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Safeguarding Policy

The Real Consultancy Company (TRCC) is committed to ensuring that arrangements are in place to safeguard and promote the welfare of its candidates.  Further, for those candidates aged 18 and under (young people), or in the case of adult learners with learning difficulties and disabilities, aged 25 and under, TRCC is committed to ensuring that it complies with its statutory duty under section 175 of the Education Act 2002 and the Children Act 2004.


In addition to this, TRCC has similar duties and commitments to our candidates who fall under the Vulnerable Adults category, as defined by the ‘No Secrets’ Government guidance 'a person aged 18 years or over, who is in receipt of or may be in need of community care services by reason of 'mental or other disability, age or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation'.




The Governing Board has overall responsibility and is supported in the delivery and monitoring of this policy by the Central Services Manager.




The following definitions apply to this policy:


  • ‘Child’ is anyone aged 18 and under.

  • ‘Vulnerable adult’ is a person aged 18 years or over, who is in receipt of or may be in need of community care services by reason of mental or other disability, age or illness and who is or may be unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation.


Reasons for the Policy


The policy exists to ensure that TRCC implements appropriate arrangements, systems, and procedures to ensure that staff at TRCC have the right skills, means and resources to protect children and vulnerable adults from harm.  Further TRCC recognises that candidates who are abused or witness violence may find it difficult to develop a sense of self-worth and that TRCC may be the only stable, secure and predictable environment in the lives of those apprentices at risk.


TRCC will endeavour to support those apprentices through a range of mechanisms including a positive ethos, behavioural policies and procedures and liaison with external agencies and expertise such as Social Services and the educational welfare and psychology services.


Policy Objectives


The objectives of this policy are to:


  • Ensure TRCC practices safe recruitment in checking the suitability of staff (consultants and volunteers if appropriate) to work with learners aged 18 and under to raise awareness of child protection issues and to equip young people and vulnerable adults with the skills needed to make them safe.

  • Develop and implement procedures for identifying and appropriately reporting or referring cases, or suspected cases, of abuse.

  • Support young people and vulnerable adults who have been abused in accordance with his/her agreed child protection plan.

  • Establish a safe environment in which young people and vulnerable adults can learn and develop.

  • Enable apprentices to: Be healthy, stay safe, Enjoy and achieve, make a positive contribution and achieve economic well-being.




We recognise that because of their contact with the apprentices, assessment staff and support staff, we are well placed to observe the outward signs of abuse. TRCC will therefore:


  • Establish and maintain an environment where young people and vulnerable adults feel secure, are encouraged to talk and are listened to.

  • Ensure that young people and vulnerable adults know that there are designated staff at TRCC whom they can approach if they are concerned or upset.


In order to achieve the above TRCC will:


  • Ensure we have a designated lead professional member of staff responsible for child protection issues who has received appropriate training and support for this role.

  • Ensure every member of staff and relevant external parties knows the name of the designated lead professional Develop effective links with relevant agencies and cooperate as required with their enquiries regarding child protection matters including attendance at case conferences.

  • Keep confidential written records of concerns about learners, even where there is no need to refer the matter ·         immediately.

  • Ensure that all records are kept securely; separate from the main learner files and in a locked location.

  • Ensure strict adherence to procedures when an allegation of any kind concerning learners is made against a member of staff.

  • Ensure safe recruitment practices are followed.


Related Policies


The following policies should be read in conjunction with this policy:


  • Anti-harassment policy.

  • Customer Complaints Procedure

  • Disciplinary policy and procedures for candidates

  • Disciplinary policy and procedures for staff

  • Health and Safety policy




Procedures for the implementation of this policy are contained in the Appendix 1.



  • Central Services Manager


Who should know about this policy?


All staff and apprentices, particularly those apprentices under the age of 18 (25 for vulnerable adults) and their parents/carers and employers.


Child Protection Procedures/Safeguarding Children and Vulnerable Adults


Child and vulnerable adult abuse of all kinds - physical, sexual, emotional, neglect, financial and discriminatory - has been increasingly detected in recent years.  Adults working in a private training provider are well placed to notice signs of abuse or may be approached by a learner who wishes to make a disclosure.  It is vital that all members of staff are aware of the appropriate way to respond to situations which may indicate that a child is being abused.


TRCC in the development of its safeguarding policy has taken account of local authority good practice procedures which state:

‘An abused child is any boy or girl, under 18 years of age, who has suffered from, or is believed likely to be at risk of, significant risk or physical injury, neglect, emotional abuse or sexual abuse.’


The Children Act of 2004 gives every child the right to protection from abuse and exploitation and the right to have enquiries made to safeguard his or her welfare.


What to do


If any member of staff has any concerns about an apprentice they consider to be suffering or to be at risk of suffering significant harm, he/she must immediately contact the:


  • Central Services Manager


What concerns should be passed on


Members of staff are sometimes unsure if a concern comes under the safeguarding procedures and the following may help with this:


  • Any suspicion, allegation or incident of abuse must be reported to the Central Services Manager of TRCC or in his/her absence, the Lead IQA immediately.

  • The Central Services Manager will discuss the situation with Social Services through the integrated team if appropriate.  This will include advice and discussion as to whether to make a formal referral for child protection.

  • The discussions will include advice regarding Social Services’ contact with the young person’s parents/carers.  In support of this process, any contact with parents/carers by other members of staff MUST be referred to Central Services Manager of TRCC or in his/her absence the Lead IQA.

  • the Central Services Manager of TRCC or in his/her absence the Lead IQA will make a full and careful written record of the alleged abuse and the report must include the name and position of the person to whom the matter is initially reported. This should be done immediately or as soon as possible thereafter. The record must be kept secure and confidential. The relevant information should include:

    1. the date and time the allegation was made.

    2. Staff name and the names of others present.

    3. The place where the alleged abuse took place, date and time. The name of the complainant.

    4. Where different, the name of the child who has allegedly been abused.

    5. A description of any injuries observed.

    6. An account of the allegation.

  • Any telephone report must be confirmed in writing to Social Services department as soon as possible. The confirmation may be handwritten, posted or emailed, but a copy must be kept securely on file.

  • The Central Services Manager of TRCC or in his/her absence the Lead IQA shall retain a copy of the written records and any other relevant material. These will be kept securely at all times.

  • Allegations against staff will also follow agreed Personnel procedures and will be referred to the Central Services Manager of TRCC or in his/her absence the Lead IQA or the Chair of the Governing Board.


What not to do


Staff should not:


  • Promise confidentiality.

  • Ask leading questions.

  • Criticise or give their views.


Who should staff discuss their concerns with:


Staff should ONLY discuss their concerns with the Central Services Manager of TRCC or in his/her absence the Lead IQA if:


  • An apprentice discloses that he/she has been sexually abused in the past or is now being sexually abused.

  • An apprentice discloses that he/she has been physically abused in the past or is now being physically abused.

  • Staff are told by another learner or parent/carer that they know a learner is being abused.

  • Staff see bruises or cuts that lead them to be suspicious of physical injury.


Neglect or Emotional Abuse


Members of staff often find it more difficult to know what to pass on in these circumstances.  Any concerns or worries about a learner’s welfare should be discussed with the Central Services Manager of TRCC or in his/her the Lead IQA regarding:


  • Lack of adequate food, clothes or hygiene.

  • Loss of weight.

  • Increase in apathy.

  • Excessive attention-seeking behaviour.

  • Unduly aggressive behaviour.


Suspected abuse by a member of staff


In the rare event that a member of staff suspects that an apprentice is being abused by a person on the staff of the apprentice’s workplace, training provider or at TRCC a report should be made in strict confidence to Central Services Manager.  If the Central Services Manager of TRCC is suspected of improper conduct this should be reported immediately in strict confidence to the Chair of the Governing Board.


 Suspected abuse by another apprentice


Any form of inappropriate behaviour (i.e. bullying and harassment) towards candidates will be dealt with under TRCC’s Disciplinary Procedures.


Responding to an Allegation – Guidelines


The guidelines on child protection emphasise the need for a careful and measured approach to reported or suspected child abuse.  Whether or not to make a referral, which could activate a child protection investigation, is a serious decision and will require careful judgement.


All complaints, allegations or suspicions of abuse must be taken seriously.  Staff are required to respond with sensitivity to a young person who confides in them, recognising that it requires courage (and/or desperation) to share such painful and personal concerns.


The Central Services Manager is also available to offer that young person support and advice and would also immediately refer any suspected cases of child abuse to the Chair of the Governing Board.


The procedures must be followed whenever an allegation is made that a young person/vulnerable adult has been abused or when there is suspicion that a young person has been abused.


Promises of total confidentiality cannot, and must not, be given.  However, young people can be assured that as few people as possible will be involved. No one will be told more than they need to know. Information is shared only on a need to know basis.


The young person/vulnerable adult will be informed of all actions taken.


Young people with learning difficulties and/or disabilities may need a different approach than other young people.  Staff must be aware of any special considerations with regard to communication difficulties and equal opportunities.  This issue will be dealt with through staff training and development.


Abuse of a Position of Trust


The Sexual Offences Act sets out a series of occupations to which the abuse of position of trust laws applies and these include End Point Assessment Organisations.


The offences for those working in positions of trust cover the same kinds of behaviour as offences which apply to the general public, except that, where positions of trust are concerned, the offences

apply where the young person is under 18, instead of under 16, even though they are over the age of consent, they are potentially vulnerable to sexual abuse from people in positions of trust or authority.  The Act sets down specific positions of trust to which offences relate. People who are in these positions of trust will normally have power and authority in a child's life and may have a key influence on their future. This applies to all roles and responsibilities within TRCC.


Good Practice


TRCC must be aware of the need to adhere to recognised good practice in the protection of children. In accordance with such practice TRCC will take steps to ensure that:


  • Promises of confidentiality are not given, as the matter may need to be taken further.

  • Individuals feel secure that any information they give will only be used to improve their circumstances.

  • As few people as possible are involved in the procedure.

  • Staff act on the basis that the overriding concern is the safety of the young person/vulnerable adult.

  • Where the complainant is a young person, questions are kept to a minimum necessary to understand what is being alleged and leading questions are avoided.

  • The young person/vulnerable adult understand that external agencies may become involved.

  • Particular attention is given to a young person/vulnerable adult with learning difficulties and/or disabilities.

  • If an apprentice declares to staff that they were abused as a child and that apprentice does not wish further action to be taken, his/her wishes are respected.

  • Conversations between staff and the discloser of abuse and (if different) the young person are recorded immediately and held in a confidential and secure place.


Physical contact with apprentices


As a general principle, staff should avoid all forms of physical contact with apprentices.  Many apprentices dislike any form of physical contact and see it as intrusive, which can lead to aggressive or challenging responses.  Physical contact which may be misconstrued by the apprentice, parent/carer or other observer should be avoided.  This could include well intentioned informal gestures such as a hand on the shoulder or arm which some apprentices can misinterpret.  A distressed apprentice may need comfort or reassurance.  The apprentice’s agreement should be sought before any physical comforting is given.


Some staff are more likely to come into physical contact with apprentices on occasions e. g. observation, professional discussion or presentations.  On such occasions staff should be aware of the limits within which this contact should take place.


Staff administering first aid should also be aware of the appropriate limits to physical contact and it is advisable that another apprentice or adult is present if the first aider is concerned as to the nature of the contact.  Staff who see c apprentices individually should be aware of the potential issues which may arise from private interviews.  Where possible, such interviews should be held in a room with visual access or with the door open, or in a room or area likely to be frequented by other people.  It is always advisable to ensure another adult knows the interview is taking place.

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