Purple Ruler Safeguarding Policy 2022

September 2022

All teachers, employees and senior management of Purple Ruler are committed to providing a safe learning environment for our students and to promote welfare and protection of children and young people. We pledge to strictly follow the statutory guidance outlined in KCSIE 2022 to continuously monitor, review and improve on our policies and procedures to ensure we have the best practice in safeguarding.

We aim to keep students safe by

  1. Appointing a Designated Safeguarding Lead.

  2. Adopting child protection and safeguarding best practice through policies, procedures and code of conduct for all staff members.

  3. Providing effective management for all staff members through supervision, support, training and quality assurance measures to ensure all staff members have the knowledge and understanding of safeguarding and to follow our policies, procedures and codes of conduct confidently and competently.

  4. Ensure our recruitment process meets all safer recruitment requirements and all members of staff have passed the necessary checks before appointment.

  5. Recording, storing and using information securely and professionally in accordance with data protection legislation and guidance.

  6. Making sure schools, students and parents are aware of our safeguarding policies and protocols to share concerns and relevant information with agencies who need to know and involve the necessary stakeholders appropriately.

  7. To use our policies and procedures to manage any allegations against staff members appropriately.

  8. To use our policies and procedures to understand school's safeguarding protocols for online/remote learning in order to ensure safeguarding concerns are attended to, communicated and reported to the school efficiently, effectively and appropriately in accordance with the school's policies.

  9. To ensure we have effective complaints and whistleblowing measures in place.

  10. To ensure we update our policies and procedures annually in accordance with the most up to date statutory regulations.

  11. Building a safeguarding culture where staff, schools, students and parents treat each other with respect, with the student's best interest at heart, working together to ensure student's welfare and protection and are comfortable about sharing concerns.

Roles and Responsibilities

Designated Safeguarding Lead:

  1. The designated safeguarding lead should take lead responsibility for safeguarding and child protection (including online) safety - KCSIE 2022.

  2. To fully understand the laws and regulations surrounding safeguarding. To be up to date with all regulations.

  3. To ensure that Purple Ruler has a robust safeguarding policies and procedures in place and that all personnel, from senior management level to teaching staff implement safeguarding ethos and practices in their daily operations.

  4. To help management team devise safeguarding and safer recruitment risk register and management plans.

  5. To assist the HR department with building a strict safe recruit selection and vetting procedure for UK nationals as well as overseas applicants. DSL is responsible to ensure the recruitment and onboarding of new teachers strictly follows this process.

  6. To ensure records are kept in the SCR.

  7. To ensure all staff engaging in regulated activities are fully compliant before deployment.

  8. To assist the training team with building a robust safeguarding training program for new teachers as well as refresher course for existing teachers.

  9. To be responsible for reviewing the safeguarding policies and procedures to ensure Purple Ruler is compliant and our practices are up to date with safeguarding and child protection.

  10. To inform schools of Purple Ruler's safeguarding polices and procedures, share SCR upon request, obtain DSL or named person from the school and instruct the teachers for each school group with any specific safeguarding requirements the school might have.

  11. To assist the QA team to build a robust class and teacher monitoring process, reporting process and methods to provide further support for teachers.

  12. To ensure all teachers know how to report a concern.

  13. To support schools, authorities and agencies with follow up action when a report of concern is submitted and acted upon.

  14. To take part in strategy discussions and inter-agency meetings.

DSL

Bella Ma

bellama@purpleruler.com

01227 913313

Managing Director

Daniel Demarmels

daniel.d@purpleruler.com

01227 913314

Senior School Liaison Officer

James Kitch

james.kitch@purpleruler.com

01227 913300

In the event where the DSL is unavailable, please contact one of the following senior management staff listed above.

Safer Recruitment and Selection Policies and Procedures

Purple Ruler maintains a high standard in recruitment. Teachers are employed by the company. We have a rigorous recruitment and training process to ensure our tutors specialise in the subject they are teaching, satisfy safer recruitment regulations, adopt the Purple Ruler pedagogy and adhere to our safeguarding policies and procedures.

Our Designated Safeguarding Lead is on the interview panel and participates in the live interview phase for each applicant. Applicants are required to go through the following application and training process.

Selection Process

Purple Ruler Teacher Selection Process.png

When an application is successful, they will proceed with the following safer recruitment vetting process, training and probation. These two processes will take place simultaneously.

Safer Recruitment Vetting Process:

  1. Reference Check from 2 references. References checks are obtained directly by Purple Ruler.

  2. Safer Recruit Document Collection:

    1. ID - Birth certificate where possible, if not, then passport

    2. Proof of Address - utility bills, bank statement or other official documents with the most recent 3 months.

    3. Proof of Study - applicants must at least be studying towards their Bachelor's degrees in a degree related to English, Maths or Sciences from one of UK's top 25 universities.

    4. For non UK citizens, applicants must provide proof of right to work and overseas police check if they have resided or worked outside of the UK within the most recent 12 months.

  3. Criminal Background check:

    1. Enhanced DBS with Child Barred List. If applicant already has one, it must be completed within the most recent 12 months. Or after any 3-month break in service.

    2. Prohibitions Check

    3. Those who have lived or worked outside of the UK must also attempt to provide local police check to the same level as the Enhanced DBS check where possible for each country they resided. If they are not able to obtain this, they must provide a statement and evidence where possible the reasons why they are not able to provide this.

  4. Overseas Applicants must provide the following:

    1. ID - Birth certificate where possible, if not, then passport

    2. Proof of Address - utility bills, bank statement or other official documents with the most recent 3 months.

    3. Proof of Study - applicants must at least be studying towards their Bachelor's degrees in a degree related to English, Maths or Sciences from their country's top 10 universities.

    4. UK Enhanced DBS with Child Barred List. If applicant already has one, it must be completed within the most recent 12 months. Or after any 3-month break in service.

    5. Prohibitions Check

    6. Local authority police check to the same level of Enhanced DBS with Child barred list, or to indicate they are not prohibited from teaching. This check must be completed within the most recent 12 months.

    7. If they have lived or worked outside of their residing country, they must also attempt to provide the highest level of background checks where possible for each country they resided. They must also provide a letter from the professional regulating authority, full employment history and reference check. If they are not able to obtain any of the above, they must provide a statement and evidence that they have exhausted all avenues of providing this.

Teacher Training, Safeguarding Training and Probation Policies

Training Policies:
  1. All new teachers must undergo mandatory teacher training and Safeguarding training before they are appointed to their positions. This may take up to 20 hours.

  2. The training itinerary is set up to complete this within a week. If any teachers are not able to complete any aspect of the training, they will be moved to the next training group.

  3. Teachers can postpone their training 3 times before they are removed from the training program and offer revoked.

  4. Safeguarding training includes self study of Purple Ruler's Safeguarding Policies and Procedures as well as reading Part 1 of KCSIE 2022.

  5. Teachers will then attend mandatory online live Safeguarding training. This includes:

    1. Prevent and recognising abuse.

    2. Record and report concerns.

    3. Teacher's code of conduct

    4. Allegations procedure and how to respond appropriately

    5. Sharing information, privacy and GDPR

    6. PREVENT training

  6. To ensure our teachers have understood the information delivered in the training, they are required to sign a Safeguarding declaration and to take an online live quiz before they can complete the training. Teachers must obtain 100% on their quiz to pass.

  7. Teachers are required to complete refresher training in Safeguarding annually or when our policies have updated.

  8. Teachers are also required to completed a refresher teacher training course when other operational processes have updated or our pedagogy is updated.

Forms of abuse

It is important to be aware that many forms of abuse can take place either online or in person. According to KCSIE 2022, the main forms of abuse are:

Abuse: 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. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. 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.

 

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

 

Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child 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 opportunities 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 a child’s developmental capability as well as overprotection and limitation of exploration and learning or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

 

Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving children in 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. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue - child on child abuse.

 

Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy, for example, as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Child-on-child abuse: is most likely to include, but may not be limited to:

  • bullying (including cyberbullying, prejudice-based and discriminatory bullying)

  • abuse in intimate personal relationships between children (sometimes known as ‘teenage relationship abuse’)

  • physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)

  • sexual violence, such as rape, assault by penetration and sexual assault; (this may include an online element which facilitates, threatens and/or encourages sexual violence). Consensual image sharing, especially between older children of the same age, may require a different response. It might not be abusive – but children still need to know it is illegal- whilst non-consensual is illegal and abusive.

  • sexual harassment,such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse

  • causing someone to engage in sexual activity without consent, such as forcing someone to strip,touch themselves sexually, or to engage in sexual activity with a third party

  • consensual and non-consensual sharing of nude and semi-nude images and/orvideos11(also known as sexting or youth produced sexual imagery)

  • upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocksto obtain sexual gratification, or cause the victim humiliation, distress,or alarm,and

  • initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

 

Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)

Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in sexual or criminal activity, in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator and/or through violence or the threat of violence. CSE and CCE can affect children, both male and female and can include children who have been moved (commonly referred to as trafficking) for the purpose of exploitation.

Child Criminal Exploitation (CCE)

Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, or pick-pocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Children can become trapped by this type of exploitation, as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the activity appears to be something they have agreed or consented to.

It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however professionals should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

Child Sexual Exploitation (CSE)

CSE is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside clothing. It may include non-contact activities, such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse, including via the internet.

CSE can occur over time or be a one-off occurrence and may happen without the child’s immediate knowledge for example through others sharing videos or images of them on social media.

CSE can affect any child who has been coerced into engaging in sexual activities. This includes 16- and 17-year-olds who can legally consent to have sex. Some children may not realise they are being exploited for example they believe they are in a genuine romantic relationship.

 

Domestic Abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn.

Female Genital Mutilation (FGM)

Whilst all staff should speak to the designated safeguarding lead (or a deputy) with regard to any concerns about female genital mutilation (FGM), there is a specific legal duty on teachers.13 If a teacher, in the course of their work in the profession, discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report this to the police.

Under section 5B(11) (a) of the Female Genital Mutilation Act 2003, “teacher” means, in relation to England, a person within section 141A(1) of the Education Act 2002 (persons employed or engaged to carry out teaching work at schools and other institutions in England).

Mental Health

All staff should be aware that 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.

Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Education staff, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. Schools and colleges can access a range of advice to help them identify children in need of extra mental health support, this includes working with external agencies.

If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken, following their child protection policy, and speaking to the designated safeguarding lead or a deputy.

Serious violence

All staff should be aware of the indicators, which may signal children are at risk from, or are involved with, serious violent crime. These may include increased absence from school or college, 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 and may be at risk of criminal exploitation.

Signs and Indicators

All staff should be aware of indicators of abuse and neglect (see below), understanding that learners can be at risk of harm inside and outside of education, home and online. Exercising professional curiosity and knowing what to look for is vital for the early identification of abuse and neglect so that staff can identify cases of learners who may need help or protection. All staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events and cannot be covered by one definition or one label alone. In most cases, multiple issues will overlap with one another. When identifying abuse, staff should be mindful of the need to consider the context of the culture, law and guidance of the relevant jurisdiction of the learner. It is important to consider whether the learner, their family and their society view the behaviour as unacceptable, as this will be a determining factor in whether the learner views the behaviour as abusive.

Staff should report behaviour in line with expectations of behaviour in the UK, and in determining next steps the cultural context of the learner or learners involved will always be taken into consideration. For situations outside the UK, we take expert advice to ascertain what is and is not acceptable in the specific country and will consider the potential impact of reporting any such concerns with regards to the learner and their family. It is the responsibility of all members of staff to report all worries or concerns over safeguarding and welfare. It is not their responsibility to investigate or decide whether a learner has been abused. Signs and indicators may be the the following forms:

  • be reluctant to turn on their webcam;

  • have visible bruises, bleeding, burns, fractures or other injuries;

  • show signs of pain or discomfort;

  • look unkempt and uncared for;

  • have difficulty in making or sustaining friendships;

  • appear fearful;

  • be reckless regarding their own or other’s safety;

  • self-harm;

  • show signs of not wanting to be at home;

  • display a change in behaviour – from quiet to aggressive, or happy-go-lucky to withdrawn;

  • challenge authority;

  • become disinterested in their education or have significant declines in performance;

  • be constantly tired or preoccupied;

  • be involved in, or particularly knowledgeable about drugs or alcohol; and/or

  • display sexual knowledge or behaviour beyond that normally expected for their age.

A member of staff may also see or hear something in the background of their online classes, which raises concern. Any concerns should be reported even if there is no conclusive evidence of abuse.

Procedures

In all cases related to child protection and safeguarding, all staff must treat all allegations seriously, in strict confidence and report efficiently to Purple Ruler Designated Safeguarding Lead (DSL) or school group Designated Safeguarding Lead (DSL) or named person. Purple Ruler promotes a 'telling' culture - See it, Think it and Share it!

Purple Ruler Staff

School Group Class

Classes conducted for a school group usually take place within school hours, on school premises and facilitated by a member of staff at the school. For these groups of students, the Designated Safeguarding Lead (DSL)will obtain a copy of the school's safeguarding policies and procedures, and ensure that we have the Designated Safeguarding Lead (DSL) or named person contact details to report to.

Before a new school group begins with their first class with us, DSL will post a Safeguarding polices and reporting process notice in the teachers communications group who are assigned to this school. This will include:

  • A copy of the safeguarding policy and KCSIE Part 1 in case any teacher need to refresh their memories on safeguarding policies.

  • A specific reminder of what to do when a student discloses anything concerning. List the name and contact details of the DSL from the school or a named person that the teacher should tell the student to report to when they disclose this information.

  • A specific reminder for teachers to complete the safeguarding report form immediately if they see or hear anything that is concerning and for them to inform a member of the management team immediately after they have completed this form: https://forms.office.com/r/EVBfWJg24Y

  • A specific reminder that in case of any serious incident or immediate danger or harm, if teachers are not able to get assistance from the facilitator of the class at the school, they must call the school immediately (add school's number).

Serious Incident or Immediate Danger and Harm:

Definition:

A serious incident which took place during an online class for a school group, where:

  • A student is at risk of, being exposed to or having disclosed that they experienced significant harm;

  • A crime has been committed

 

Examples:

  • Where a student is alleged to have seriously harmed themselves or another person.

  • Serious concerns or signs that a learner is engaged in extremist behaviour, protracted bullying, sexual abuse or harassment.

  • Death.

 

Procedure:

  1. Person identifying the incident reports to school's DSL or named person if concerned student is at immediate risk of harm. Information can be found on school group on Lark. Where this information is absent, the person identifying the incident reports to Purple Ruler Designated Safeguarding Lead (DSL). Designated Safeguarding Lead (DSL) will report the incident to school's named person.

  2. If the identifying person is a teacher, and the incident is taking place during a class. The Teacher must remain in the class, remain calm and collected, try to keep the other students calm and distant from the incident.

  3. After taking initial action, the incident must be reported to PR Designated Safeguarding Lead (DSL) if it has not been reported to them in the previous steps.

  4. Person identifying the incident must record the incident on Safeguarding Form.

  5. Designated Safeguarding Lead (DSL) will review the report, follow up with the school and support the school's actions that follows.

  6. Record actions taken in the incident.

  7. Designated Safeguarding Lead (DSL) carries out risk assessment in procedure and actions taken for prevention and improvement in safeguarding polices and procedures.

Safeguarding and Welfare Concerns:

In cases where the teacher or any person who suspects that a student may be at risk but have no 'real' evidence, where possible the person identified the risk should ask if the student is okay and offer their support in any way. Then follow the procedure to share the incident.

  1. Complete the Safeguarding Report Form immediately and inform a member of the management team, ideally the DSL, but teachers are encouraged to report it to anyone whom they feel comfortable with https://forms.office.com/r/EVBfWJg24Y If the person whom they have reported to isn't the DSL, the member of staff must inform the DSL immediately.

  2. Purple Ruler will report the incident to the school's Designated Safeguarding Lead (DSL) or named person.

  3. Purpler Ruler shall only follow the policies and procedures and instructions of the school, and shall not carry out investigation independently.

  4. All allegations or suspicions shall be referred to the school no matter the level of significance.

Recording Concerns

All concerns and correspondence will be kept in a secure, confidential safeguarding case management system. The student's circumstances will be kept under review and the school will be made aware again if in the learner’s best interest. All concerns, discussions and decisions made, and the reasons for those decisions, are recorded in writing. Records should include:

  • The date and time of the incident

  • The date and time of the disclosure of incident

  • The date and time the record is being made

  • The name, role, and contact details of the person the concern was originally reported to

  • The name, role and contact details of the person making the report (if this is not the same person as above)

  • The name, age and other relevant information about the student who is the subject of concern

  • The names of all parties involved in the incident including any witnesses;

  • What was said and done and by whom;

  • Follow up actions, and the time and date it was reported to the school.

  • Staff should be aware that notes of such reports could become part of an assessment by social care and/or a criminal investigation.

Victim Disclosure

It takes courage for anyone to disclose that they are being or have been abused. It is essential that all victims are reassured that they are being taken seriously, regardless of how long it has taken them to come forward and that they will be supported and kept safe. Regardless if they are a member of staff or student, when a victim discloses any risks to their safety or wellbeing, one should approach the conversation with the following considerations:

  • allow them to speak freely and do not be afraid of pauses or silences;

  • remain calm and avoid overreaction;

  • offer reassurance and general words of comfort;

  • not ask investigative questions, but rather prompt, if necessary, with open questions – where, when, what, tell, explain, describe etc. If appropriate, staff can ask students if they have been harmed and what the nature of that harm was;

  • recognize that trauma can impact memory and so learners may not be able to recall all details or timeline of abuse;

  • explain at an appropriate time that, in order to help, the information must be passed on to relevant people in positions of responsibility;

  • not reprimand the learner for failing to disclose earlier; and

  • establish next steps - this conversation will be escalated to Designated Safeguarding Lead (DSL) and someone will be in contact with them with further support.

  • After a disclosure, seek support, if distressed, the person who has disclosed this information should never be given the impression that they are creating a problem by reporting abuse. Nor should they be made to feel ashamed for making a report. Abuse that occurs online or outside of education should not be downplayed and should be treated equally seriously.

Collecting Evidence

If an incident takes place, the person identifying the risk or receiving disclosure, should ensure they capture and collect evidence.

  • All classes are recorded automatically on The Lesson Space. However, one should record the time cap of when the incident occurred.

  • Screenshots of contents in the chat box.

These files should be passed to Designated Safeguarding Lead (DSL) to incorporate into the report.

Prevent and Radicalisation

We recognise our duty to help prevent young people from being drawn into extremist viewpoints and radicalisation. In the UK, Prevent Duty is the duty in the Counterterrorism and Security Act 2015 on specified authorities including providers to have due regard to the need to prevent people from being drawn into terrorism. There is no single way of identifying an individual who is likely to be susceptible to radicalisation, but there are a number of early indicators of radicalisation or extremism, which may include:

  • showing sympathy for extremist causes;

  • glorifying violence, especially to other faiths or cultures;

  • making remarks or comments about being at extremist events or rallies;

  • evidence of possessing illegal or extremist literature;

  • advocating messages from illegal organizations or other extremist groups;

  • out of character changes in dress, behavior and peer relationships;

  • secretive behaviors including online searches or sharing extremist messages or social profiles;

  • intolerance of difference, including faith, culture, gender, race or sexuality;

  • artwork or writing that displays extremist themes;

  • attempts to impose extremist views or practices on others;

  • verbalizing anti-Western or anti-British views; and

  • advocating violence towards others.

Members of staff who have concerns about a student will make these concerns known to the Designated Safeguarding Lead (DSL) at the earliest opportunity. The Designated Safeguarding Lead (DSL) will then make a judgement as to the most appropriate course of action.

Non-emergency advice for staff is available via the DfE’s helpline +44 (0)20 7340 7264 and by email at counter-extremism@education.gsi.gov.uk

Staff Code of Conduct

We expect that all staff are responsible for their behaviour. Our expectation is that all staff will always model professional behaviours. The safeguarding of students is paramount and takes precedence over all other considerations. All staff members are expected to adhere to the following conduct:

1. Professionalism
  • Staff should complete Safeguarding training;

  • Staff should maintain a friendly, positive attitude and be patient towards students, other members of staff and anyone from the schools we work with;

  • Staff should be focused on the teaching when in a class and their students throughout the lesson;

  • In a lesson, staff must not have any private conversations on any social media platforms, via telephone or SMS messaging, even talking with colleagues on Lark. Staff may still contact the management team when they require technical or safeguarding assistance.

  • Staff must not visit websites for personal reasons during class.

  • Staff should physical props where possible as supplementary tools in lesson to improve students' understanding of the lesson content and to build rapport. Staff must ensure these are appropriate items and only for the purpose of the lesson.

  • Make sure to provide equal opportunity to all students.

  • Staff are expected to be receptive to feedback in order to continuously improve on their teaching skills to reach or maintain the expected standard of teaching quality.

  • Staff must not eat during class.

  • Be conscious of confidentiality when working online;

  • Not engage in conduct (including other employment) which could reasonably be expected to damage the reputation and standing of the organisation;

  • Not make any improper suggestions towards any students during their sessions or through their communications;

  • Not sharing their personal contact details with students including their personal mobile number, personal email address or social media or gaming accounts. Staff should therefore not accept any ‘friend’ or ‘follow’ requests from students on their social media accounts;

  • Staff should be conscious of their social media presence, whether it displays appropriate activities and content suitable for the status of a teacher.

  • Staff must be dressed appropriately when delivering classes, avoid the following: anything low cut, tracksuits, V Neck t-shirts, blouse, tank tops or straps, pajamas or stained clothing.

  • Teaching Environment: where possible, please try to teach in a well-lit, noise free environment with either decorated with educational posters as your background or a plain white wall.

  • Headset Quality: Make sure to connect to a headset/headphones/earphones when teaching. Avoid using bluetooth headphones/headsets, it doesn't record sound into the class playback videos.

  • Camera Position: Make sure that your image is clear, that you are at an appropriate distance from the camera, and that you are in the middle of the camera at a neutral angle.

  • We require all classes to be recorded for safeguarding reasons, therefore, please remember to close the other apps, even ones that are running in the background on your device. Make sure that there are no pop ups on the screen.

  • Staff should not share the link to their online class with anyone, including other staff members without the approval of a manager;

  • Staff are responsible for the security of their login details to the platform. They must not share their username and password and must not let someone else log into their account assuming their identity.

  • If staff are concerned their login details may have been compromised, they must immediately change their password and report the situation to the Designated Safeguarding Lead with the relevant details.

2. Social Media Policy

Staff must not use social media in a way that might breach any of company policies, any express or implied contractual obligations, legislation, or regulatory requirements. In particular, the use of social media must comply with:

  1. Our policy against discrimination, bullying or harassment. This requires all staff not post any comments that disparage or otherwise insult or harass others based on their sexuality, ethnicity, gender, religion, beliefs or nationality.

  2. Our requirements for confidentiality about our business practices.

  3. Staff 'duty of care' towards students and school.

  4. In the use of social media staff must not:

    1. Make disparaging or defamatory statements about the company, students, employees, clients, customers or suppliers.

    2. Use data obtained in the course of employment with us in any way which breaches the provisions of the Data Protection Act 1998.

    3. Breach copyright belonging to the company or our schools.

    4. Make any statements which cause, or may cause, harm to our reputation or otherwise be prejudicial to our interests. Staff should avoid using social media communications that might be misconstrued in a way that could damage our business reputation.

  5. If any staff disclose that they are employees of our company in a social media communication, they must state that their views do not represent those of the company.

  6. Staff are not permitted to add social media contacts made during the course of their employment to pertain to suppliers, customers, parents or children.

 

Any instances where a member of staff feels their actions, or the actions of others, may have compromised the organisation, or their own professional standing, should be recorded and reported to the Designated Safeguarding Lead (DSL).

Although this Code of Conduct gives advice and instruction on how to deal with specific situations, it should not replace professional common sense and good judgement. In all matters relating to student/staff relationships, staff must bear in mind how an action might reasonably be regarded by a third party.

Concerns or Allegations Relating to Staff

When an allegation is made against a member of staff working for or on behalf of Purple Ruler or a concern expressed about their conduct relating to students, set procedures must be followed. It is rare for a student to make an entirely false or malicious allegation, although misunderstandings and misinterpretations of events can happen, and a student may make an allegation against an innocent party because they are too afraid to name the real perpetrator.

Reporting concerns

A member of staff who is concerned about the conduct of a colleague towards a student must remember that the welfare of the student is paramount. No member of staff will suffer a detriment for raising a genuine concern.

Allegations or concerns against members of staff, should be reported to the Designated Safeguarding Lead (DSL). An allegation or concern against the Designated Safeguarding Lead (DSL) should be reported directly to the Managing Director. Staff may also report any allegations or concerns directly to the police if they believe direct reporting is necessary to secure action and they feel a crime has been committed. Staff may additionally use the NSPCC whistleblowing helpline number, 0800 028 0285, if they feel that staff conduct may not have passed the threshold for a criminal offence but raises concerns which are not being addressed within the internal reporting mechanisms. Allegations against a former member of staff no longer working for us should be referred to the police.

Reports can be made verbally but should be supported by a dated and timed note of what has been disclosed or noticed, said or done.

Designated Safeguarding Lead (DSL) must log the incident, before the end of the day. It is vital that expressions of concern that do not necessarily amount to ‘allegations’ are reported, particularly if there are repeated reports of such concerns and/or questionable conduct.

It may be that the concern expressed has been raised by another party. If there are repeated reports of such concerns and/or questionable conduct, a pattern of unacceptable behaviour may be identified.

Reporting an incident relating to staff

Staff, parents, and members of the Governing Body are reminded not to investigate the matter themselves, not to make assumptions or offer alternative explanations for behaviours, or to promise confidentiality to the alleged victim(s).

The incident must be reported to the Designated Safeguarding Lead (DSL). In their absence, it must be reported to the other listed people at the top of this document.

Threshold for concerns

We accept that some professionals can pose a serious risk to students and we will act on every allegation or concern that a person working with or who is in contact with students may have:

  • behaved in a way that has harmed a student, or may have harmed a student;

  • possibly committed a criminal offence against or related to a student;

  • behaved towards a student or students in a way that indicates he or she may pose a risk of harm to students; and/or

  • behaved or may have behaved in a way that indicates they may not be suitable to work with students (including behaviour that might have happened outside of the learning environment).

Responding to Low Level Concerns

A low-level concern is when behaviour is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, but when this behaviour does not meet the harm threshold set out above. Examples of such behaviour could include, but are not limited to:

  • being overly friendly with student;

  • having favourites;

  • engaging with a student on a one-to-one basis without recording the meeting; and/or

  • using inappropriate sexualised, intimidating or offensive language.

Sharing low level concerns is vital to create and embed a culture of openness, trust and transparency in which our values and expected behaviour, as set out in the staff code of conduct, are constantly lived, monitored and reinforced by all staff.

Sharing concerns includes self-referral, where, for example, a staff member may have found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards.

Where a low-level concern is raised, this will be dealt with promptly and appropriately and a record of the concern kept allowing any patterns of unacceptable behaviour to be identified. To address low level concerns, we will:

  • ensure staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others;

  • encourage staff to share any low-level safeguarding concerns;

  • address unprofessional behaviour and support the individual to correct it at an early stage;

  • provide a responsive, sensitive and proportionate handling of such concerns when they are raised; and

  • monitor low-level concerns to help identify any weakness in the safeguarding system.

Responding to crimes that reach the threshold

If an allegation meets the criteria listed above under the section ‘Threshold for Concerns’, it will be dealt with according to the statutory guidance set out in Keeping Learners Safe in Education (DfE, September 2022).

On receiving a reported concern, the DSL will proceed as follows:

  1. Produce a case report, taking detailed notes from the source, including the date and time of the incident.

  2. Report to LADO (Local Authority Designated Officer) immediately whilst investigating the incident. Including watching the playback of the recorded lesson.

  3. The DSL and Managing Director will liaise with the LADO to discuss the nature, content and context of the allegation and agree on a course of action. At this stage, we will consider the following:

    1. What information needs to be shared;

    2. Identify what other information might be needed;

    3. Consider whether the alleged perpetrator should continue to work or if suspension is more appropriate;

    4. Whether to inform the member of staff at this stage;

    5. Discuss support strategies with the school on helping the student;

    6. Decide what action is needed and who needs to be involved and informed.

  4. Proceed with the course of action confirmed with LADO and/or police.

The decisions about the course of action are taken on a case by case basis. The safety of any student is of absolute essence, but also remember that the member of staff, against whom an allegation has been made, has the right to remain anonymous and to expect any allegations to be investigated as expeditiously as possible.

Any course of action is subject to a risk assessment. Decisions would also follow the guidance of the LADO and/or police. If the parties involved in these discussions consider it necessary, a Strategy Meeting is arranged, usually by Social Services, which will involve representatives from the LADO, the police and the provider (e.g., the Principal, DSL or Chair of Management Board, as appropriate). From the above discussions, there are three possible courses of action:

  • It may be the subject of a police force and/or joint police and Social Services investigation and possible action through the courts; or

  • It may be the subject of a disciplinary investigation; or

  • The matter may be remitted to the provider to be dealt with.

The following definitions will be used when determining the outcome of allegation investigations:

Substantiated: there is sufficient evidence to prove the allegation

Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive

False: there is sufficient evidence to disprove the allegation

Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation; the term, therefore, does not imply guilt or innocence

Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made.

If Social Services and the police decide to take no action, we will still need to consider what further investigation is necessary. If there is a case to answer, a disciplinary hearing will be called, which could lead to dismissal.

Where a criminal investigation has taken place and either (i) a trial has resulted, (ii) the investigation has been closed without charge or (iii) a decision has been taken not to prosecute a case after charge, the DSL will discuss with the LADO what, if any, further action is required as regards the member of staff concerned and the sharing of information obtained by the agencies involved in assisting any further action to be taken by us.

Where a disciplinary investigation is required, the investigation should be conducted in accordance with our disciplinary procedure.

Action upon conclusion of a case

We will refer to the DBS (following consultation with the LADO) any person who has been removed from working in regulated activity, and it believes the person may have harmed, attempted to harm, incited another to harm or put a student at risk of harm or if there is reason to believe the person may have committed one of a number of offences listed under the Safeguarding Vulnerable Groups Act (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009. ‘Removal from working’ for these purposes will include dismissal, non-renewal of a fixed term contract, no longer using a supply teacher engaged directly or supplied by an agency, terminating the placement of a trainee or volunteer, no longer using staff employed by a contractor and resignation or voluntary withdrawal from any of the above.

In cases where it is decided on the conclusion of the case that a person who has been suspended can return to work, we will consider how best to facilitate this. We appreciate that most people would benefit from some help and support when returning to work after a very stressful experience. Depending on the individual’s circumstances, a phased return and/or the provision of a mentor to aid and support in the short term may be appropriate. We will also consider how the person’s contact with the learners who made the allegation can best be managed if they are still attending the educational provision.

If an allegation is determined to be false, the DSL will work to support the school in their actions to help the student. If an allegation is shown to have been deliberately invented or malicious, Purple Ruler will inform the main education provider who can consider whether any disciplinary action is appropriate against the learner who made it.

A referral will be made to the Teaching Regulation Agency (TRA) via the GOV.UK website where a teacher has been dismissed (or might have been dismissed had he/she not resigned) and a prohibition order may be appropriate.

A central record of all allegations and concerns (and connected documents) against members of staff will be kept securely, separate from normal staff records, and with access limited to the DSL, as well as Human Resources representatives and officers who may be key workers for cases. The only exception to this requirement for permanent recording is where allegations have been found to be malicious. In such cases, all records will be removed from staff personnel files. The record of allegations may provide clarification in cases where a future DBS disclosure reveals information from the police about an allegation that did not result in a criminal conviction. It will also help to prevent unnecessary re-investigation if, as occasionally happens, an allegation re-surfaces after a period. The record will be retained at least until the member of staff involved has reached normal retirement age, or for a period of 10 years from the date of the allegation if that is longer. An allegation which was proven to be false, unsubstantiated or malicious will not be included in references for staff. Where there have been concerns about a member of staff and he or she leaves us to work elsewhere, the DSL will consider the question of passing the concerns to the new employer or authority. We will pass allegations or concerns affecting a learner on to his or her next provider, if applicable.

Whistleblowing

Employees can raise concerns when they suspect past, present, or imminent wrongdoing, or an attempt to conceal wrongdoing. Officially this is called ‘making a disclosure in the public interest’. We encourage all employees who have concerns about wrongdoing or malpractice involving any aspect of our work, to feel able to come forward and voice these without fear and in confidence. It is important that concerns are raised at the earliest time possible as this will allow the opportunity to address and resolve any concerns quickly.

The concern should, in most instances, be raised with the employee’s line manager though it is important that the concern is raised with the person best placed to deal with the matter and with whom the employee feels most comfortable. There may be certain rare occasions, however, when it would be inappropriate to raise the concern with the line manager because, for example, the concern:

  • may implicate the manager in some way

  • is about a senior manager within the line management chain or somewhere else in the department

  • is particularly serious and needs to be dealt with as a matter of urgency.

Once a concern has been raised by an employee, a meeting may be arranged with them to determine how the concern should be taken forward. All investigations will be conducted sensitively, as quickly as possible, and under this procedure. The investigation should be concluded within three months of the matter being raised, though some scenarios may result in a longer timeframe.

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