Safeguarding Policy
Purpose and scope
This policy sets out how Clarence Green College safeguards and promotes the welfare of children and young people receiving Alternative Provision (AP). It applies to all staff, leaders, tutors, assessors, volunteers, contractors and anyone working on behalf of the College in connection with AP.
The policy applies whether provision is delivered at a College-controlled site, a commissioned venue, a shared/community location, online, or through an approved off-site activity. It applies to commissioned placements and to parent/carer enquiries or privately funded arrangements involving a child.
For the purpose of this policy, a child is anyone under the age of 18. Safeguarding arrangements for learners aged 18 or over are addressed through adult safeguarding procedures, although this policy may still inform good practice where a mixed-age cohort is involved.
2. Policy statement and safeguarding principles
Clarence Green College is committed to creating a safe, inclusive and respectful environment in which children can learn, re-engage with education and progress. Safeguarding is everyone’s responsibility and concerns will be acted on promptly, proportionately and in the best interests of the child.
• The welfare and best interests of the child are paramount.
• Children will be listened to, taken seriously and told how to obtain help.
• All staff must maintain professional curiosity and act on concerns rather than assume someone else will do so.
• No member of staff should promise a child absolute confidentiality where safeguarding information may need to be shared.
• Discrimination, harassment, bullying and abuse are not tolerated.
• Safeguarding practice will be inclusive and responsive to disability, SEND, communication needs, culture, language, sex, sexual orientation, religion or belief, and other individual circumstances.
• Information will be shared lawfully and proportionately when needed to protect a child.
• Commissioners will be kept informed in accordance with the safeguarding arrangements agreed for each placement.
3. Legal and national guidance framework
This policy has been developed with reference to current national legislation and guidance for England. Clarence Green College adopts the Department for Education’s Non-school Alternative Provision Voluntary National Standards as a framework for good practice and commissioner assurance.
• Children Act 1989 and Children Act 2004.
• Education Act 1996 and Education Act 2002, where relevant to commissioners and education partners.
• Keeping Children Safe in Education (KCSIE) 2026, effective 1 September 2026.
• Working Together to Safeguard Children 2026.
• DfE Alternative Provision statutory guidance, updated February 2025.
• DfE Non-school Alternative Provision: Voluntary National Standards, August 2025.
• Working Together to Improve School Attendance, updated July 2026.
• Counter-Terrorism and Security Act 2015 and Prevent Duty Guidance: England and Wales (2023), updated March 2024, where applicable and as a safeguarding framework.
• Equality Act 2010.
• Data Protection Act 2018 and UK GDPR.
• DfE information-sharing advice for safeguarding practitioners, updated 2024.
Status of KCSIE for this provider
KCSIE is statutory guidance for schools and colleges. Clarence Green College uses its safeguarding principles and procedures as a benchmark for AP practice and to support commissioning schools and local authorities in meeting their continuing safeguarding duties.
4. Definitions
Safeguarding and promoting welfare
Safeguarding includes providing help and support to meet children’s needs as soon as problems emerge; protecting children from maltreatment whether within or outside the home, including online; preventing impairment of mental and physical health or development; ensuring children grow up with safe and effective care; and taking action to enable the best outcomes.
Child protection
Child protection is the activity undertaken to protect specific children who are suspected to be suffering, or likely to suffer, significant harm.
Alternative Provision
Alternative Provision refers to education arranged outside a pupil’s usual mainstream setting because they require a different educational approach or cannot access suitable education in their usual setting. The commissioning school or local authority retains responsibilities for the child, including safeguarding and oversight of the placement.
5. Governance and safeguarding leadership
The proprietor/senior leadership team is responsible for ensuring that effective safeguarding arrangements are in place, resourced, implemented, monitored and reviewed annually. The College will maintain a named Designated Safeguarding Lead (DSL) and, wherever practicable, a trained Deputy DSL.
The DSL will:
• lead safeguarding and child protection practice across Alternative Provision;
• work with commissioning school DSLs and local authority commissioning leads before and during placements;
• review safeguarding information and ensure risk assessments are completed where required before a child starts;
• record, triage and act on safeguarding concerns;
• share relevant safeguarding information with commissioners and statutory agencies;
• make or coordinate referrals where this has been agreed or where urgent action is required;
• liaise with children’s social care, police, Prevent/Channel partners and the LADO as appropriate;
• advise and support staff and arrange additional safeguarding training where necessary;
• ensure this policy and related safeguarding procedures remain current;
• ensure safeguarding records are secure, accurate and available to authorised staff only.
The DSL will undertake role-appropriate safeguarding training and refresh formal DSL training at least every two years, with updates and learning in between. Any Deputy DSL will be trained to the same standard.
6. Roles and responsibilities
All staff and adults working with children must:
• read and understand the safeguarding information and procedures relevant to their role;
• complete required safeguarding induction and training;
• be alert to indicators of abuse, neglect, exploitation, radicalisation, online harm and other welfare concerns;
• report concerns immediately to the DSL or Deputy DSL;
• act directly in an emergency if delay would place a child at further risk;
• maintain appropriate professional boundaries and follow the staff behaviour/code of conduct policy;
• record factual information promptly and accurately;
• challenge unsafe practice and report low-level concerns or allegations about adults.
Commissioners and placing organisations
The College expects the commissioning school or local authority to provide relevant information before placement, remain actively involved in safeguarding and attendance, and agree with the College how concerns and referrals will be progressed. The commissioning organisation retains its own safeguarding responsibilities throughout the placement.
7. Safer recruitment and staff suitability
Clarence Green College will use safer recruitment practices proportionate to each role and consistent with the DfE voluntary national standards for non-school AP.
• Identity, right-to-work and employment-history checks will be completed.
• Enhanced DBS checks, including children’s barred list information where appropriate to regulated activity, will be obtained before unsupervised work with children.
• Qualifications and professional status will be checked where relevant.
• References will be obtained and scrutinised, with gaps or inconsistencies explored.
• Online searches may be undertaken as part of due diligence where lawful and appropriate.
• Overseas checks will be considered for individuals who have lived or worked abroad.
• Recruitment and vetting checks will be recorded on a Single Central Record or equivalent safeguarding register.
• No person who has failed required safeguarding checks will be permitted to undertake a role for which those checks are required.
• Contractors and agency staff must provide written evidence of appropriate checks and remain subject to the College’s safeguarding procedures.
8. Staff induction, training and professional conduct
All permanent staff will receive safeguarding induction before or at the start of work with AP learners. Child protection training will be refreshed at least annually, with updates provided whenever risks, guidance or local procedures change. Temporary staff, volunteers and contractors will receive proportionate safeguarding information based on their role and level of contact with children.
Staff must follow the College’s code of conduct, including expectations concerning professional boundaries, communication, gifts, social media, personal devices, photography, transport, one-to-one work, and contact outside agreed provision. Staff must never use personal social media accounts to communicate with learners.
9. Responding to safeguarding concerns and disclosures
A safeguarding concern may arise from something a child says, a change in behaviour or presentation, information from another person, an online interaction, attendance patterns, an injury, a disclosure, or a concern about an adult’s conduct.
If a child discloses abuse or harm, staff should:
1. Listen calmly and take the child seriously.
2. Do not promise secrecy. Explain that the information may need to be shared with people who can help.
3. Use open prompts only where necessary for clarification; do not investigate or ask leading questions.
4. Reassure the child that they have done the right thing by speaking.
5. If immediate safety or medical action is required, take that action without delay.
6. Record the child’s words as accurately as possible, distinguishing fact from professional observation.
7. Report the concern to the DSL/Deputy DSL immediately.
8. Preserve any relevant evidence and do not confront an alleged perpetrator unless directed by safeguarding authorities.
If the DSL is unavailable
A concern must never be left unreported because the DSL cannot be reached. Contact the Deputy DSL or a senior leader. Where a child may be at immediate risk or significant harm is suspected, staff may contact children’s social care or the police directly and then inform the DSL and commissioner as soon as possible.
10. Referrals, escalation and immediate danger
At the start of each placement, Clarence Green College and the commissioner will agree who normally leads external safeguarding referrals. This does not remove any individual’s duty to act if a child is at risk.
• Immediate danger or an emergency: call 999.
• Suspected significant harm or serious welfare concerns: contact the relevant local authority children’s social care service without delay, following local threshold procedures.
• Concerns about a member of staff, volunteer, contractor or proprietor: follow the allegations procedure and contact the relevant LADO where the threshold is met.
• Possible criminal offence: liaise with police as appropriate.
• Radicalisation concerns: follow local Prevent referral arrangements and consider Channel support where relevant.
• If disagreement with another agency leaves a child at risk, the DSL will use professional escalation procedures rather than allow the matter to drift.
11. Working with commissioners and placing schools/local authorities
Safeguarding responsibilities and communication routes will be agreed before the placement starts and recorded in the placement/referral documentation.
• The College will obtain the name and contact details of the commissioner, school DSL (where applicable), parent/carer and emergency contacts.
• Relevant safeguarding, behaviour, SEND, medical, attendance and risk information must be shared before the placement where possible.
• Significant safeguarding incidents will be reported promptly to the commissioner in accordance with the agreed protocol.
• The College will participate in safeguarding meetings, reviews, strategy discussions and multi-agency work where invited or required.
• Any change in staffing or delivery arrangements that could materially affect safeguarding will be communicated to the commissioner.
• Placement suitability will be reviewed where safeguarding risks cannot be safely managed.
12. Attendance, absence and children missing education
Attendance is a safeguarding matter. The College will record attendance or absence for every scheduled AP session and share this information promptly with the commissioner.
• Attendance information should be provided to the commissioner as soon as practicable and, where agreed, ideally within 30 minutes of the start of the session.
• Unexpected or unexplained absence will be followed up urgently in accordance with the placement agreement.
• Where the College is responsible for first-day contact, staff will contact the parent/carer and, where appropriate, professionals working with the child.
• If a child cannot be located or the circumstances raise welfare concerns, the DSL and commissioner will consider safeguarding action immediately.
• Patterns of absence, late arrival, unexplained changes in attendance or repeated non-engagement will be reviewed as potential safeguarding indicators.
• Attendance concerns and support will be reviewed with commissioners regularly, and more frequently where risk is elevated.
13. Child-on-child abuse, sexual violence and harassment
Abuse can occur between children and may take place in person or online. Staff must never dismiss harmful behaviour as “banter”, “part of growing up” or something children should tolerate.
• bullying, including cyberbullying and prejudice-based or discriminatory bullying;
• physical abuse;
• sexual violence and sexual harassment;
• consensual and non-consensual sharing of nude or semi-nude images and videos;
• upskirting or image-based abuse;
• abusive or controlling behaviour within intimate relationships;
• initiation or hazing-type violence and rituals;
• exploitation, coercion or intimidation by peers.
Reports will be risk assessed and responded to in a way that protects the child reporting harm, any other children at risk, and the rights and welfare of the child alleged to have caused harm. Separate support and safety planning will be considered where appropriate.
14. Specific safeguarding risks
Staff will receive training and guidance relevant to the risks encountered by AP learners. Concerns must be reported even where evidence is incomplete.
• Neglect and physical, emotional or sexual abuse.
• Child sexual exploitation and child criminal exploitation, including county lines.
• Serious violence, gangs, weapons and community-based harm.
• Domestic abuse and children affected by abusive relationships.
• Modern slavery, trafficking and exploitation.
• Female genital mutilation (FGM), forced marriage and other so-called honour-based abuse.
• Missing episodes and risks linked to absence from education.
• Homelessness, unsafe accommodation and family breakdown.
• Substance misuse.
• Mental health concerns where these may indicate or increase safeguarding risk.
• Online abuse, grooming, sextortion, coercion, harmful content and technology-facilitated abuse.
• Bullying, hate incidents and discriminatory abuse.
• Self-harm or suicidal concerns: these will be treated as urgent welfare matters and escalated to appropriate emergency/health services where necessary.
15. Online safety, technology and generative AI
Online safety is integrated into safeguarding practice. Where the College controls devices or networks used by AP learners, it will use proportionate filtering, monitoring and access controls and will review their effectiveness in light of the learners’ ages, needs and risks.
• Learners will receive age-appropriate guidance on safe and responsible technology use.
• Professional accounts and approved platforms will be used for online teaching and communication.
• Staff must not use personal messaging or social media accounts to communicate with learners.
• Remote sessions must take place through approved arrangements and must not create unmanaged one-to-one safeguarding risks.
• Photographs, recordings and personal data may only be captured or shared for legitimate purposes and in accordance with College policy and consent/lawful basis requirements.
• Safeguarding case information, identifying personal data or confidential learner records must not be entered into public generative AI tools.
• Generative AI must never be used as a substitute for professional safeguarding judgement, risk assessment or statutory referral decisions.
• Any technology-facilitated abuse or online concern will be handled through normal safeguarding procedures.
16. Prevent, radicalisation and extremism
Clarence Green College treats susceptibility to radicalisation as a safeguarding concern. The College will follow relevant Prevent guidance, local safeguarding arrangements and commissioner requirements. Where the College is not itself a specified authority, the same principles may be applied as good safeguarding practice and to support commissioners that are subject to the Prevent duty.
• Staff will receive Prevent awareness appropriate to their role.
• The DSL will understand local Prevent referral routes and government Prevent training resources.
• Concerns may include changes in behaviour, extremist or terrorist material, online grooming, coercion or signs that a learner is being influenced to support terrorism.
• Concerns will be assessed in context and without stereotyping or discriminatory assumptions.
• Where appropriate, the DSL will consult the commissioner and local Prevent/Channel arrangements.
17. SEND and learners with additional vulnerabilities
Children with SEND, communication needs, care experience, social care involvement, disrupted education, poor attendance or previous exclusion may face additional safeguarding vulnerabilities. Staff will consider the possibility that signs of abuse may be misinterpreted as part of a child’s disability, behaviour or additional needs.
• Reasonable adjustments will be made to communication and reporting routes.
• Individual risk assessments and support plans will incorporate known safeguarding information.
• EHC plans, personal education plans, individual healthcare plans and relevant support plans will be reviewed where provided.
• The learner’s voice will be sought using communication methods appropriate to their needs.
• Information about looked-after and previously looked-after children will be handled sensitively and in collaboration with relevant professionals.
18. Behaviour, de-escalation and physical intervention
Positive relationships, predictable routines and de-escalation are the preferred approaches to behaviour. The College will maintain a separate behaviour policy and will make reasonable adjustments for learners with identified needs.
Physical intervention will be avoided wherever possible and used only where lawful, necessary and proportionate to prevent harm or serious disruption, and by staff who are appropriately trained where required. Any significant physical intervention will be recorded, reviewed and reported to the commissioner and parent/carer in accordance with policy and the placement agreement.
19. One-to-one, community, off-site, remote and transport arrangements
Alternative Provision may be delivered in varied environments. The College will use proportionate risk assessment and safe-working arrangements for each delivery model.
One-to-one work
• Locations should, where practicable, allow appropriate visibility or oversight while preserving dignity and confidentiality.
• Unplanned isolation of a learner with an unchecked adult is not permitted.
• Professional boundaries and communication rules apply at all times.
Community and off-site provision
• Individual and location-based risks must be assessed before provision.
• Arrangements for arrival, departure, supervision, emergency contact and unexpected absence must be clear.
• Where the public or unchecked adults may be present, supervision must be proportionate to risk.
Home-based or remote provision
Provision in a private home will only be used where expressly agreed, lawful, suitable and supported by a documented risk assessment and commissioner/parental arrangements. Online provision must use approved platforms and professional accounts.
Transport
Where the College arranges transport, driver suitability, insurance, vehicle safety, collection/drop-off arrangements, lone-working risks and emergency contacts will be checked and documented. Where transport is arranged by a commissioner or parent/carer, responsibilities will be clearly recorded.
20. Site security, visitors and contractors
Where the College controls the delivery site, access will be restricted to learners receiving provision, staff and supervised/authorised visitors. Sign-in procedures, visitor identification, supervision and contractor arrangements will be proportionate to the site and risk profile.
Where provision is delivered in a shared or public setting, a specific risk assessment will address public access, toilets/changing areas where relevant, arrival/departure, visibility, emergency response and the possibility of contact with unchecked adults.
21. Allegations, low-level concerns and the LADO
Any concern about the conduct of a member of staff, volunteer, contractor, leader or proprietor must be reported without delay. This includes allegations that a person has harmed or may have harmed a child, may have committed an offence against a child, may pose a risk of harm, or may be unsuitable to work with children.
Concerns about the DSL should be reported to the proprietor/senior leader. Concerns about the proprietor or where there is a conflict of interest should be reported directly to the relevant LADO/commissioner as appropriate.
• Low-level concerns will be recorded and reviewed to identify patterns or emerging risk.
• No internal investigation will compromise a police, social care or LADO process.
• The College will cooperate fully with LADO and commissioner requirements.
• Where the legal criteria are met, referrals will be made to the Disclosure and Barring Service and/or relevant professional regulator.
22. Whistleblowing
Staff must be able to raise concerns about unsafe practice without fear of retaliation. Concerns should normally be raised with a senior leader or proprietor. If internal reporting is inappropriate, ineffective or presents a conflict of interest, staff should use external safeguarding, LADO or whistleblowing routes. A concern about a child’s safety must never be delayed because of uncertainty about internal hierarchy.
23. Information sharing, confidentiality and safeguarding records
Safeguarding records will be accurate, factual, dated, secure and accessible only to authorised persons. The College will comply with the Data Protection Act 2018 and UK GDPR while recognising that data protection law does not prevent appropriate information sharing for safeguarding purposes.
• Information will be shared on a need-to-know basis and only to the extent necessary for the safeguarding purpose.
• Consent will be sought where appropriate, but lack of consent will not prevent sharing where there is a lawful safeguarding basis and sharing is necessary to protect a child.
• Safeguarding information received from commissioners will be stored securely and linked to the learner’s safeguarding record.
• Personal email accounts, personal cloud storage and informal messaging applications must not be used to store safeguarding case information.
• When a placement ends, relevant safeguarding information will be transferred or returned securely in accordance with the commissioner agreement and retention requirements.
• Access requests and disclosures will be managed in accordance with data protection law and safeguarding considerations.
24. Learner induction, voice and raising concerns
Every learner will receive an induction appropriate to their age and communication needs. The induction will explain the purpose of the placement, expected behaviour, attendance arrangements, health and safety, online safety and how to seek help or report a concern.
• Learners will be told who the DSL/safeguarding contact is.
• Learners will be offered more than one route to raise concerns where practicable.
• Learner feedback will be sought during reviews and used to improve safety and provision.
• No child will be disadvantaged for making a safeguarding report in good faith.
25. Working with parents and carers
Parents and carers are important safeguarding partners. The College will communicate relevant safety, attendance, behaviour and welfare information unless doing so would place a child at greater risk, compromise an investigation, or conflict with instructions from statutory agencies.
For parent/carer-initiated or privately funded provision, the College will still assess safeguarding suitability and will involve the child’s school, local authority or statutory agencies where this is necessary to protect the child or meet legal/educational responsibilities.
26. Complaints and safeguarding complaints
Safeguarding concerns will not be treated merely as customer-service complaints. Where a complaint contains safeguarding information, the safeguarding procedure takes priority. Complaints about safeguarding practice may also be raised through the College complaints process, but statutory referrals will not be delayed pending the outcome of a complaint.
27. Quality assurance, monitoring and review
The proprietor/senior leadership team and DSL will monitor implementation of this policy through safeguarding audits, staff training records, recruitment records, incident and concern logs, attendance data, learner/parent/commissioner feedback, risk assessments and placement reviews.
• This policy will be reviewed at least annually.
• It will also be reviewed following a serious safeguarding incident, significant complaint, change in legislation/guidance, change in delivery model or commissioning requirement.
• The College will make the policy accessible to commissioners, parents/carers and the wider public.
• Lessons learned from incidents and quality assurance activity will be translated into actions, training and procedural improvements.