Contents

• Policy Statement

• Terminology

• Duty of Care (including named staff)

• Local Authority Contacts

• Associated Policies

• Policy review

• Codes of Conduct

• Child Protection Information

• Prevent

• Training

• Safer Recruitment

• Welfare and Implementation of Safeguarding

• Accommodation standards

• Student Behaviour and Discipline

• Additional Considerations

 

 

Policy Statement

The UK College of English provides English Language training in two centres: Oxford Street and Salisbury. Our safeguarding policy matches the needs of these two centres while always acting in the best interests of the vulnerable person, whatever their individual circumstances. This policy has been updated according to government guidance from “Keeping Children Safe in Education 2018”.

Oxford Street

Minimum age: 12 for closed groups; 16 for mixed groups

Age range: mostly 16 – 34

Accommodation: Homestay, residential

Salisbury

Minimum age: 8

Age range: 8 – 17, taught in age-appropriate groups

Accommodation: Homestay, residential

 

 

Terminology

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

“U18s” refers to “under 18s”

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

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

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

“Designated safeguarding staff” refers to the multiple people (in separate teams for Oxford Street and Salisbury) who implement the safeguarding policy.

Duty of Care

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

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

Designated Safeguarding Lead

Oscar Czerniawski

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

Designated Safeguarding Staff

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

Oxford Street

Pulkit Vasudha

Laura Villa

Stephanie Day

Atam Sharma

Salisbury

Updated annually and available on the website

 

 

Local Authority Contacts

The DSL is in contact with Wiltshire Multi Agency Safeguarding Hub for Salisbury and the LCSB for Westminster.

 

Associated Policies

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

 

 

Policy review

The safeguarding policy is updated annually and new training is offered where relevant. Some elements of safeguarding policy are incorporated into class so that students can have input into the formulation of future policies. Last updated April 2019.

 

 

Codes of Conduct

1. Staff are in a ‘Position of Trust’ concerning their students. This makes any sexual activity with students aged 16 – 18 illegal according to the Sexual Offences Act 2003.

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

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

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

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

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

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

 

Child Protection Information

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

Understanding and recognising abuse 

An allegation of abuse 

This consists of Information which indicates a person may have:

– behaved in a way that has harmed a child

– committed a criminal offence against or related to a child

– behaved towards a child in such a way that indicates s/he would pose a risk of harm if working closely or regularly with a child

Different kinds of abuse 

Grooming  

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

Abusers may also seek to gain the trust of other adults so that they are allowed to be in situations where they have access to potential victims.

Grooming of under 18s constitutes a criminal offence.

Sexual abuse  

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

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

How to spot someone who may potentially have been sexually abused 

The person may behave inappropriately e.g.  sexualised play or awareness (drawings / promiscuous behaviour) or by being over- needy and attention-seeking .

Sexual Harrassment

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

Emotional abuse  

Here too, the victim may behave in an over-needy, attention-seeking way.

This type of abuse is often persistent, for example in bullying, and may be compounded by the abuser making the victim wary of authority or other adults trying to help them.

Victims of emotional abuse may exhibit both aggression and withdrawal within a short space of time. Emotional abuse is sometimes linked to conditions such as anorexia and self-harming.

Physical abuse  

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

How to spot physical abuse 

Bruising – Symmetry (2 black eyes/bruising on both shoulders) indicates possible abuse

Burns or scalds – A clear edge indicates possible abuse

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

Other 

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

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

Neglect  

This may occur in all levels of society as it includes actions such as leaving a child unattended or ignoring their physical and medical needs. In Salisbury, U18s who are not fully independent may ‘self-neglect’ and this should also be reported as appropriate.

How to spot neglect 

The child may thrive away from their home environment.

They may be unused to supervision and be unable to recognise boundaries of acceptable behaviour, possibly resulting in very aggressive or anti-social behaviour.

Controlling, coercive and threatening behaviours  

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

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

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

Procedure for reporting disclosures of abuse   

Responsibility of staff to report 

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

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

What to do if abuse is disclosed  

Receive  

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

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

Reassure  

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

React 

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

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

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

 

DO DON’T
· Stay calm and be available. (The student has put their trust in you.)

· Find out the general subject area. Ask ‘What is it about?’ 

· If subject matter does require privacy and you are in public place, suggest to student to go somewhere quieter, e.g. a quiet corner of a large space, or probably better, a classroom that has large windows. If you need to use a regular room without large windows, ensure the door is left open and you are sitting within view.

·  If possible, quickly and discreetly, tell another staff member where you are and that you are having a private meeting with a student.

· Try to sit at right angles to student rather than directly opposite or next to them. Be open and ready to listen. Ask What do you want to tell me?’ 

· Be open, calm, patient and listen. Your role is only to hear what they have to say – and try and remember their exact words.

·  If appropriate, you can say; ‘Is there anything else you want to tell me?’ 

· If the student hasn’t already told you, you are allowed to ask only ‘When did this happen?’ 

· When student has told all they want to, reassure them and say ‘You’ve done the right thing to tell me.’ 

·  Find somebody responsible (usually another staff member) to sit with them whilst you respond.

· Tell the DSL what has happened.

· Immediately afterwards, write a report of the meeting using the student’s exact words, giving only facts and record time, date, place etc. (the DSL will give you a form). If the student’s language level was low, state that in your report.

· The DSL will ensure report is filed in proper (secure) place.

· Once you have handed matter over to the DSL (or other senior staff) and completed and filed your report, and you know the student is being looked after, (it may be appropriate to go and see the student again to make sure they are OK), make sure you look after yourself. Being told information about child abuse is often very upsetting.

· Refuse to listen; e.g. tell them you’re too busy or to see them later. Or over-react.

· Assume it’s something related to abuse.

·  Start asking more questions or show worry or concern with your facial expressions.

·  Be in a room on your own with a student with the door closed.

· Draw too much attention to the situation.

· Promise confidentiality if they ask you to keep a secret. Explain ‘If it’s necessary, I will tell somebody else (who can help more than I can.)’ 

·  Put words in their mouth or make any comments on what they tell you.

· Write while they are talking to you.

· Ask any direct or leading questions or start probing. (That could jeopardise any subsequent police investigation, if that becomes necessary.)

· Leave the student alone after they’ve disclosed. Make it clear to staff member sitting with student not to ask any questions; just be a reassuring presence

· Tell any colleagues what the student has said (apart from one of those listed as needing to be told).

· Write any opinions, or draw any conclusions about anything. Don’t write any comments about the accused.

· Try and ‘improve’ the student’s English if it wasn’t grammatically accurate or vocabulary was wrong. (That is a job for any police or social services people to do.)

· Talk to any colleagues about what has happened.

 

Refer directly to the one of the DSS as set out above. Once the DSL is involved, he/she will liaise with the Local Child Safeguarding Board to determine the correct course of action. This would be done where it is believed:

• there is a risk of significant harm to the student or

• harm to others or

• a criminal act has taken place or

• the student is at immediate risk or danger

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

• seek further advice from Social Services

• make a referral to Social Services

• report the incident to a designated Social Worker

• report the matter to the Police if a crime is suspected

Do not discuss the case with anyone outside the DSS.

If the DSL is accused, the DSS will contact MASH (for Salisbury) or LCSB (for Oxford Street) directly and follow their directions.

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

Record 

Make brief notes at the time and write them up in detail as soon as possible.

Do not destroy any original notes in case they are required by Court.

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

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

 

 

Prevent

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

PREVENT training is considered part of safeguarding and so concerns about radicalisation would also be reported. All teachers have received training in this. Furthermore, the DSL has established contact with the local PREVENT police officer. The Director of Studies and Assistant Director of Studies have attended a course, conducted by English UK, outlining their responsibilities under the legislation.

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

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

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

Terrorist material could include: 

• articles, images, speeches or videos that promote terrorism

• content encouraging people to commit acts of terrorism

• websites made by terrorist organisations

• videos of terrorist attacks

• messages intended to stir up hatred against any religious or ethnic group.

• bomb-making instructions

Additional useful contacts 

Anti-Terrorist Hotline: 0800 789 321

Reporting terrorist material online at https://eforms.homeoffice.gov.uk/outreach/terrorism_reporting.ofml

 

Anti-terrorist Hotline 0800 789 321
Reporting terrorist material online https://eforms.homeoffice.gov.uk/outreach/terrorism_reporting.ofml

 

 

Training

It is the DSL’s responsibility to ensure that all adults have training as appropriate.

Level 1 Basic Awareness applies to homestay hosts, teaching staff and group leaders (through the use of group leader agreements).

Level 2 Advanced Safeguarding applies to members of the DSS.

Level 3 Specialist Safeguarding Training applies to the DSL.

 

Delivery

Initial

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

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

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

Refresher

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

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

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

 

 

Safer recruitment

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

Stages

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

DBS Applications and renewals

Obtaining criminal record checks for

Teacher

1. when a new DBS is required

UKCE obtain permission to run enhanced DBS upon passing interview.

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

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

2. when a teacher has an existing DBS from elsewhere

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

3. renewal for active employees

DBS is checked annually via the update system.

 

Homestay (most relevant for Salisbury)

1. new

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

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

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

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

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

3. renewal for returning hosts

DBS is checked annually via the update system.

4. Agency (most relevant for Oxford Street)

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

 

Activity leader

1. when a new DBS is required

UKCE obtain permission to run enhanced DBS upon passing interview.

While awaiting DBS, UKCE run a barred list check as a minimum, and do not allow unsupervised access to U18s.

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

2.when a leader has an existing DBS from elsewhere

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

3. renewal for returning employees

DBS is checked annually via the update system.

 

Transfer contractors

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

 

Overseas applicants

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

 

Responding to existing record

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

 

 

Welfare and the Implementation of Safeguarding

Risk Assessments

Risk assessments are used to consider the risks that are posed to vulnerable students along with actions to address these. They are used for 16 + students who are placed with adult students, U18 students in closed groups and all students on excursions.

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

Supervision

The following ratios of adults to U18s are observed:

 

Age Supervision Ratio   Maximum Class Size
8-11 1:14 10
12-15 1:14 14
16+ 1:20 20 (Oxford Street); 14 (Salisbury)

 

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

Welfare Provision

Oxford Street

• Students are given a handbook before arrival which highlights relevant information including local laws, healthcare providers and advice about life in London.

• Induction includes the naming of the front desk staff and safeguarding team as points of contact.

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

• A phone line is provided for the students and printed on their student ID badges.

• A lanyard system identifies U18s with red, staff with dark blue, adult students with turquoise and visitors with yellow.

• Staggered breaks to avoid overcrowding and unnecessary contact between adults and U18s

Salisbury

• Students are constantly aware of the provision of welfare through the wearing of wrist bands that have details of the emergency line and DSS.

• There is an ethos of friendly concern and availability that extends to all adults, with lines of communication to the DSS for reporting purposes as necessary.

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

Parental Consent

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

Emergency contact details

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

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

 

 

Accommodation

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

• Acceptable cleanliness

• Furniture and fittings

• Introduction of prohibited items

• Damage, misuse or loss of fire detection and fire-fighting equipment

• A representative will visit all accommodation provided to ensure that they meet the standards of the British Council prior to placing students.

• Accommodation providers are required to have an enhanced Disclosure and Barring Service (DBS) Certificate should they accommodate students under the age of 18.

• Accommodation providers are required to create student registers that are to be regularly monitored to ensure it is current and accurate.

• Accommodation providers are to be gas safety certified.

• Accommodation provided is fitted with smoke alarms that are in working order.

• Accommodation providers will not accommodate two students with the same first language unless unavoidable or specifically requested, in writing, by the students, UKCE, legal guardians/ agency representatives.

Students’ rooms and facilities

Accommodation providers are required to provide the following for students:

• A sufficiently spacious bedroom with natural light, equipped with a single or double bed

• A towel and bed linen which will be changed in a weekly basis and an adequate supply of duvets or blankets

• An adequate sized mirror

• A wardrobe or drawer space

• Facilities for a daily shower

• A desk and a chair or study space at the accommodation, where available

• Adequate heating and lighting

• Privacy from members of the opposite sex

• Access to washing and ironing facilities or a weekly laundry service, especially in the case of under 16s

Homestay accommodation

The regulations that govern homestay accommodation are as follows:

• UKCE homestay accommodation providers will accept students into their home as temporary members of the household.

• Students will eat and live with their homestay accommodation providers and students will be given access to the property.

• The household must ensure a comfortable living environment.

• There will be an adult at the homestay accommodation to receive students on their arrival and overnight when students under the age of 16 are present.

• No student under the age of 18 will be accommodated with a student or person aged 18 or older.

• No more than four students will be accommodated in one homestay accommodation at any one time.

• No more than two students will be accommodated in the same bedroom unless specifically requested in writing by UKCE, the students, their agency representatives, or parents/legal guardians.

• English will be the language of communication within the homestay home.

• Contact names and telephone for UKCE and homestay accommodation providers will be given to students and their legal guardians/ agency representatives for use in cases of emergency.

 

 

Student Behaviour and Discipline

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

In accommodation, students should:

• respect their fellow residents and be careful of everyone’s health and safety

• respect the accommodation and avoid damaging the furnishings and facilities

• respect the privacy of the hosts amnd not give out their information or invite guests without their permission

• never be in possession of weapons or replica weapons

• not rearrange the furniture in their accommodation

• not drink or smoke if they are under the age of 18. Other smoking devices (such as e-cigarettes) are also not permitted.

• never cover smoke detectors

 

At all times, students should:

• arrive on time for lessons and activities

• not eat in classrooms

• only use phones in class as directed by the teachers

• try to maximise their learning by using English in class

• minimise abusive behaviour (see below)

• feel welcome to raise concerns with the safeguarding and welfare team

 

Abusive Behaviour

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

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

• Verbal abuse

• Harassment

• Bullying

• Actual or threatened violence

• Damage to personal property

 

The following actions also constitute abusive behaviour:

1. Deliberate unkindness or any action that causes hurt or upset will not be tolerated from any student, staff member or visitor.

2. It is a form of abusive behaviour to write notes, make phone calls or send electronic messages that are offensive, hurtful, annoying or worrying.

3. Abusive behaviour can also include Cyberbullying; use of information technology to repeatedly harm or harass other people in a deliberate manner, e.g. sending, forwarding or posting harmful material using a cell phone or the internet. Cyberbullying can also take place in the workplace or on company web sites, blogs or product reviews.

4. Students, staff members and visitors have a right to privacy of property and personal information in school. It is dishonest and can be a form of abuse to go into another person’s pocket or bag, read a private document or electronic message.

 

Procedure for dealing with breaches of the code of conduct

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

1. The misbehaviour is first brought to the attention of the student by an adult so that the student can correct it himself / herself.

2. A member of DSS reminds the student of the code of conduct (and the later steps of dealing with it) and asks the student to sign a customised and relevant code of conduct declaration.

3. A final warning is given.

4. As a last resort, in consultation with all parties, the course / accommodation services may be cancelled without refund.

 

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

If abusive behaviour is suspected or witnessed, a clear account of the incident must be reported to a member of DSS who must deal with it immediately.

1. The member of DSS/s will interview everyone who was involved and will further record the incident.

2. Parents, guardians and/or agents will be kept informed, where necessary.

3. Punitive measures will be used as appropriate and in consultation with all parties concerned. This may lead to permanent exclusion from the course and any other services (e.g. accommodation). No refund or alternative arrangements will be made.

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

• offering an immediate opportunity to discuss the experience with DSS

• offering continuous support and reassurance

• working on restoring self-esteem and confidence

• taking measures to ensure no further abusive behaviour occurs

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

• being given the opportunity to discuss the events

• discovering why s/he became involved

• establishing the wrong doing and the need to change behaviour

• advising and supporting him/her to seek professional help

• if s/he is a student, inform parents, guardians and/or agents to help change the attitude, where necessary

• if s/he is a staff member, informing their line manager to help change the attitude, where necessary. Should the offence be of a serious nature, disciplinary procedures will be followed

 

Additional considerations

Fire Safety

Fire safety risk assessments make provision for U18s in terms of additional precautions, such as awaking younger students in residential accommodation.

Homestay hosts are required to complete their own fire safety risk assessments.

Safety during transfers

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

Oxford Street

U18 students are accompanied during group leaders during their flights and transfers.

Salisbury

Homestay hosts greet students on the first day and help to arrange their transport to school.

Special Educational Needs

Designated staff should be careful not to confuse Special Educational Needs with warning signs of abuse. To avoid this, they should be aware of which students have special needs through the enrolment process. These students may be especially vulnerable.

Private Fostering

If an U18 is placed with a host family for over 27 nights, the arrangement changes and is subject to a private fostering agreement, with the agreement of the local council (Wiltshire for Salisbury and Westminster for Oxford Street).

GDPR with regard to safeguarding

• The Data Protection Act 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe.

• Private data regarding staff and student identification is held securely within databases with restricted access and kept securely when in hard copy.

• For safeguarding purposes, relevant staff may have access to student phone numbers for the purpose of maintaining contact. These are kept on school phones and deleted as soon as they are no longer required.

• A paper folder is used to keep records of concerns and allegations and is kept securely in the Academic Management offices of Oxford Street and Salisbury for their respective reports.