early help approach in meeting children’s needs and understanding that it is more effective for children when adults recognize emerging problems early rather than reacting later. Early help means providing support as soon as a problem emerges...’ (Keeping Children Safe in Education CYPES, May 2021)
Underpinning Principles from the Education Department’s Child Protection Policy
(Education Child Protection Policy, 2016)
At JCG, we work in partnership with States of Jersey Police and Children’s Services to identify and provide appropriate support to students who have experienced domestic abuse (DA) in their household. In line with CYPES’ Keeping Children Safe In Education (May 2021) guidance, we ‘treat and manage disclosures of DA as a serious safeguarding concern’, and we make appropriate use of the ‘types of Overt or Silent Support for children living with domestic abuse’ outlined in Appendix C of that document.
In order to achieve this, the Jersey Multi-agency Safeguarding Hub (MASH) will share with the Designated Safeguarding Lead(s) in school police information of all domestic incidents where one of our students has been present. On receipt of any information, the Designated Safeguarding Lead will decide on the appropriate support the child requires. We record this information and store it securely. (Please see Appendix 8: Domestic Abuse Notification Protocol SOJP)
Systems and Procedures
1.Staff have a responsibility to familiarise themselves with the guidelines determined by Education. This is available as part of the Education Child Protection Policy located digitally here.
2. Staff have a responsibility to familiarise themselves with Part One of CYPES Keeping Children Safe in Education (May 2021)
3. Every complaint or suspicion of abuse from within or outside the College will be taken seriously and, in line with published Jersey thresholds, will be referred to Children and Family Hub/MASH, without investigation within the school. In these cases, the following referral procedures apply:
4. Following our reporting procedure, it is essential that any information or concerns regarding Child Protection is communicated to the Designated Safeguarding Lead or the Principal. A referral should be made/logged through MyConcern.
5. Following our procedures for dealing with disclosure, when a student discloses information, members of staff must:
6. Staff should be aware of online safety procedures and positively communicate the importance of maintaining e-safety in the use of technology and the Internet. (See Appendix 9 regarding online safety)
7. Staff should be mindful of the Staff Guidelines for safe practice. (See Appendix 6 Staff Guidelines)
8. Recruiting Procedures and policy for DBS checks are followed.
Types of abuse
(Taken from CYPES’ Keeping Children Safe in Education, May 2021)
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 in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children.
There are four types of child abuse which are commonly identified as:
Signs of abuse
Possible signs of abuse include the following (but are not limited to and do not necessarily mean that abuse is occurring):
Signs of grooming, sexual exploitation or sexual abuse
The signs of grooming aren’t always obvious. Groomers will also go to great lengths not to be identified. Children may:
In older children, signs of grooming can easily be mistaken for 'normal' teenage behaviour, but unexplained changes in behaviour or personality, or inappropriate sexual behaviour for their age may be observed. Further guidance is given in
Specific Safeguarding Issues
Gangs and serious youth violence
A gang is defined as a group of young people who spend time together, often fighting other groups or involved in anti-social behaviour. Youth violence refers to harmful behaviours that can start early and continue into adulthood. The young person can be a victim, an offender, or witness the violence. Youth violence includes various behaviours including some violent acts such as bullying, slapping or hitting. These behaviours can cause more emotional harm than physical harm. Others, such as robbery and assault (with or without weapons) can lead to serious injury or even death. All staff should be aware of indicators, which may signal that children are at risk from, or are involved with serious violent crime. These may include increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs.
Female Genital Mutilation (FGM)
Whilst all staff should speak to the designated safeguarding lead (or deputy) with regard to any concerns about FGM, there is a specific legal duty on teachers. If a teacher discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report it to the police. There is a range of potential indications that a girl may be at risk or has already suffered from FGM. Further information is available on p. 42 of Keeping Children Safe in Education Annex A (May 2021).
Safeguarding incidents and/or behaviours can be associated with factors outside the college (and the home) and/or can occur between children outside the school. All staff, but especially the Designated Safeguarding Lead (and deputy) should be considering the context within which such incidents and/or behaviours occur. This is known as contextual safeguarding, which means assessments of children should consider whether wider environmental factors are present in a child’s life that are a threat to their safety and/or welfare. The school needs to provide as much information as possible as part of the referral process to Children and Families Hub / Early Help.
Child Sexual Exploitation (CSE), Child Criminal Exploitation (CCE) and various kinds of risk-taking behaviour can all constitute contextual safeguarding concerns.
Special Educational Needs
Children with special educational needs (SEN) and disabilities can face additional safeguarding challenges. In the UK, children with Special Educational Needs and Disabilities (SEND) are three times more likely to be abused than their peers. Additional barriers can exist when recognising abuse and neglect in this group of children. This can include:
Further guidance can be found on pp. 37-38 of CYPES’ Keeping Children Safe in Education (May 2021).
‘Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.’ (Keeping Children Safe in Education, DFE, 2021)
The College takes a proactive approach to promoting resilience and promoting well-being through its commitment to character education across the curriculum.
The Association of Chief Police Officers (ACPO) defines missing as:
‘Not at the place they are expected to be, but the circumstances are out of character. The context suggests they may be subject of a crime or at risk or harm to themselves or others.’
A child going missing from education is a potential indicator of abuse or other underlying welfare concerns Students are registered in accordance with Education Department requirements and the school has procedures in place to deal with students who go missing. These procedures are outlined in Appendix 5 of the Education Department’s Attendance Policy 2019: Children Missing in Education. See also pp. 32-33 of CYPES Keeping Children Safe in Education (May 2021).
Peer on peer / child on child abuse
All staff should be aware that safeguarding issues can manifest themselves via peer on peer abuse. This is most likely to include, but is not limited to:
All peer on peer abuse is unacceptable and will be taken seriously; it will never be minimised as ‘banter’, ‘having a laugh’ or ‘part of growing up.’ Staff must be aware that children may be abused out of school, but should not minimise the potential risks of girl on girl abuse.
In relation to nude and semi-nude images, a key consideration is for staff not to view or forward illegal images of a child (see Appendix 3 for further guidance).
All students can report abuse (e.g. bullying or harassment) through the College website’s Report a Concern function, as well as by speaking to any member of staff: https://digitaljcg.typeform.com/to/SlBD2DJy
Sexual violence and sexual harassment between children
Sexual harassment is unwanted conduct of a sexual nature which has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Sexual harassment can occur online and offline and both inside and outside of College.
All staff should be mindful of the following DFE guidance:
‘Sexual violence and sexual harassment can occur between two children of any age and sex from primary through to secondary stage and into colleges. It can occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Sexual violence and sexual harassment exist on a continuum and may overlap; they can occur online and face to face (both physically and verbally) and are never acceptable...all staff working with children are advised to maintain an attitude of ‘it could happen here’. (Sexual violence and sexual harassment between children in schools and colleges, DFE, September 2021)
These additional points of guidance are taken from the same DFE publication, and will guide the response of the DSL and all staff to any incident of sexual violence/harassment between children:
Procedures to minimise the risk of peer on peer abuse
Staff should always be clear that abuse is abuse and should never be tolerated or passed off a “banter” or “part of growing up” (see the guidance above) and should be aware of the importance of challenging such behaviours. Tolerating or dismissing such behaviours risks normalising them. Form tutors discuss pastoral cases with Heads of School as they arise and during regular tutor meetings, some of which may relate to peer on peer abuse.
The pastoral curriculum (form time, PSHE, year assemblies) provides opportunities to teach students about appropriate and safe relationships. Topics include relational aggression, kindness, bullying, friendships, healthy relationships, radicalisation and grooming. There are other opportunities for discussion throughout the academic year (Just Be group, Pastoral Prefect meetings, Student Council).
Staff are on patrol duty during break time and lunchtime supervisors are on duty to minimise the risk of adult-free zones. CCTV is in operation in designated areas of the College and footage may be accessed as part of an investigation. The student support team and site team regularly liaise when a need arises to make an area of the school more accessible and visible.
Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. ‘Extremism’ is defined as vocal or active opposition to fundamental values, including the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. All staff are subject to the Prevent duty: they must have due regard to the need to prevent people from being drawn into terrorism.
Signs of radicalisation
There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. It can happen in many different ways and settings. Background factors may contribute to vulnerability which are often combined with background influences such as family, friends or online, and with particular needs for which an extremist or terrorist group may appear to provide an answer. The internet and the use of social media in particular has become a major factor in the radicalisation of young people.
As outlined in CYPES’ Keeping Children Safe in Education (May 2021), thee following issues may make an individual vulnerable to radicalisation:
The following are possible early indicators of radicalisation:
Students who are at risk of radicalisation may have low self-esteem or be victims of bullying or discrimination. As with managing other safeguarding risks, staff should be alert to changes in students’ behaviour which could indicate that they may be in need of help or protection. Staff should use their professional judgement in identifying children who might be at risk of radicalisation and act proportionately. This may include making a referral to Children and Families Hub/ MASH through the Designated Safeguarding Lead with whom they should discuss their concerns.
The Designated Safeguarding Lead and the Principal are undertaking Prevent awareness training (September 2021), and a Deputy DSL (ESF) has already undertaken this training. These colleagues able to provide advice and support to other members of staff on protecting children from the risk of radicalisation.
Suitable filtering is reviewed to keep students safe from terrorist and extremist material when accessing the internet in College.
Online Safety: online safety is explicitly addressed in the staff induction process for new staff; staff are regularly updated through tutor meetings and staff meeting. Online safety features in our PSHE programme for students.
If a member of staff is concerned that a pupil may be exposed to radicalisation the normal referral processes apply, i.e. they should discuss it with the Designated Safeguarding Lead who will follow the safeguarding procedures outlined in this policy.
The use of technology is a significant component of many safeguarding issues, including CSE, sexual predation and radicalisation. The breadth of issues classified within online safety can be categorised into four areas of risk
In seeking to manage online safety, College should have appropriate filters and monitoring systems in place, and give due consideration to the student age range, their frequency of access and the proportionality of costs vs risks.
For further guidance, see Appendix E of CYPES Keeping Children Safe in Education (May 2021).
All staff are required to report to the DSL, Principal (or if they are not available and the matter is urgent, a member of the Senior Leadership Team) any concern or allegations about College practices or the behaviour of colleagues which are likely to put students at risk of abuse or other serious harm. If the member of staff feels unable to raise their concern with the DSL, Principal (or a member of SLT), they should contact the Chair of Governors. There will be no retribution or disciplinary action taken against a member of staff for making such a report provided that it is done in good faith. Malicious allegations may be considered as a disciplinary offence.
What staff should do if they have concerns about a child or receive a complaint of abuse
Please see Appendix 3.
Child Protection Training
All new staff will be given guidelines and procedures during their induction period. New staff will access one day Foundation Level CP training as soon as possible, organised centrally by the Education Department.
GTTP beginning teachers and NQTs will receive training from Education as part of their induction programme.
A rolling programme of child protection training aims to train all staff, volunteers and members of the governing body to Foundation level and provide a cycle of refresher training sessions. Staff will complete an annual online refresher, using platforms such as National College or the Virtual College. Certificates to be forwarded to Designated Safeguarding Lead as proof of completion and collated by a member of the admin team.
Heads of School will access training at Level 3, as they serve as Deputy DSLs within their area of the College.
The Designated Safeguarding Lead (DSL) will undergo the DSL training course and any other safeguarding training at Level 3 and above to provide them with the knowledge and skills required to carry out the role
Where appropriate, individual staff may access further relevant training.
Roles and Responsibilities
Students should be encouraged to take responsibility for:
All staff have responsibility for:
The Designated Safeguarding Lead has responsibility for:
For a full account of the role of the DSL, see Appendix D of CYPES’ Keeping Children Safe in Education (May 2021)
The SLT has responsibility for:
The Principal has responsibility for:
Data, Referrals and Record Keeping
All concerns, discussions and decisions made and the reasons for those decisions should be recorded contemporaneously using My Concern. If in doubt about recording requirements, staff should discuss with the designated safeguarding lead.
Action by the Designated Safeguarding Lead on receiving a notification of concern/ complaint of abuse
Options may include the following: managing any support for the child internally via the College's own student support processes; an early help assessment; or a referral to the Children and Families Hub. The Designated Safeguarding Lead will, when taking action:
Types of referral
There are different types of referral procedures according to the nature of the disclosure made.
Where a child has suffered or is at risk of harm and the matter does not involve a member of staff, a referral will be made to Children and Families Hub/MASH as soon as possible.
Where there are concerns about a member of staff’s suitability to work with children, a referral will be made to MASH who will inform the JDO.
If the child is considered to be a concern and is not at risk of suffering immediate significant harm but requires additional support (e.g. Early Help or pastoral support), the Designated Safeguarding Lead will refer the child to the relevant agency. Where a child and family would benefit from coordinated support from more than one agency (for example education, health, housing, police) there should be a referral to Early Help.
Where a disclosure relates to the mental health of a student and she is at risk from herself rather than a third party, the Designated Safeguarding Lead will refer to CAMHS and parental consent will be sought. Where a student is already accessing care from CAMHS the DSL or appropriate member of the Student Support Teams will raise the concern with CAMHS.
See Appendix 4 for a flow chart detailing different responses to concerns being identified about a child.
Student child protection records:
The College will keep all child protection records confidential, allowing disclosure only to those who need the information in order to safeguard and promote the welfare of children. The College will co-operate with police and social services to ensure that all relevant information is shared for the purposes of child protection investigations and in accordance with the requirements of Working Together To Safeguard Children (July 2018).The Designated Safeguarding Lead will ensure that if a student who is subject to a child protection plan moves to another school, their child protection file will be transferred securely to a designated contact at the new school and confirmation of safe receipt obtained.
Engaging Students in Learning about Safeguarding
Listening to students:
The College provides a range of opportunities for students to be listened to. Tutor groups throughout the College ensure that there is regular contact time between tutor and tutees at daily registration and for extended tutor periods up to three times a week. Weekly PSHE lessons for students in Y7-10 seek to create an environment where students can share any concerns. A ‘Who can I talk to?’ document outlines the support system within the College and identifies key members of staff in the student support team, including school counsellors. This document is available to view on tutor room noticeboards. The College employs two counsellors (providing full time cover). Students may self-refer to the counsellors. Parental permission is sought for referrals to CAMHS services for students under the age of 16.
Teaching students about safeguarding:
Students are taught about a range of safeguarding issues (including online safety, substance misuse, child sexual exploitation, grooming, mental health, self-harm and bullying, relationship education, relationships and sex education and health education) through their PSHE lessons, visiting speakers and the assembly, tutorial and Elective programmes. Students are taught how to identify risks and how to adjust their behaviour in order to mitigate these risks and build resilience. Certain safeguarding issues are covered in the delivery of Relationships and Sex Education (RSE). Resilience to radicalisation is taught through PSHE by promoting fundamental values and enabling students to challenge extremist views. Suitable filtering and monitoring is in place to protect students from online abuse on the school networks.
The College recognises that the evaluation of risks and putting in place steps to mitigate against these risks contributes to promoting the welfare and protection of students. For hazardous activities and curricular and co-curricular activities that may pose specific risks, risk assessments are carried out in accordance with the College’s Health and Safety policy and reviewed as required. Risk assessments for school trips and visits are reviewed by the Assistant Headteacher (Organisation). Students who are at risk of harm are either referred to external agencies in accordance with these procedures and/or if the student is at risk of harm from themselves, the Designated Safeguarding Lead will assess the risk and may put in place a safety plan that will be shared with relevant teachers.
All visitors must sign in and sign out on departure and are escorted whilst on College premises by a member of staff or appropriately DBS checked volunteer, unless they have a current DBS certificate which is presented on arrival. All visitors are given a name badge with the title ‘Visitor’ which must be clearly displayed and worn at all times whilst on the College premises.
The College takes all practicable steps to ensure that College premises are as secure as circumstances permit.
Monitoring and review
Any safeguarding incidents at the College will be followed by a review of the safeguarding procedures within the School (which will include a review of this policy) to determine whether any improvements can be made to prevent a similar event from occurring in the future. Such reviews of safeguarding incidents are a standing item on the agenda of Student Support Team meetinngs.
In addition, the Designated Safeguarding Lead will monitor the operation of this policy and its procedures and undertake an annual review of this policy and the College's safeguarding procedures.
Relationship to other policies
External Policies and other useful documents:
|Appendix 1||Threshold Criteria & Assessment Grids
|Appendix 2||MyConcern User Guide
||What staff should do if they have concerns about a child or receive a complaint of abuse
||Concerns about a child flow chart
||Emergency Contact List
||Police Involvement in Schools Procedure
||Domestic Abuse Notification Protocol (extract)
||Online Safety Policy
||Student Acceptable Use agreement (appendix to Online Safety Policy)
||Staff Acceptable Use agreement (appendix to Online Safety Policy)
||Confirmation of receipt and reading of policy
The Assessment Framework (ED Child Protection Policy)
The Assessment Framework will assist professionals in identifying those children with extra needs and enable them to make appropriate referrals to agencies on behalf of the child. Where possible, this should be completed in consultation and partnership with the parent, carer and/or young person according to their capacity.
Staff are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a child, staff should always act in the best interests of the child. Staff should approach all concerns about students with a mindset of see/hear it, believe it, do something about it (as outlined below).
Concerns / initial complaint of abuse:
Staff should act on their concerns immediately and:
For urgent concerns, the member of staff should seek the DSL or a deputy in person immediately, and:
Sexting / sharing nude and semi-nude images
Sexting is defined as the production of and/or sharing of sexual photos and videos of and by young people who are under the age of 18. Staff who are aware of an incident involving sexting should:
All evidence, (for example, scribbled notes, mobile phones containing text messages, clothing, computers), must be safeguarded and preserved and given to the DSL
All suspicion or complaints of abuse must be reported to the Designated Safeguarding Lead or Deputy Designated Safeguarding Lead, or if the complaint involves a member of staff, to the Principal. Details of procedures for reporting allegations against members of staff are given on page 4 of this policy. If in exceptional circumstances you are not able to speak to the Designated Safeguarding Lead, the Deputy Designated Safeguarding Lead or the Principal, you should speak to your line manager. If there is risk of immediate serious harm to a child and you are not able to follow this referral procedure, contact Children and Families Hub/MASH. Please see Emergency contact list at Appendix 5 for emergency contact details. Anybody can make a referral. If there is an immediate emergency, dial 999 and report the matter to the police.
Supporting Principles relating to any Safeguarding Disclosure:
For further guidance, see ‘Recognition and dealing with disclosures’ in CYPES’ Keeping Children Safe in Education (May 2021)
Report and Record
In the event of a serious disclosure from a child, the following is a list of people or agencies who must be contacted immediately regardless of meetings, etc. The immediate safety of a child or student is always our priority.
1. Senior Leadership Team
|Simon Milner||Designated Safeguarding Lead||Ext 207||516207||07797 750715|
|Carl Howarth||Principal||Ext 204||516204||07797 922662|
|Emma Silvestri-Fox||Assistant Head and Deputy DSL||Ext 216||516216||07797 818030|
|Peter Marett||Assistant Head and Deputy DSL||Ext 261||516261||07797 745490|
|Toni Rollo||Vice Principal||Ext 214||516214||07797 788724|
|Ruth Lea||Assistant Head||Ext 268||516268||07829 738340|
If none of the above can be contacted
2. Children and Families Hub – 519000
“Words to the effect of …“As the result of a serious disclosure from a child at our school, we have concerns about that child’s safety.”
If the Hub cannot be contacted directly - (If you get the voicemail – state that you will be phoning the Police)
3. States of Jersey Police Child Protection Unit – 612612 or 999
Staff have a duty to deal with any child protection issue that may arise and also to avoid any activity that may reasonably raise concerns as to their propriety. Examples might include students drinking alcohol with staff, being invited to their homes or allowing access to inappropriate materials or internet sites. Any member of staff who is aware of such activities should report them to a senior colleague or the DSL. This should include what the DFE’s Keeping Children Safe in Education (2021) refers to as a ‘low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’’. Ensuring such low-level concerns are appropriately shared and ‘dealt with effectively should also protect those working in or on behalf of schools and colleges from potential false allegations or misunderstandings.’
Any individual contact with students out of education settings should only be done with the prior knowledge of parents and senior colleagues. Staff should make every effort to avoid being in a situation where they are alone with a student in an isolated area, talking with a student in a closed room without others being aware of or being on their own with a student in a car or minibus.
This includes gender related comments about a student’s physical attributes; unwelcome or gratuitous physical contact; suggestive or offensive remarks or innuendos about students of a specific sex; propositions of physical intimacy; gender related verbal abuse; threats or taunting; bragging about sexual prowess; requests for dates or sexual favours; offensive jokes or comments of a sexual nature about a student; displays of sexually offensive pictures, graffiti or other materials; highly personal questions or discussions about sexual activities; rough and vulgar humour or language related to gender; repeated “compliments” regarding a student’s appearance, hair and clothes.
In common law, a member of staff is held to a higher standard of conduct than many other members of society. A member of staff’s sexual relationship with a student is regarded as professional misconduct. Any such relationship or conduct directed at establishing a relationship are prohibited. Activities such as sending intimate letters or e-mails from a member of staff to a student, personal telephone calls, suggestive comments and dating are unacceptable. Staff receiving inappropriate communication from students should report the matter to the DSL, or another member of the SLT, who will investigate and deal with it appropriately.
Physical restraint of students is part of a range of strategies available to manage challenging behaviour and to protect the safety of children. The Education Restraint Policy is included in the Special Educational Needs Policy. A link to this policy can be found in the ‘Relationship to other Policies’ section of this document.
Restraint should only be used as a last resort after other strategies included in the school’s behaviour policy. Physical restraint always carries a risk that the child or staff may be damaged, physically or emotionally. Inappropriate or excessive use of restraint can lead to an allegation of assault. For further details, see pp. 35-36 of CYPES’ Keeping Children Safe in Education (May 2021).
Physical Contact and Intervention
Have another person present
Use restraint in anger
Defuse the situation – ‘talking down’
Adopt a threatening stance
Use physical restraint as a last resort
Be aware of gender and cultural issues
Restrain by tying or binding
Use MINIMUM amount of reasonable force
Search a student or their property without appropriate advice and ensuring that a Head of School or the DSL is with you
Continually offer the child the opportunity to regain self-control
Hit or shake a student, pull hair, hold arms behind back or squeeze excessively
Ensure a written report is compiled following the use of any restraint
Inform DSL after the incident
Photography, Videos and Other Creative Arts
Many activities involve recording images. These may be undertaken as part of the curriculum, extra school activities, for publicity and to celebrate achievement. Staff need to be aware of the potential for these occasions to be misused for pornographic or “grooming” purposes. Careful consideration should be given as to how these activities are organised and undertaken. Using images of children for publicity purposes will require the consent of parents. Images should not be displayed on websites, in publications or in a public place without such consent. When using a photograph for publicity purposes the following guidance should be followed:
Further advice is available in the Education ‘Policy and Guidance on Use of Images: photographs, videos, CCTV and web cams.’
Online-safety - Internet Use
The College has a clear procedure regarding access to and the use of the Internet and have regard to Education guidance. Staff should also refer to the schools’ e-safety policy, including the Acceptable Use Agreement (AUA).
Under no circumstance should staff in Education settings access inappropriate images. Accessing child pornography or indecent images of children on the Internet and making, storing or disseminating such material is illegal.
Using Education equipment to access inappropriate or indecent material, including adult pornography, is unacceptable.
Education advises staff to exercise caution when communicating with children and young people using the Internet or mobile technology. Staff should only use official Education email accounts to talk to students online so that any communication is logged. It may be appropriate to set up a site to communicate in some circumstances, for example, to arrange sporting fixtures or for a particular curricular activity but staff should ensure their line manager or SLT is aware of this and that it is shared with other staff.
Staff should also only communicate on school matters as personal communication could be considered to be inappropriate.
Students might try to include staff in their ‘friends’ list on their online social network or get hold of a personal email address or mobile number. Staff should be cautious about this as there are inherent risks in staff using such sites to communicate with students in respect of the potential overlap between their personal and professional lives. Staff should refer any concerns to the DSL.
The Education Department has a policy on Police Involvement in Schools.
A copy of the full policy is available at the link in the ‘Relationship to other policies’ section of this document. Please see below a summary of key points:
Contacting the Police
Should an event occur which requires Police involvement, then please speak to a Senior Leader at school. The Senior Leader will decide whether the police should be contacted.
The Senior Leader will
Schools are encouraged to deal with minor incidents internally, using the Improving Behaviour Policy.
If an incident is deemed serious enough to contact the police, then all interviews with those suspected of being involved in the crime must stop until the Police arrive.
Receiving a call from the Police/Social Services
General phone calls - When anyone calls and speaks to any member of JCG staff, saying that they are from the Police or Social Services
This protocol sets out a joint-agency procedure to provide, by early intervention, appropriate support for children and young people who have experienced domestic abuse in their household.
Child/young person in this document refers to any child under the age of 18 years.
What is domestic abuse?
This definition was provided by the UK Home Office and was adopted in Jersey on 1st January 2013.
Any incident or pattern of incident of controlling, coercive or 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. This can encompass, but is not limited to, the following types of abuse:
Domestic Abuse is a safeguarding children issue: statistics show that the States of Jersey Police [SOJP] attend between 900 – 1100 domestic incidents a year and that around 45% of these involve children within the household or linked to the involved parents. It therefore follows that a number of these children will be ill-prepared to deal with school either the following day or on a Monday morning.
Witnessing domestic abuse is distressing for a child, who can often see the abuse, hear it from another room, see a parent’s injuries or distress afterwards or be physically hurt trying to stop the abuse.
The emotional responses of children who witness domestic abuse may include fear, guilt, shame, sleep disturbances, sadness, depression, and anger.
Research tells us that domestic abuse may have a long term psychological and emotional impact on children.
This protocol supports the implementation of working partnerships between the SOJP and the Education Department, in this case the Education MASH researcher. The protocol sets out how information will be shared between the SOJP and the Education MASH researcher who has links with every school in Jersey.
With an ethos based on ‘safeguarding children and promoting the welfare of children’, the SOJP will inform the Education MASH researcher about any domestic abuse incidents where a child has been present to allow the school to take appropriate steps to support the child during what could be an emotionally difficult day and ensure support as needed continues.
Schools can then ensure support mechanisms are in place for the child. In its simplest form, given some leeway, comfort and support. This makes a huge difference to children. It also allows children the opportunity to talk about their experience in the knowledge that a safe adult in school understands what is happening in their lives.
It is felt that the numbers of incidents can be managed through existing information sharing protocols, in this case from PPU to Education MASH researcher. The Education MASH researcher will then be expected to share information with relevant schools.
The information shared will only be what is required to safeguard the child or, and would include:
This Protocol does not replace or supersede existing protocols, or singularly address child welfare. The Protocol should always be followed in conjunction with the current safeguarding procedures and practitioner’s guidelines found here and is in place to ensure the child’s welfare is safeguarded and promoted.
By sharing this information, children who are experiencing domestic abuse will have access to responsive support after a domestic abuse incident. Schools will receive information when:
This knowledge, given to the schools by the Education MASH researcher allows the provision of silent or overt support dependent upon the needs and wishes of the child.
Professionals can only work together effectively to protect children if there is an exchange of relevant information between them. This has been recognised by the courts in Jersey (see X v Minister for Health and Social Services  JRC252).
Any disclosure of personal information to others must always have regard to the Law. This Protocol sets out the legal position of PPU, Education MASH researcher and schools in relation to exchanging and sharing of information.
Law of Confidentiality
Personal information about individuals held by PPU is subject to the legal duty of confidence, and should not normally be disclosed without the consent of the subject. However, the law permits the disclosure of confidential information where a countervailing public interest can be identified. Such a public interest might relate to the proper administration of justice and to the prevention of wrongdoing. The court in R v Chief Constable of North Wales Police, ex parte Thorpe  QB 396 Lord Bingham CJ considered that where a public body acquires information relating to a member of the public which is not generally available and is potentially damaging, the body ought not to disclose such information save for the purpose of and to the extent necessary for performance of its public duty or enabling some other public body to perform its public duty.
There is a public interest in the safeguarding of children. Both Jersey case law and the Data Protection (Jersey) Law 2005 recognise that it may be necessary for PPU to disclose confidential information to the Education MASH Researcher for the purposes of safeguarding children and young people who have experienced domestic abuse in their household. The information to be disclosed must be both relevant and necessary for the purposes of safeguarding.
It is acknowledged that the law on the disclosure of confidential information is complex. There are restrictions on the sharing of information between the parties under the Data Protection (Jersey) Law 2005 and the Human Rights (Jersey) Law 2000. However, the sharing of information is not necessarily contrary to these Laws.
Data Protection (Jersey) Law 2005
The Data Protection (Jersey) Law 2005 (the 2005 Law) requires that personal information is obtained and processed fairly and lawfully; only disclosed in appropriate circumstances; is accurate, relevant and not held longer than necessary; and is kept securely. The 2005 Law allows for disclosure without the consent of the subject in certain conditions, including for the purposes of the exercise of any functions conferred on any person by or under any enactment.
When disclosing personal information, many of the data protection issues surrounding disclosure can be avoided if the consent of the individual has been sought and obtained. Where consent of the individual is not sought, or is sought but withheld, there can be an exchange of information between the PPU and the Education MASH Researcher where there is an overriding public interest or justification for doing so.
The Data Protection (Sensitive Personal Data) (Jersey) Regulations 2005 contain further conditions for processing Sensitive Personal Data. Given the information to be shared relates to children and young people who have experienced domestic abuse in their household and is for the purpose of providing support to the child or young person, the PPU can share such information for a policing function (Regulation 11).
This means that the exchange of relevant information between PPU and the Education MASH Researcher in this Protocol is not restricted under the 2005 Law because it will nearly always be the case that the overriding public interest in favour of sharing the information will apply.
Children (Jersey) Law 2002
The Children (Jersey) Law 2002 is the law that governs what Jersey authorities adhere to with regards to children. In particular, Article 4 provides that a person who does not have parental responsibility for a particular child but has care of the child may (subject to the provisions of that Law) do what is reasonable in all the circumstances of the case for the purpose of safeguarding or promoting the child’s welfare. This would include the sharing of information where it is necessary and in the public interest to do so.
European Convention on Human Rights
The Human Rights (Jersey) Law 2000 gives effect to the rights and freedoms guaranteed under the European Convention on Human Rights. Article 8 protects the right to respect for private and family life, home and correspondence. Article 8 is a "qualified" right which means that it can be interfered with where it is in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.
The court will order disclosure of information where it is necessary for the protection of health or morals, for the protection of the rights and freedoms of others and for the prevention of disorder or crime (Article 8 (2)). Disclosure should be appropriate for the purpose and only to the extent necessary to achieve that purpose.
It is recognised that the handling of such confidential, sensitive information needs to be dealt with in a way that is proportionate and appropriate to the needs of each child or young person. To address this, the Education MASH researcher will only disclose information to ‘Key Adults’ from each school [The Designated Safeguarding Lead, Head Teacher or their Deputy]. The Education MASH researcher will be responsible for recording what information is given to the ‘Key Adults’ and to agreeing the secure storage of such information. Further dissemination within the school must be on a ‘Need to know’ basis.
Whilst consent may not be required good practice dictates that Police Officers ensure that children [age appropriate] and parents/carers are aware that information will be shared with the school and Education MASH researcher and for what purpose. This is with the usual considerations that this will not increase risk to the child or impact on the prevention or detection of crime.
Roles and Responsibilities Police
What will be disclosed?
Details collated with respect to the child will include their name, age, date of birth, home address and school attended. The school will be told the time/date/location of the incident, the parties involved in the incident [including their relationship with the child], and the child’s involvement in the incident.
How will it be disclosed and when?
Information will be disseminated from the Public Protection Unit [PPU] directly to the Education MASH researcher, in the Multi-Agency Safeguarding Hub. The Education MASH researcher will then be responsible for sharing the information once they have confirmed the school attended. A log will be kept by PPU as to what is disclosed and when as will the Education MASH researcher
Incidents occurring on Friday, Saturday or Sunday will be disclosed to the Education MASH researcher on the Monday morning.
There is no planned provision to share information on all incidents with the Education MASH researcher during school holiday periods, as the aim of this protocol is to provide support in the period immediately following the incident. (However significant incidents occurring during the school holidays will be considered for disclosure at the start of term)
A disclosure will be made in respect of all children attending Education Department Schools/Settings.
Education Department’s /School’s Responsibility
It is the responsibility of the Education Department Designated Safeguarding Officer [DSO] to ensure that the ‘Key Adults’ who receive this information are those who are suitably briefed around safeguarding and the handling of such sensitive information.
Any changes to the named ‘Key Adults’ would be managed between the school and the DSO and shared with the Education MASH researcher. Schools should ensure any change of DSL is notified to the Ed. Dept. DSO and both the DSL/ Head teacher and/or their deputy are aware of and able to implement their responsibilities in relation to this protocol. This means ensuring that key administrators/receptionists are aware of the importance and significance of contact from the Education MASH researcher so information can be shared in a timely manner.
Schools must record and retain the information that they receive from the Education MASH researcher and such information will be stored in the same way as child protection records. Schools need to be aware that in the event of any domestic murder or serious case review the documents may be required for disclosure purposes.
The PPU, Education MASH Researcher and the school, which either sends or receives data from the other in pursuance of this Protocol, and that processes that data, or any part of it, for their own purposes is a data controller for their version of the data. Data controllers are responsible for complying with their obligations under the 2005 Law in respect of any personal and sensitive personal data that they process.
In line with the 5th Principle in Schedule 1 to the 2005 Law data controllers must ensure that all Personal data must not be kept longer than is necessary for the purposes for which they are processed. The PPU, the Education Department and schools agree to review their records retention policies and ensure that appropriate provision is made for the retention and destruction of Personal data obtained as part of this Protocol.
In accordance with the 7th principle in Schedule 1 to the 2005 Law, data controllers must take appropriate technical and organisational measures against unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to, Personal data.
There are always data security risks when transferring and managing personal and sensitive personal data. Both the PPU and the Education Department agree to take action to mitigate these risks by adopting appropriate data security practices, including ensuring that they have robust procedures in place to protect against the loss or theft of data received pursuant to this Protocol.
Once the school Designated Safeguarding Lead (DSL) receives information from the MASH Education Researcher they will inform relevant school staff so that additional support can be implemented during the school day. For primary school children this is likely to be the class teacher, for secondary school children it may be the form tutor, head of year or relevant subject teachers.
If the child already receives additional support, for example, the Social, Emotional, Mental Health and Inclusion Team (SEMHIT) may already be working with the child and family, the school ELSA and/or school counsellor, they should be informed on ‘a need to know’ basis as such information is likely to influence their approach and assessment of the child.
Being prepared for the unexpected
The child may be unusually upset and emotional, but equally, they may present as withdrawn and ‘not their usual self’. The identified school staff need to observe and monitor. There is a chance the child will disclose to an adult about what has happened, or share further information that raises further concern. Staff need to manage any disclosures in the usual way according to safeguarding children procedures.
The internet and constantly evolving technology continually changes the way that we all interact with the world. Whilst advances in technology offer a plethora of excellent opportunities for teaching and learning, this technology comes with some potential risks.
Online safety is not purely about technology. Many of the issues arising from online activity are behavioural and consequently will be managed in the same way as any other inappropriate behaviour.
E-Safety messages such as ‘don’t post personal information online’ are now almost meaningless, as the whole point of social media for many young people is to share personal information. Also the huge range of online applications now used means that locking information down via privacy settings is almost impossible.
Our key aim with respect to the use of technology is that there is no substitute for a strong established culture of safeguarding within the College, which prioritises the safety of both our students and staff, especially in relation to the use of online apps, social media and wireless technology.
To achieve these aims our policies, systems and procedures are designed to:
Systems and Procedures:
Online Safety Training for Staff:
The e-Safety Officer and the DSL have joint responsibility for:
All Students should be encouraged to take responsibility for:
Parents/guardians have responsibility for:
The Principal has responsibility for:
Relationships to other policies
External policies to be found at: