Safeguarding Policy

CHILD PROTECTION AND SAFEGUARDING POLICY 

1. Purpose 

The purpose of this policy is to ensure that Elevate Learning Alternative Provision acts in a timely, proportionate and child-centred way to safeguard and promote the welfare of children. This policy ensures that all staff understand their safeguarding responsibilities, that clear systems are in place for identifying and responding to concerns, and that Elevate Learning adopts Keeping Children Safe in Education (KCSIE) and local safeguarding partner procedures as benchmark guidance for a non-school Alternative Provision. 

This policy is designed to ensure that: 

• Children are protected from abuse, neglect, exploitation and harm.  

• Safeguarding is understood as everyone’s responsibility.  

• Staff are properly trained to recognise and report safeguarding issues.  

• Early help is used where children and families need support before concerns escalate.  

• Clear referral pathways are followed where concerns meet statutory thresholds.  

• Safeguarding information is recorded, shared and escalated appropriately.  

• Safeguarding practice reflects the increased vulnerability of children attending Alternative Provision.  

Elevate Learning recognises that many children placed in AP may have experienced disrupted education, emotional distress, neurodevelopmental needs, trauma, family adversity, risk of exclusion or previous placement instability. Safeguarding practice must therefore be especially vigilant, relational and responsive.  

2. Scope 

This policy applies to all adults working in or on behalf of Elevate Learning Alternative Provision, including: 

• Employees.  

• Agency workers.  

• Contractors.  

• Volunteers.  

• Casual staff.  

• Consultants.  

• Directors and leaders.  

• Visiting professionals where relevant.  

Visitors must always follow site-safety and safeguarding instructions and will not be left unsupervised with children. 

This policy applies during: 

• Onsite provision.  

• Off-site activities.  

• Transport arrangements where relevant.  

• Blended placements.  

• Extended provision.  

• Any activity delivered by or on behalf of Elevate Learning Alternative Provision.  

3. Safeguarding Commitment 

Elevate Learning Alternative Provision is committed to providing a safe, nurturing and protective environment across all aspects of its work. As an organisation that prioritises the safeguarding of children and vulnerable individuals, Elevate Learning actively promotes a culture of zero tolerance for abuse of any kind. 

We recognise that safeguarding is not only about responding when harm has occurred. It is also about prevention, safe recruitment, staff conduct, effective information sharing, child-centred practice, early help, emotional wellbeing, and building an environment in which children feel safe enough to speak. 

Our safeguarding culture is underpinned by: 

• A whole provision approach.  

• Strong pastoral support.  

• Trauma-informed and regulation-aware practice.  

• Clear staff expectations.  

• Positive relationships.  

• Accessible reporting systems for children.  

• Robust safeguarding systems and leadership oversight.  

Elevate Learning also recognises the need for preventative education. This includes regular, developmentally appropriate work around: 

• Boundaries and consent.  

• Prejudice, stereotypes and equality.  

• Body confidence and self-esteem.  

• Respectful relationships.  

• Coercion and controlling behaviour.  

• Sexual exploitation, grooming and abuse.  

• Domestic abuse.  

• So-called honour-based abuse, including forced marriage and FGM.  

• Sexual violence and sexual harassment.  

• Online safety.  

• How children can seek support.  

3.1 Alternative Provision Context 

Elevate Learning Alternative Provision (AP) operates as a non-school Alternative Provision. Commissioning schools and Local Authorities retain statutory responsibilities for: 

• Admissions.  

• Attendance registers and attendance coding.  

• Exclusions.  

• Children Missing Education procedures.  

• Wider statutory educational duties.  

Elevate Learning holds day-to-day safeguarding responsibility while pupils are in its care and provides same-day safeguarding and attendance information to the commissioner where risk or significant incidents arise. This AP context is already reflected within your Elevate Learning provider information and commissioning model. 

Where school-specific statutory powers do not apply to non-school AP, Elevate Learning uses safeguarding-led, consent-based and risk-assessed approaches, with police or external agency involvement where appropriate. 

4. Responsibilities 

4.1 Safeguarding is Everyone’s Responsibility 

Safeguarding and child protection is everyone’s responsibility. Everyone who comes into contact with children and their families has a role to play in safeguarding children and promoting their welfare. This includes all staff, volunteers, contractors, agency staff, leaders and directors working in or on behalf of Elevate Learning Alternative Provision. All adults working within the provision must always maintain a child-centred approach and must consider, in every decision and interaction, what is in the best interests of the child. 

Elevate Learning Alternative Provision recognises that effective safeguarding depends upon a whole-provision approach. Safeguarding is not the sole responsibility of the Designated Safeguarding Lead, nor is it limited to responding to disclosures or obvious child protection incidents. It is embedded in culture, practice, relationships, communication, environment, behaviour support, curriculum delivery, pastoral systems and leadership oversight. 

As a non-school Alternative Provision, Elevate Learning works within a shared safeguarding context. Commissioning schools and Local Authorities retain statutory responsibilities for admissions, attendance registers and coding, exclusions, and Children Missing Education procedures. However, Elevate Learning holds day-to-day safeguarding responsibility while children are in its care and must therefore act promptly, proportionately and in close liaison with commissioners and external agencies where required. Significant safeguarding information, welfare concerns and serious incidents will be shared with parents/carers and with the commissioning school and/or Local Authority the same day, where appropriate and were doing so does not place a child at additional risk. Elevate Learning will also follow local missing/absent and CME procedures alongside commissioners. 

This policy applies not only to activity taking place within the main provision site, but also to: 

• Off-site activities.  

• External visits.  

• Transport arrangements where relevant.  

• Outreach or blended support arrangements.  

• Extended provision.  

• Any activity delivered by or on behalf of Elevate Learning Alternative Provision.  

Elevate Learning recognises that safeguarding is also preventative. The provision plays a crucial role in helping children understand risk, build protective behaviours, recognise unsafe situations and know how to seek help. This sits within a wider whole-provision approach to preparing children for life in modern Britain and promoting a culture of dignity, equality and respect. Elevate Learning does not tolerate sexism, misogyny, misandry, homophobia, biphobia, transphobia, discriminatory language, sexual harassment or sexual violence in any form. Harmful behaviour between children will always be taken seriously, challenged and addressed in line with safeguarding and behaviour procedures. 

This preventative safeguarding culture is underpinned by: 

• The Behaviour Policy.  

• The Staff Code of Conduct.  

• The pastoral support system.  

• The Online Safety Policy.  

• The Anti-Bullying Policy.  

• The safeguarding curriculum and wellbeing provision.  

• The provision’s trauma-informed and PBS-informed practice.  

Because many pupils attending Elevate Learning Alternative Provision may have experienced disrupted education, trauma, unmet SEND, communication differences, emotional dysregulation, school avoidance or placement instability, safeguarding must be applied with particular care, professional curiosity and contextual understanding. Staff must be alert to the fact that distress, fear or harm may present through behaviour, withdrawal, shutdown, aggression, non-attendance, anxiety, sensory overwhelm or changes in regulation rather than through direct disclosure. 

4.2 All Staff Responsibilities 

All staff working in or on behalf of Elevate Learning Alternative Provision have a clear duty to safeguard children and promote their welfare. This duty applies regardless of role, seniority or contractual status. Every adult in the provision must understand that they may be the person to whom a child chooses to disclose abuse, or the person best placed to notice an emerging concern, pattern of behaviour or change in presentation that indicates a child may be at risk. 

All staff will be expected to: 

• Read and understand Keeping Children Safe in Education Part 1, and Annex B were directed by the DSL or Provision Lead.  

• Receive role-relevant safeguarding induction before beginning unsupervised work with children.  

• Sign an annual declaration confirming that they have reviewed safeguarding guidance and understand their responsibilities.  

• Follow this Child Protection and Safeguarding Policy, the Staff Code of Conduct, the Behaviour Policy, the Online Safety Policy and all related safeguarding procedures.  

• Act immediately where they are concerned that a child may be suffering, or likely to suffer, harm.  

• Record safeguarding concerns factually, promptly and on the same day.  

• Raise concerns about staff conduct, low-level concerns or allegations without delay.  

• Always maintain professional boundaries.  

• Contribute to a safe, respectful and inclusive environment for all pupils.  

All staff must understand that safeguarding concerns may arise in a wide range of ways. A child may disclose directly, disclose indirectly, show behavioural indicators, demonstrate changes in presentation, or communicate through play, body language, avoidance, aggression, shutdown, emotional dysregulation or online behaviour. Staff must never assume that another adult will act and must never delay reporting because they are uncertain whether a concern “meets threshold”. If in doubt, staff must always speak to the DSL. 

All staff will reinforce the importance of online safety when communicating with parents and carers. This includes ensuring that parents/carers are aware of what children may be asked to do online as part of their learning, support or therapeutic provision, which platforms may be used, what risks may arise in digital environments, and who the child may be interacting with. Staff must also reinforce expectations around safe online behaviour, use of devices, image-sharing, digital communication and reporting online concerns. 

All staff will provide a safe and respectful space for children, including children who are or may be LGBTQ+, to speak out and share concerns. Staff must not promise confidentiality. Instead, they must explain in an age-appropriate and reassuring way that concerns may need to be shared with people who can help keep the child safe. Where a child raises a concern, staff must record it on the safeguarding system the same day and ensure it is passed to the DSL without delay. 

All staff will be aware of the systems that support safeguarding within Elevate Learning Alternative Provision, including: 

• This Child Protection and Safeguarding Policy.  

• The Staff Code of Conduct.  

• The role and identity of the DSL and deputy DSL.  

• The Behaviour Policy.  

• The Online Safety Policy.  

• The safeguarding response to children who are missing or absent from education.  

• The Low-Level Concerns Policy.  

• The Managing Allegations Against Staff Policy.  

• The referral pathway for staff, including early help, statutory referral and escalation routes.  

All staff will understand the early help assessment process and their role within it. This includes: 

• Identifying emerging concerns at the earliest possible stage.  

• Speaking to the DSL about those concerns.  

• Contributing information to help build a full picture of the child’s needs.  

• Supporting the completion or implementation of early help plans where required.  

• Understanding that early help must not delay statutory safeguarding action where risk has escalated.  

All staff will understand the staff referral pathway and the process for making referrals to local authority children’s social care. This includes: 

• knowing that any staff member can make a referral directly if they believe a child is at risk of significant harm.  

• knowing that the DSL should normally coordinate referrals unless urgent direct action is needed.  

• understanding what may happen after a referral, including statutory assessments, strategy discussions, multi-agency involvement and planning.  

• understanding the role they themselves may play in providing records, observations, chronology or ongoing support.  

All staff will know what to do if they identify a safeguarding issue or if a child tells them they are being abused or neglected. This includes understanding: 

• how to listen without leading or investigating.  

• how to record concerns in the child’s own words where possible.  

• how to maintain appropriate confidentiality.  

• how to escalate if they believe action has not been taken.  

• what to do in relation to specific safeguarding issues such as FGM, extremism, child-on-child abuse or nudes/semi-nudes.  

All staff will be aware of the signs and indicators of abuse, neglect and exploitation. This includes, but is not limited to: 

• physical abuse.  

• emotional abuse.  

• sexual abuse.  

• neglect.  

• domestic abuse, including controlling and coercive behaviour.  

• parental conflict that is frequent, intense and unresolved.  

• child-on-child abuse.  

• grooming.  

• child sexual exploitation (CSE).  

• child criminal exploitation (CCE).  

• serious violence and county lines.  

• FGM.  

• radicalisation.  

• online harm and technology-facilitated abuse.  

All staff will also be aware of new and emerging threats, including: 

• online grooming.  

• image-based abuse.  

• sexual exploitation facilitated by social media.  

• criminal exploitation through peer groups or local networks.  

• radicalisation online.  

• misuse of AI, digital manipulation or deepfake imagery.  

• the increasing role of technology in both presenting and concealing harm.  

All staff must understand the importance of reassuring victims that they are being taken seriously and that they will be supported and kept safe. No child should ever be made to feel blamed, minimised or disbelieved. Staff must be especially careful to avoid language or responses that could reinforce shame, fear or self-blame. 

All staff must understand that children can be at risk of harm: 

• inside or outside the home.  

• within family, peer, online and community contexts.  

• at school, in the AP, in transport and in public spaces.  

• through cumulative, overlapping and contextual vulnerabilities.  

All staff must understand that children who are, or who are perceived to be, lesbian, gay, bisexual or gender questioning may be targeted by other children and may face additional barriers to speaking out. Staff must respond with sensitivity, respect and safeguarding awareness. 

All staff must also understand that a child and their family may be experiencing multiple needs at the same time. A presenting issue such as behaviour, attendance, anxiety, dysregulation, family conflict or learning difficulty may sit alongside wider safeguarding need. Staff must therefore maintain professional curiosity and ask themselves not only “what is happening?” but also “what may sit underneath this presentation?” 

Finally, all staff will know what to look for in identifying children who may need help or protection. This includes being alert to: 

• sudden or sustained changes in behaviour.  

• emotional distress or dysregulation.  

• unexplained injuries.  

• poor attendance or missing episodes.  

• deterioration in presentation, communication or engagement.  

• signs of fear, shame or coercion.  

• peer relationship concerns.  

• problematic online behaviour.  

• repeated minor concerns that, when viewed together, suggest a pattern.  

Staff must remember that at Elevate Learning Alternative Provision, because of the profile of pupils supported, safeguarding concerns may not always present in straightforward ways. Behaviour may be communication. Distress may be masked. Disclosure may be partial. Patterns may emerge over time. This makes timely recording, same-day reporting, thoughtful professional curiosity and consistent DSL oversight essential. 

4.3 The Designated Safeguarding Lead (DSL) 

The Designated Safeguarding Lead (DSL) is a member of the provision leadership team and takes lead responsibility for child protection and wider safeguarding across Elevate Learning Alternative Provision. The DSL’s role is central to ensuring that safeguarding systems are effective, responsive and consistently applied in practice. 

At Elevate Learning Alternative Provision, the DSLs are: 

• Claire May (DSL) 

• Rebekah Toro Pérez (Deputy DSL)  

The DSL takes lead responsibility for safeguarding and child protection within the provision. This includes oversight of: 

• child protection referrals.  

• early help decision-making and coordination.  

• safeguarding recording systems and chronologies.  

• online safety.  

• child-on-child abuse.  

• low-level concerns and allegations interface.  

• multi-agency safeguarding liaison.  

• safeguarding support for vulnerable children.  

• the safeguarding implications of attendance, missing episodes, placement instability and AP transitions.  

As a non-school Alternative Provision, Elevate Learning adopts DfE safeguarding guidance, including Keeping Children Safe in Education, as benchmark practice, while also recognising the specific safeguarding realities of Alternative Provision. This includes the need for same-day communication with commissioning schools and/or Local Authorities where significant incidents, immediate risks, attendance concerns or welfare matters arise. The DSL is responsible for ensuring that this communication takes place promptly, appropriately and with a clear written record of information shared, actions agreed and lead professional responsibilities. 

The DSL is also responsible for ensuring that safeguarding practice is appropriately adapted to the context of Elevate Learning’s provision model. This includes recognising that children attending AP may be more vulnerable due to factors such as: 

• disrupted education.  

• emotional regulation difficulties.  

• autism, ADHD or other neurodevelopmental differences.  

• communication needs.  

• risk of exploitation.  

• school avoidance.  

• previous exclusion or placement breakdown.  

• family adversity or instability.  

The DSL must therefore ensure that safeguarding systems are not only compliant, but also responsive to the profile of pupils attending the provision. 

During term time, the DSL will be available during provision hours for staff to discuss safeguarding concerns. Staff must know who the DSL and deputy DSL are, how to contact them, and what to do if they are unavailable. When the DSL is absent, the deputy DSL will act as cover. If both the DSL and deputy DSL are unavailable, a member of the Education Leadership Team / Directors will act as safeguarding cover, including during out-of-hours or out-of-term activity where safeguarding oversight is required. 

The DSL will be given the time, funding, training, authority, professional status, resources and support necessary to carry out the role effectively. This is essential in ensuring that safeguarding leadership is not tokenistic or reactive but embedded and operationally effective. 

The DSL will be expected to: 

• Provide advice and support to staff 

The DSL will be the first point of professional advice for staff regarding child welfare and child protection matters. Staff must feel able to seek advice where they are uncertain about thresholds, how to respond to disclosures, whether a concern requires early help or referral, or how to record and share information safely. 

The DSL must ensure that staff understand that they should never delay reporting concerns, and that uncertainty must not prevent timely action. 

• Lead on referrals and statutory safeguarding processes 

The DSL will make referrals, or support staff in making referrals, to relevant statutory and safeguarding agencies, including: 

• local authority children’s social care.  

• police.  

• Channel / Prevent processes.  

• the Disclosure and Barring Service (DBS).  

• the Local Authority Designated Officer (LADO), where appropriate.  

The DSL is responsible for ensuring that referrals are made promptly where threshold is met, that decision-making is clearly recorded, and that follow-up action takes place where an external agency response is delayed, unclear or inadequate. 

• Contribute to assessments and multi-agency work 

The DSL will take part in strategy discussions, child protection meetings, Team Around the Family meetings, early help processes, child in need planning, professional meetings and any other relevant multi-agency forums. The DSL may also support other staff to contribute to these processes where their direct knowledge of the child is important. 

This includes contributing to the assessment of children and ensuring that the provision’s observations, safeguarding records, attendance concerns, behavioural indicators and contextual concerns are clearly shared with other professionals. 

• Oversee early help and thresholds 

The DSL will lead decision-making around whether concerns are best responded to through: 

• internal pastoral/safeguarding monitoring.  

• early help.  

• referral to children’s social care.  

• immediate statutory safeguarding action.  

The DSL must ensure that early help is used effectively and not as a substitute for child protection referral where there is risk of significant harm. The DSL must keep all cases under review and ensure escalation where concerns are not improving. 

• Maintain safeguarding records 

The DSL is responsible for ensuring that safeguarding records are: 

• factual.  

• timely.  

• complete.  

• secure.  

• accessible to those with a professional need to know.  

This includes oversight of chronologies, referral records, DSL decisions, early help records, attendance-related safeguarding concerns, risk assessments and inter-agency communications. The DSL must ensure that patterns of concern are identified and that repeated “low-level” issues are not missed when viewed cumulatively. 

4.4 The Education Leadership Team / Directors 

The Education Leadership Team / Directors hold overall responsibility for ensuring that safeguarding and child protection arrangements within Elevate Learning Alternative Provision are effective, robust and consistently applied. They provide strategic oversight, challenge and accountability to ensure that safeguarding is embedded across all aspects of the provision. 

The Education Leadership Team / Directors recognise that safeguarding is not a standalone function, but a whole-provision responsibility that must underpin all policies, procedures, decision-making and daily practice. They ensure that safeguarding is central to the culture of Elevate Learning Alternative Provision and that all systems are designed to protect children and promote their welfare. 

The Education Leadership Team / Directors will: 

• Ensure a whole-provision safeguarding approach 

The Education Leadership Team / Directors will ensure that safeguarding and child protection are at the forefront of, and underpin, all relevant aspects of policy development, operational practice and provision delivery. This includes ensuring that safeguarding is reflected consistently across: 

• behaviour systems.  

• pastoral support.  

• curriculum delivery.  

• attendance processes.  

• online safety.  

• staff conduct.  

• recruitment.  

• partnership working.  

They will ensure that safeguarding is not treated as a reactive process, but as a proactive and preventative framework that supports children’s safety, wellbeing and development. 

• Approve, review and monitor safeguarding policy 

The Education Leadership Team / Directors are responsible for: 

• reviewing and approving this Child Protection and Safeguarding Policy annually.  

• ensuring that the policy reflects current legislation, statutory guidance and local safeguarding arrangements.  

• ensuring that the policy is effectively implemented in practice.  

• ensuring that safeguarding procedures are understood and followed by all staff.  

They will hold the Provision Lead and DSL to account for the effectiveness of safeguarding systems and will seek assurance that safeguarding practice is consistent, timely and child centred. 

• Ensure compliance with legal duties 

The Education Leadership Team / Directors will ensure that Elevate Learning Alternative Provision meets its obligations under: 

• the Children Acts 1989 and 2004.  

• Keeping Children Safe in Education (KCSIE).  

• Working Together to Safeguard Children.  

• the Human Rights Act 1998.  

• the Equality Act 2010, including the Public Sector Equality Duty.  

• the Prevent Duty.  

• local safeguarding partner arrangements.  

They will ensure that safeguarding practice reflects these duties and that children’s rights, safety and welfare are prioritised in all decisions. 

• Provide strategic safeguarding oversight 

A named safeguarding lead at board/director level will be appointed to monitor the effectiveness of safeguarding arrangements. This individual will: 

• provide strategic oversight of safeguarding.  

• ensure appropriate challenge and scrutiny.  

• review safeguarding data, trends and patterns.  

• ensure learning from incidents is embedded into practice.  

This role will be separate from the DSL to ensure independent oversight. 

• Ensure effective leadership and resourcing of safeguarding 

The Education Leadership Team / Directors will ensure that: 

• the DSL has sufficient authority, status and seniority to carry out their role effectively.  

• the DSL is provided with adequate time, funding, training, resources and administrative support.  

• there is always appropriate DSL cover available.  

• safeguarding leadership is visible, accessible and effective.  

They will ensure that safeguarding is prioritised within staffing structures, workload expectations and operational planning. 

• Ensure staff training and competence 

The Education Leadership Team / Directors will ensure that all staff: 

• receive safeguarding and child protection training at induction.  

• receive regular updates and refresher training (at least annually).  

• receive training that reflects the specific context of Alternative Provision.  

• understand their roles and responsibilities in safeguarding.  

• understand how to identify, record and report concerns.  

Training will include: 

• online safety and filtering/monitoring awareness.  

• Prevent and radicalisation awareness.  

• child-on-child abuse.  

• low-level concerns.  

• behaviour and safeguarding links.  

• AP-specific safeguarding risks (e.g. exploitation, attendance, vulnerability).  

The Education Leadership Team / Directors will ensure that training is aligned with local safeguarding partner advice and reflects emerging risks and trends. 

• Ensure effective filtering and monitoring systems 

The Education Leadership Team / Directors will ensure that appropriate filtering and monitoring systems are in place to safeguard children online. This includes: 

• ensuring systems are proportionate, effective and regularly reviewed.  

• ensuring staff understand their roles and responsibilities in relation to filtering and monitoring.  

• ensuring safeguarding risks linked to online activity are identified and responded to.  

• reviewing DfE filtering and monitoring standards and working with IT providers to meet them.  

They will ensure that online safety is treated as a core safeguarding priority. 

• Ensure procedures for managing concerns about staff 

The Education Leadership Team / Directors will ensure that there are clear and effective procedures in place to manage: 

• safeguarding concerns about staff.  

• allegations of abuse.  

• low-level concerns.  

• concerns relating to volunteers, contractors or external providers.  

They will ensure that: 

• all concerns are taken seriously and responded to appropriately.  

• there is a clear interface between safeguarding, HR processes and the Managing Allegations Policy.  

• the Local Authority Designated Officer (LADO) is involved where required.  

• commissioners are informed where this is relevant to their safeguarding responsibilities.  

• Ensure safeguarding for vulnerable groups 

The Education Leadership Team / Directors will ensure that this policy reflects the additional vulnerabilities of children with: 

• SEND.  

• neurodevelopmental differences (e.g. autism, ADHD).  

• communication needs.  

• mental health needs.  

• complex family circumstances.  

They will ensure that staff understand that these children may face additional barriers to: 

• recognising abuse.  

• communicating concerns.  

• being believed or understood.  

Safeguarding systems must therefore be adapted to meet these needs and ensure that vulnerability is not overlooked or misinterpreted. 

• Ensure safeguarding in external provision and partnerships 

Where another organisation or individual provides services, activities or facilities on behalf of, or within, Elevate Learning Alternative Provision, the Education Leadership Team / Directors will: 

• seek assurance that appropriate safeguarding policies and procedures are in place.  

• review documentation where necessary.  

• ensure clear communication between organisations regarding safeguarding responsibilities.  

• ensure that safeguarding expectations are a condition of use of premises or partnership working.  

• terminate agreements where safeguarding standards are not met.  

• Ensure appropriate management of allegations against leadership 

The Education Leadership Team / Directors will ensure that: 

• a clear process is in place for managing allegations against the Provision Lead.  

• a director (or equivalent) acts as the case manager in such situations.  

• appropriate external agencies (including the LADO) are involved where required.  

• safeguarding integrity is always maintained.  

• Maintain safeguarding knowledge and oversight 

All members of the Education Leadership Team / Directors will read Keeping Children Safe in Education in full and maintain up-to-date knowledge of safeguarding requirements. 

They will ensure that they: 

• understand their strategic safeguarding responsibilities.  

• can provide effective challenge and support.  

• are confident in interpreting safeguarding information and data.  

• can evaluate the effectiveness of safeguarding systems.  

• Promote a strong safeguarding culture 

The Education Leadership Team / Directors are responsible for ensuring that Elevate Learning Alternative Provision promotes a strong safeguarding culture in which: 

• children feel safe and able to speak.  

• staff feel confident to raise concerns.  

• safeguarding is prioritised over operational convenience.  

• professional curiosity is encouraged.  

• poor practice is challenged.  

• learning from incidents is embedded.  

They will ensure that safeguarding is not seen as a compliance exercise, but as a fundamental responsibility that sits at the heart of the provision. 

5. Definitions 

Safeguarding and promoting the welfare of children means: 

• providing help and support to meet children’s needs as soon as problems emerge.  

• protecting children from maltreatment within or outside the home, including online.  

• preventing impairment of children’s mental and physical health or development.  

• ensuring children grow up in circumstances consistent with safe and effective care.  

• taking action to enable all children to have the best outcomes.  

• Child protection: is part of this definition and refers to activities undertaken to protect specific children who are suspected to be suffering, or likely to suffer, significant harm. This includes harm that occurs inside or outside the home, including online. 

• Abuse is a form of maltreatment of a child and may involve inflicting harm or failing to act to prevent harm. Appendix 1 explains the different types of abuse. 

• Neglect is a form of abuse and is 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. Appendix 1 defines neglect in more detail. 

• Sharing of nudes and semi-nudes (also known as sexting or youth-produced sexual imagery) is where children share nude or semi-nude images, videos or live streams. This also includes pseudo-images that are computer-generated images that otherwise appear to be a photograph or video. 

• Children include everyone under the age of 18.  

• Victim is a widely understood and recognised term, but we understand that not everyone who has been subjected to abuse considers themselves a victim or would want to be described that way. When managing an incident, we will be prepared to use any term that the child involved feels most comfortable with. 

• Alleged perpetrator(s) and perpetrator(s) are widely used and recognised terms. However, we will think carefully about what terminology we use (especially in front of children) as, in some cases, abusive behaviour can be harmful to the perpetrator too. We will decide what’s appropriate and which terms to use on a case-by-case basis.  

The following 3 safeguarding partners are identified in Keeping Children Safe in Education (and defined in the Children Act 2004, as amended by chapter 2 of the Children and Social Work Act 2017). They will make arrangements to work together to safeguard and promote the welfare of local children, including identifying and responding to their needs:   

• The local authority (LA) 

• Integrated care boards) for an area within the LA 

• The chief officer of police in the LA area 

6. Policy Aims and Principles 

6.1 Aims 

Elevate Learning Alternative Provision aims to ensure that all children aged 4–11 are safeguarded effectively through a culture of vigilance, early identification and timely intervention. Safeguarding is embedded across all aspects of provision, recognising that many pupils in Alternative Provision may present with additional vulnerabilities, including social, emotional and mental health needs, trauma, or disrupted educational experiences. 

The aims of this policy are to: 

• ensure that appropriate action is taken promptly and effectively to safeguard and promote the welfare of all children.  

• ensure all staff understand that safeguarding is everyone’s responsibility and are confident in recognising and responding to concerns.  

• provide clear, consistent procedures for identifying, reporting and managing safeguarding concerns, including early help and statutory referrals.  

• ensure that children feel safe, listened to and supported, and that their wishes and feelings are considered.  

• establish a strong safeguarding culture where abuse, neglect and exploitation are never tolerated or minimised.  

• support early identification of need through a graduated response, including early help, pastoral support and multi-agency working.  

• ensure that safeguarding practice reflects the specific context of Alternative Provision, including close communication with commissioning schools and local authorities.  

• protect children from harm both within and outside the provision, including online.  

• ensure all staff receive appropriate training, supervision and support to carry out their safeguarding responsibilities effectively.  

• promote equality, inclusion and anti-discriminatory practice, recognising that some children may face additional barriers to protection.  

Through these aims, Elevate Learning Alternative Provision seeks to ensure that every child can learn, develop and thrive in a safe, supportive and protective environment. 

2.  Equality Statement 

Some children have an increased risk of abuse, both online and offline, and additional barriers may exist to recognising or disclosing it. Elevate Learning is committed to anti-discriminatory practice and recognises children’s diverse circumstances. 

We give special consideration to children who: 

• have SEND or health conditions.  

• are young carers.  

• may experience discrimination due to race, ethnicity, religion, gender identity or sexuality.  

• have English as an additional language.  

• are living in difficult circumstances.  

• are at risk of FGM, sexual exploitation, forced marriage or radicalisation.  

• are asylum seekers.  

• are affected by mental health needs.  

• are looked after or previously looked after.  

• are missing or absent from education.  

Elevate Learning recognises that children with SEND, communication needs, autism, ADHD, emotional regulation needs and learning differences may face additional barriers to recognising harm, reporting concerns, or being understood when they do so. 

7. Confidentiality and Information Sharing 

Confidentiality and data protection within Elevate Learning Alternative Provision are addressed in full within the Data Protection Policy. However, it is essential that all staff understand how confidentiality operates specifically within a safeguarding context. 

Safeguarding practice is underpinned by the principle that the welfare of the child is paramount. While respecting confidentiality is important, it must never prevent appropriate information sharing where this is necessary to protect a child from harm or to promote their welfare. 

All staff must understand that effective safeguarding relies upon timely, proportionate and lawful information sharing. Information sharing enables professionals to build a full picture of a child’s circumstances, identify patterns of concern, and take appropriate action. 

Elevate Learning Alternative Provision operates within a multi-agency safeguarding framework and will share information, where appropriate, with: 

• local authority children’s social care.  

• police.  

• health professionals.  

• safeguarding partners.  

• commissioning schools and/or Local Authorities.  

• other relevant professionals involved in the child’s care.  

As a non-school Alternative Provision, Elevate Learning recognises the importance of maintaining clear and timely communication with commissioners, particularly where safeguarding concerns, attendance risks, or significant incidents arise. Where appropriate, and where it does not place a child at increased risk, significant safeguarding information will be shared with parents/carers and the commissioning school or Local Authority on the same day. 

7.1 Principles of Information Sharing 

All staff must follow these key safeguarding principles: 

• Timely information sharing is essential to effective safeguarding and child protection.  

• Fears about sharing information must not stand in the way of protecting a child or promoting their welfare.  

• The Data Protection Act 2018 and UK GDPR do not prevent the sharing of information for safeguarding purposes.  

• Where necessary, special category personal data can be shared without consent where:  

• it is not possible to obtain consent.  

• it cannot reasonably be expected that consent can be obtained.  

• seeking consent would place a child at risk.  

Staff must understand that safeguarding concerns should always be recorded and shared in line with this policy, even where uncertainty exists about the level of risk. 

7.2 Confidentiality and Children 

Staff must never promise a child that they will keep information secret. If a child discloses abuse, neglect or harm, staff must: 

• listen carefully and respectfully.  

• explain in a clear and age-appropriate way that the information will need to be shared with professionals who can help keep them safe.  

• reassure the child that they will be supported.  

• only share information with those who need to know.  

Staff must be particularly mindful that children attending Elevate Learning Alternative Provision may: 

• have experienced breaches of trust.  

• be reluctant to disclose.  

• fear consequences of sharing information.  

• communicate in indirect or non-verbal ways.  

This requires staff to approach confidentiality with sensitivity, clarity and honesty. 

7.3 Requests Not to Share Information 

If a child asks that information is not shared, particularly in cases involving sexual violence or sexual harassment, there is no single definitive response. The Designated Safeguarding Lead (DSL) will make a professional judgement, balancing the child’s wishes with the duty to protect them and others. 

In making this decision, the DSL will consider: 

• the level of risk to the child.  

• whether other children may be at risk.  

• the nature and seriousness of the concern.  

• the child’s age, capacity and understanding.  

• whether parents/carers can be informed safely.  

• whether the matter constitutes a criminal offence.  

The DSL will apply the following safeguarding principles: 

• If a child is at risk of harm, has been harmed, or is in immediate danger, a referral must be made to local authority children’s social care.  

• Where offences such as rape, assault by penetration or sexual assault are disclosed, the matter must be referred to the police.  

• Even where a child does not consent to information sharing, staff may lawfully share information if there is a legal safeguarding basis to do so.  

All decisions must be clearly recorded, including the rationale for sharing or not sharing information. 

7.4 Anonymity and Protection of Identity 

Staff must take all reasonable steps to protect the identity and dignity of children involved in safeguarding concerns, particularly in cases involving sexual violence or sexual harassment. 

This includes: 

• carefully limiting who is informed of the concern.  

• avoiding unnecessary sharing of identifying information.  

• ensuring discussions take place in private and appropriate settings.  

• being aware of how information may spread through peer groups or social media.  

Staff must also be aware of: 

• anonymity considerations within the criminal justice process.  

• the potential impact of rumours or online exposure.  

• the need to actively protect victims from further harm or distress.  

7.5 Professional Judgement and Support 

All staff must be aware that safeguarding decisions often require professional judgement. Where staff are unsure about whether or how to share information, they must: 

• speak to the DSL or deputy DSL without delay.  

• seek advice rather than delay action.  

• ensure that concerns are recorded even where advice is sought.  

Staff must also be aware of the government’s “7 Golden Rules for Information Sharing” and apply these where relevant. 

Confidentiality is also addressed in relation to: 

• safeguarding record-keeping.  

• information transfer between settings.  

• allegations against staff.  

• multi-agency working.  

8. One-to-One Situations (Being Alone with a Child) 

Elevate Learning Alternative Provision recognises that, due to the nature of Alternative Provision, staff may at times be required to work on a one-to-one basis with children. This may be necessary to support: 

• emotional regulation.  

• pastoral intervention.  

• SEND or communication needs.  

• therapeutic or structured support.  

• reintegration planning.  

• de-escalation or recovery following distress.  

While one-to-one working can be appropriate and beneficial, it also presents potential risks for both children and staff. It is therefore essential that all such interactions are conducted safely, transparently and in line with safeguarding expectations. 

8.1 Principles of Safe One-to-One Working 

Staff must always aim to: 

• prioritise the safety and wellbeing of the child.  

• maintain professional boundaries.  

• ensure transparency and accountability.  

• reduce the risk of misinterpretation or allegation.  

• ensure that no situation places a child or staff member at avoidable risk.  

Where possible, staff should avoid being alone with a child. However, where this is not possible or appropriate, safeguards must be in place. 

8.2 Expectations for One-to-One Contact 

Where one-to-one contact is necessary, staff must: 

• use rooms that allow visibility (e.g. glass panels, open doors, or observable spaces).  

• ensure that another member of staff is aware of:  

• where the meeting is taking place.  

• the purpose of the meeting.  

• its expected duration.  

• keep the interaction proportionate, time-limited and focused on the child’s needs.  

• use language and behaviour that is professional, appropriate and supportive.  

• avoid any physical contact unless it is appropriate, necessary and in line with policy (e.g. in regulated support contexts).  

Where one-to-one work forms part of an ongoing support plan (for example, pastoral support, SEND provision or therapeutic intervention), parents/carers will be informed and, where appropriate, this will be documented within the child’s support plan. 

8.3 Recording and Accountability 

Where one-to-one interactions fall outside normal classroom practice, staff must ensure that a record is made. This should include: 

• the date and time of the session.  

• the reason for the session.  

• the location.  

• any significant observations or outcomes.  

This supports transparency, safeguarding oversight and continuity of care. 

8.4 Prohibited Practice 

Staff must never: 

• arrange to meet a child alone off-site.  

• arrange to meet a child outside of provision hours.  

• communicate with a child through personal or unapproved channels.  

• create situations where they are isolated with a child without visibility or awareness of others.  

Any such behaviour would be considered a serious breach of safeguarding expectations. 

8.5 Responding to Concerns 

If a staff member feels uncomfortable about any one-to-one situation, or if a child’s behaviour or the circumstances of the interaction raise concern, they must: 

• report this immediately to the DSL.  

• record the concern factually.  

• seek guidance and support.  

This includes situations where: 

• boundaries feel unclear.  

• behaviour is misinterpreted or could be misinterpreted.  

• the child presents in a way that raises safeguarding concern.  

• the staff member feels at risk.  

 Context of Alternative Provision 

Elevate Learning recognises that, within Alternative Provision, one-to-one working may be more frequent due to: 

• individualised support needs.  

• regulation and behaviour support.  

• smaller group sizes.  

• flexible provision models.  

For this reason, it is especially important that one-to-one practice is: 

• planned where possible.  

• transparent.  

• recorded.  

• aligned with safeguarding and behaviour policies.  

• overseen by leadership and the DSL.  

9. Recognising Abuse, Harm and Safeguarding Need 

Elevate Learning Alternative Provision recognises that all staff play a critical role in identifying children who may need help, protection or intervention. Staff are often best placed to notice changes in a child’s presentation, behaviour, attendance, communication, relationships or emotional wellbeing that may indicate a safeguarding concern. 

All staff must maintain an attitude of professional curiosity and understand that abuse, neglect and exploitation do not always present in direct or obvious ways. Children may not tell adults clearly or immediately that something is wrong. Concerns may instead emerge through patterns over time, changes in behaviour, dysregulation, emotional distress, withdrawal, attendance concerns, online behaviour, indirect comments or other indicators. 

This is particularly important within an Alternative Provision context, where children may have: 

• experienced trauma or adverse childhood experiences.  

• unmet SEND, social communication or sensory needs.  

• emotional regulation difficulties.  

• disrupted education or placement instability.  

• previous negative experiences of professionals.  

• family instability, social care involvement or wider contextual vulnerabilities.  

Staff must therefore understand that behaviour may be a form of communication and that safeguarding concerns may sit beneath presenting behaviours. This means that behaviour should not be viewed in isolation or explained away without careful consideration of what may be causing or contributing to it. 

9.1 Recognising Need, Vulnerability and Risk 

All staff must be able to identify children who: 

• are suffering or likely to suffer significant harm.  

• may require statutory safeguarding intervention.  

• may benefit from early help.  

• are experiencing emerging needs that require monitoring, support or multi-agency involvement.  

Staff should be particularly alert to children who: 

• have SEND or disabilities.  

• are neurodivergent, including autism or ADHD.  

• are young carers.  

• are bereaved.  

• are persistently absent or missing from education.  

• are at risk of exclusion or have experienced multiple suspensions.  

• are at risk of exploitation, including CSE, CCE, serious violence or county lines.  

• are affected by domestic abuse, parental conflict, adult mental ill health or substance misuse.  

• are misusing substances themselves.  

• are experiencing mental health difficulties.  

• are at risk of radicalisation.  

• are viewing harmful or inappropriate online content.  

• are in unstable or unsafe living situations.  

• have returned home from care.  

• are at risk of FGM, forced marriage or honour-based abuse.  

• have a parent in custody.  

Staff must understand that safeguarding concerns may be cumulative and that several low-level concerns, taken together, may indicate significant vulnerability or escalating risk. 

9.2 Specific Safeguarding Issues 

Staff must be aware of a wide range of specific safeguarding issues and understand that these may affect children individually or in combination. These include, but are not limited to: 

• child-on-child abuse.  

• child sexual exploitation (CSE).  

• child criminal exploitation (CCE).  

• serious violence and county lines.  

• grooming.  

• domestic abuse.  

• coercive and controlling behaviour.  

• sexual violence and sexual harassment.  

• female genital mutilation (FGM).  

• forced marriage.  

• radicalisation and extremism.  

• online harm and exploitation.  

Staff must also remain alert to new and emerging risks, particularly those facilitated through technology, social media and online contact. 

9.3 Recognising Concerns Related to Extremism and Radicalisation 

Elevate Learning Alternative Provision recognises its duty under the Prevent Duty to have due regard to the need to prevent children from being drawn into terrorism. Safeguarding children from radicalisation forms part of the provision’s wider safeguarding responsibilities and must be approached in the same way as other forms of harm and vulnerability. 

Radicalisation refers to the process by which an individual comes to support terrorism or extremist ideologies. This may arise through online exposure, peer influence, family dynamics or wider community factors. Children attending Alternative Provision may be particularly vulnerable where they experience social isolation, unmet need, identity-related difficulties, exclusion, emotional vulnerability or reduced connection to protective adults and environments. 

All staff must remain alert to signs that a child may be at risk of radicalisation. These may include: 

• changes in behaviour, language or attitudes.  

• expression of extremist views or narratives.  

• fixation on particular ideologies, grievances or causes.  

• withdrawal from established peer groups.  

• increased secrecy around online activity.  

• accessing extremist material online.  

• justification of violence or harm to others.  

Staff must not attempt to investigate, debate or challenge extremist views directly. Their responsibility is to recognise the concern, record it and report it in line with safeguarding procedures. 

9.4 Recognising Mental Health Concerns in a Safeguarding Context 

Elevate Learning Alternative Provision recognises that mental health and safeguarding are closely linked. In some cases, mental health difficulties may indicate that a child has experienced, or is at risk of experiencing, abuse, neglect, exploitation or other forms of harm. 

Staff must understand that mental health concerns should never automatically be viewed in isolation. Instead, they must consider whether there are underlying safeguarding factors contributing to the child’s presentation. 

Children attending Alternative Provision may be more likely to experience: 

• emotional dysregulation.  

• anxiety or school avoidance.  

• trauma-related responses.  

• low self-esteem or identity-based distress.  

• behavioural distress.  

• social communication differences.  

These presentations may mask or overlap with safeguarding concerns. 

Staff must be alert to indicators that a child may be experiencing mental health difficulties, including: 

• changes in behaviour, mood or engagement.  

• withdrawal, isolation or shutdown.  

• aggression or increased dysregulation.  

• persistent absence or avoidance.  

• expressions of hopelessness, distress or low mood.  

• self-harm or risk-taking behaviour.  

• changes in presentation, hygiene or communication.  

Because of the nature of Alternative Provision, staff must avoid normalising distress or high-risk behaviours simply because a child has SEMH needs or a history of dysregulation. Staff must remain curious, reflective and safeguarding-informed. 

9.5 Professional Curiosity 

All staff must: 

• remain professionally curious.  

• question patterns, changes and inconsistencies.  

• follow up concerns.  

• avoid making assumptions.  

• consider whether presenting behaviour, distress or need may indicate wider harm.  

Professional curiosity is especially important in Alternative Provision, where children may communicate through behaviour and where multiple vulnerabilities may overlap. Staff must understand that curiosity is not investigation; it is the professional responsibility to notice, reflect, record and report. 

10. Safeguarding Procedures and Reporting Pathways 

Elevate Learning Alternative Provision has clear safeguarding procedures to ensure that concerns are identified, reported, recorded, assessed and acted upon in a timely and effective way. All staff must know what to do when they have a concern, when a child makes a disclosure, or when there is immediate risk. 

The overriding principle is that no concern is too small to report if it relates to the safety or welfare of a child. 

10.1 Immediate Risk of Harm or Significant Harm 

If a child is suffering or likely to suffer significant harm, or is in immediate danger, staff must: 

1. take immediate action to protect the child.  

2. contact emergency services (999) and/or Children’s Social Care without delay.  

3. inform the DSL as soon as possible.  

4. record the concern and the action taken on the same day.  

All staff must understand that anyone can make a referral to Children’s Social Care if they believe a child is at risk. 

If a referral is made directly, the DSL must be informed as soon as possible afterwards. 

10.2 If a Child Makes a Disclosure 

If a child discloses abuse, neglect or harm, staff must respond calmly, supportively and professionally. 

Staff must: 

• listen carefully and take the child seriously.  

• allow the child to speak freely.  

• avoid interrupting or asking leading questions.  

• remain calm and not show shock or disbelief.  

• reassure the child that they have done the right thing.  

• explain what will happen next.  

• not promise confidentiality.  

• record the disclosure in the child’s own words as soon as possible.  

• sign and date the record.  

• pass the information to the DSL immediately.  

• record the concern on the safeguarding system the same day.  

Staff must not: 

• investigate the concern.  

• ask the child to repeat their account unnecessarily.  

• share the information with others who do not need to know.  

Staff must be aware that some children may: 

• not recognise that they are being abused.  

• feel ashamed, embarrassed or fearful.  

• struggle to communicate due to SEND, trauma or communication needs.  

• disclose gradually or indirectly.  

These factors must never prevent staff from acting. 

10.3 Early Help, Support and Thresholds 

Not all concerns will meet the threshold for statutory child protection intervention. However, children may still require support through early help, pastoral intervention, family support or multi-agency planning. 

Where concerns do not indicate immediate risk of significant harm, staff must still: 

• record the concern factually.  

• report it to the DSL without delay.  

• support the DSL in gathering information if required.  

The DSL will decide whether the appropriate course of action is: 

• internal monitoring and support.  

• early help intervention.  

• referral to Children’s Social Care.  

• referral to other agencies.  

Staff must understand that early help must never delay referral where significant harm is suspected. 

10.4 Reporting Concerns About Extremism and Radicalisation 

If a member of staff has concerns about extremism or radicalisation, they must: 

• report the concern to the DSL immediately.  

• record the concern factually on the safeguarding system the same day.  

• not delay reporting while seeking more evidence or clarification.  

Where possible, the DSL should be consulted before any external referral is made. 

If the DSL or deputy DSL is unavailable, staff must not delay action. They must: 

• speak to a member of the Education Leadership Team; and/or  

• seek advice from local authority Children’s Social Care.  

• make a referral directly where appropriate.  

The DSL must be informed as soon as possible following any action taken. 

The DSL will assess the level of risk and determine the most appropriate course of action. This may include: 

• internal safeguarding monitoring and support.  

• early help intervention.  

• referral to Channel.  

• referral to Children’s Social Care.  

• referral to the police where there is a risk of criminal activity.  

The DSL will ensure that all decisions are clearly recorded, including the rationale. 

For non-emergency advice, staff and DSLs may use: 

• DfE Prevent Helpline: 020 7340 7264  

• Email: counter.extremism@education.gov.uk  

In an emergency, staff must: 

• call 999; or  

• contact the Anti-Terrorism Hotline: 0800 789 321.  

As a non-school AP, Elevate Learning will share significant Prevent-related concerns with the commissioning school/LA on the same day where appropriate and will ensure that such concerns are managed within the wider safeguarding framework. 

10.5 Reporting Mental Health Concerns Where Safeguarding May Be Present 

If a staff member has a concern about a child’s mental health, they must: 

• record the concern factually.  

• report it to the DSL.  

• consider whether there may also be safeguarding concerns.  

Where the mental health concern is linked to abuse, neglect, exploitation or risk of harm, staff must: 

• follow safeguarding procedures immediately.  

• treat the matter as a safeguarding concern.  

• ensure urgent action is taken where risk is identified.  

Where the concern relates to mental health without immediate safeguarding risk, staff must still inform the DSL. The DSL will decide what support is needed, which may include: 

• pastoral support.  

• early help intervention.  

• referral to CAMHS or other external services.  

• internal support planning.  

The DSL will ensure that the child’s needs are monitored, reviewed and escalated if risk increases. 

10.6 Female Genital Mutilation (FGM) 

FGM is illegal and is a form of child abuse with serious and lifelong consequences. 

Any teacher who: 

• is informed by a girl under 18 that FGM has been carried out; or  

• observes physical signs indicating FGM  

must personally report this to the police immediately. 

They must also inform the DSL unless advised otherwise by police. 

All other staff must report concerns about FGM risk or suspected FGM to the DSL immediately. 

Staff must never examine a child. 

10.7 Escalation and Follow-Up 

Safeguarding concerns do not end once they have been reported. Staff and DSLs must ensure that concerns are followed through and not allowed to drift. 

If staff believe that a concern has not been responded to appropriately, they must escalate this to: 

• the DSL.  

• the Provision Lead.  

• the relevant external agency, where appropriate.  

The DSL must ensure that: 

• referrals are followed up.  

• outcomes are recorded.  

• escalation procedures are used where a response is inadequate or delayed.  

10.8 AP Context and Communication with Commissioners 

As a non-school Alternative Provision, Elevate Learning operates within a shared safeguarding framework with commissioning schools and Local Authorities. 

The provision will: 

• share significant safeguarding concerns with the commissioning school/LA the same day.  

• ensure clarity around who is leading on safeguarding actions.  

• work collaboratively with social care, police, health and other professionals.  

• ensure that the child’s safety, welfare and educational outcomes always remain central.  

Because AP placements may involve multiple professionals, settings and transitions, clear reporting pathways and communication are essential to ensure that no safeguarding concern is missed or delayed. 

11. Concerns About Staff, Supply Staff, Volunteers and Contractors 

Elevate Learning Alternative Provision recognises that safeguarding concerns may arise in relation to adults working with children. It is essential that all such concerns are responded to promptly, appropriately and in line with statutory guidance. 

This includes concerns or allegations about: 

• employees.  

• agency or supply staff.  

• volunteers.  

• contractors.  

• visitors.  

• anyone working on behalf of the provision.  

Elevate Learning maintains a culture of openness, transparency and accountability, where concerns about adults can be raised safely and without fear of reprisal. Safeguarding children requires that all adults are held to the highest standards of professional conduct. 

11.1 Types of Concerns 

Concerns about staff may fall into two categories: 

1. Allegations that meet the harm threshold 

These are concerns that suggest a member of staff has: 

• behaved in a way that has harmed a child or may have harmed a child.  

• possibly committed a criminal offence against or related to a child.  

• behaved towards a child in a way that indicates they may pose a risk of harm.  

• behaved in a way that indicates they may not be suitable to work with children.  

These concerns must be treated as formal allegations and managed in line with statutory procedures. 

2. Low-Level Concerns 

Low-level concerns relate to behaviour that: 

• does not meet the harm threshold.  

• may be inconsistent with the staff code of conduct.  

• may indicate emerging patterns of concern.  

Examples may include: 

• boundary issues.  

• inappropriate language or tone.  

• favouritism.  

• being alone with a child without appropriate safeguards.  

Low-level concerns must still be recorded, reviewed and addressed to ensure early intervention and prevent escalation. 

(see low-level concerns policy) 

11.2 Procedures for Dealing with Concerns about Staff, Supply Staff, Volunteers and Contractors 

Staff Responsibility to Report Concerns 

All staff have a professional and statutory responsibility to: 

• report concerns about adults immediately.  

• not assume that someone else will act.  

• not attempt to investigate the concern themselves.  

• record concerns factually and promptly.  

If a member of staff has any concern about another adult, they must: 

• report it to the DSL/Deputy DSL immediately.  

If the concern relates to the DSL/Deputy DSL, it must be reported to: 

• a member of the Education Leadership Team / Directors.  

If there is a concern about how a report is being handled, or a conflict of interest, staff must: 

• report directly to the Local Authority Designated Officer (LADO).  

Staff must understand that whistleblowing protections apply, and that failure to report concerns may place children at risk. 

 Immediate Action and Safeguarding First 

Where a child may be at risk of harm: 

• safeguarding action must take priority over all other processes.  

• Children’s Social Care and/or the police must be contacted immediately where required.  

• the child’s safety must be secured without delay.  

Role of the Case Manager 

The DSL or Deputy DSL or Provision Lead will act as the case manager for allegations against staff (unless the allegation is about them). 

They will: 

• ensure that appropriate action is taken immediately.  

• contact the Local Authority Designated Officer (LADO) for advice.  

• follow all statutory procedures.  

• ensure that safeguarding remains the priority throughout.  

• maintain confidentiality and accurate records.  

• liaise with external agencies as required.  

Where the allegation concerns the Provision Lead, a director will take on this role. 

Role of the Local Authority Designated Officer (LADO) 

The LADO provides advice and oversight for allegations that meet the harm threshold. 

The Provision Lead (or Director) must: 

• contact the LADO as soon as possible.  

• follow the LADO’s guidance on next steps.  

• not investigate internally before seeking advice.  

The LADO will advise on: 

• whether the allegation meets threshold.  

• whether a strategy meeting is required.  

• whether police or Children’s Social Care involvement is necessary.  

• how the case should be managed.  

11.3 Managing Allegations 

Where an allegation meets the harm threshold: 

• the matter will be managed in line with statutory safeguarding procedures.  

• appropriate agencies will be involved.  

• the member of staff may be suspended where necessary (in line with HR procedures).  

• the child will be safeguarded and supported throughout.  

Elevate Learning will ensure that: 

• investigations are fair, proportionate and timely.  

• confidentiality is maintained.  

• information is shared appropriately.  

• records are accurate and securely stored.  

Managing Low-Level Concerns 

Low-level concerns will be managed in line with the Low-Level Concerns Policy. 

The Provision Lead will: 

• record all concerns.  

• review patterns or repeated behaviours.  

• take appropriate action, which may include:  

• guidance or training.  

• supervision or monitoring.  

• formal management action where required.  

Low-level concerns are essential in identifying emerging risk and maintaining a strong safeguarding culture. 

11.4 Safeguarding Culture and Professional Standards 

Elevate Learning Alternative Provision promotes a culture in which: 

• all concerns are taken seriously, regardless of perceived severity.  

• staff feel confident to report concerns.  

• professional boundaries are clearly understood.  

• poor practice is challenged.  

• safeguarding is prioritised over reputation or convenience.  

Staff must understand that: 

• it is better to report a concern that proves unfounded than to fail to report a concern that could protect a child.  

• patterns of behaviour are significant.  

• safeguarding is a collective responsibility.  

 Record Keeping 

All concerns, allegations and decisions must be: 

• recorded clearly and factually.  

• stored securely.  

• retained in line with safeguarding and data protection requirements.  

Records must include: 

• details of the concern.  

• actions taken.  

• decisions made and rationale.  

• outcomes.  

Alternative Provision Context 

As a non-school Alternative Provision, Elevate Learning will: 

• share relevant safeguarding information with the commissioning school/LA where appropriate.  

• ensure clear communication regarding safeguarding responsibilities.  

• work collaboratively with external agencies.  

• ensure that safeguarding concerns involving staff are managed transparently and in line with statutory expectations. 

12. Child-on-Child Abuse 

12.1 Allegations of Abuse Made Against Other Pupils 

Elevate Learning Alternative Provision recognises that children are capable of abusing their peers. This is referred to as child-on-child abuse and can take many forms, including physical, emotional and sexual abuse, as well as exploitation and harmful online behaviours. 

Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”, as such attitudes can lead to a culture of unsafe and unacceptable behaviour and may prevent children from reporting concerns. 

We recognise the gendered nature of some forms of child-on-child abuse, particularly sexual violence and harassment. However, all forms of child-on-child abuse are unacceptable and will be taken seriously, regardless of gender, background or context. 

In an Alternative Provision context, we recognise that pupils may present with: 

• increased vulnerability.  

• social, emotional and mental health needs.  

• previous trauma or adverse experiences.  

• behaviours that may mask underlying safeguarding concerns.  

As such, all incidents will be considered within a trauma-informed and safeguarding-led framework. 

Most incidents of pupils hurting other pupils will be managed through the Behaviour Policy. However, this safeguarding policy will apply where concerns meet safeguarding thresholds. This includes behaviour that: 

• is serious and potentially a criminal offence.  

• is violent or coercive in nature.  

• could place pupils at risk of harm.  

• involves the misuse of drugs or alcohol.  

• involves sexual violence, sexual harassment or exploitation.  

• includes the sharing of nudes or semi-nudes.  

• indicates a pattern of harmful or concerning behaviour.  

Staff must always consider whether the behaviour is indicative of wider safeguarding concerns, including whether the child displaying harmful behaviour may themselves be at risk of abuse. 

12.2 Procedures for Dealing with Allegations of Child-on-Child Abuse 

If a pupil makes an allegation of abuse against another pupil, or staff observe or suspect such behaviour, the following procedures must be followed. 

Staff must: 

• record the allegation immediately, using the child’s own words where possible.  

• report the concern to the DSL without delay.  

• not investigate, interview or attempt to resolve the situation themselves.  

• reassure the child that they have been heard and will be supported.  

The DSL will take lead responsibility for managing the concern and will: 

• assess the nature, seriousness and context of the allegation.  

• determine whether the threshold for referral to Children’s Social Care and/or the police has been met.  

• seek advice from safeguarding partners where appropriate.  

• ensure all actions and decisions are clearly recorded.  

Where the allegation involves potential criminal behaviour, the DSL will liaise with the police and follow their guidance. 

As Elevate Learning operates as a non-school Alternative Provision, behavioural consequences within sessions will be applied in line with the Behaviour Policy. Where statutory decisions (such as suspension or exclusion) are required, these will be managed by the commissioning school or Local Authority. 

 Risk Assessment and Support Planning 

Following any allegation, the DSL will ensure that a comprehensive and dynamic risk assessment is undertaken. 

This will include consideration of: 

• the safety and wellbeing of the victim.  

• the risk posed by the alleged perpetrator.  

• the needs and vulnerabilities of all pupils involved.  

• contextual safeguarding factors, including peer dynamics, transport and online contact.  

A support and safety plan will be implemented for: 

• the victim(s).  

• the alleged perpetrator(s).  

• any other pupils affected.  

This will include: 

• a named trusted adult.  

• supervision and environmental adjustments.  

• separation or restricted contact where required.  

• access to pastoral or therapeutic support.  

• referral to external services, including CAMHS, where appropriate.  

The DSL will also ensure that transport arrangements are considered, recognising this as a potential area of increased vulnerability in Alternative Provision. 

 Multi-Agency Working and Ongoing Management 

Where required, the DSL will: 

• contact Children’s Social Care and follow their advice.  

• liaise with the police.  

• work with health professionals and other agencies.  

• inform the commissioning school/LA on the same day where there is significant risk.  

If there are delays in the criminal justice process, the DSL will continue to: 

• implement safeguarding measures.  

• review risk assessments regularly.  

• maintain communication with external agencies.  

• ensure all children remain safe.  

Disciplinary action may be taken where appropriate and proportionate. Decisions will be made on a case-by-case basis, considering: 

• whether action may prejudice an investigation.  

• the safety of all pupils.  

• the need to maintain a safe environment.  

Safeguarding will always take priority over disciplinary processes. 

12.3 Creating a Supportive Environment and Minimising Risk 

Elevate Learning Alternative Provision recognises that preventing child-on-child abuse requires a whole-provision approach, underpinned by strong safeguarding culture and consistent adult practice. 

We are committed to creating an environment where: 

• pupils feel safe, respected and listened to.  

• harmful behaviour is challenged consistently.  

• pupils feel confident to report concerns.  

• safeguarding is embedded in everyday practice.  

To achieve this, we will: 

• challenge all forms of derogatory, sexualised or inappropriate language and behaviour.  

• be vigilant to behaviours that may disproportionately affect certain groups, including gender-based harm.  

• deliver a curriculum that supports understanding of:  

• consent and boundaries.  

• respectful relationships.  

• online safety.  

• recognising and reporting abuse.  

• ensure reporting systems are accessible, well-promoted and understood.  

• reassure pupils that they will be taken seriously and supported.  

• identify and respond to environmental or systemic safeguarding concerns.  

• support victims, alleged perpetrators and witnesses appropriately.  

Staff will be trained to understand: 

• how to recognise indicators of child-on-child abuse.  

• that abuse may occur even without direct disclosure.  

• that pupils may communicate concerns through behaviour.  

• that some pupils face additional barriers to reporting.  

• that children who harm others may themselves be vulnerable.  

• the importance of immediate action and reporting to the DSL.  

Staff must maintain a mindset that “it could happen here” and act with professional curiosity at all times. 

12.4 Sharing of Nudes and Semi-Nudes (‘Sexting’ / Youth-Produced Sexual Imagery) 

Elevate Learning Alternative Provision recognises that the sharing of nudes and semi-nudes (also referred to as ‘sexting’ or youth-produced sexual imagery) is a complex safeguarding issue that can place children at significant risk of harm. 

Incidents may involve: 

• consensual sharing between peers.  

• non-consensual sharing (e.g. image redistribution).  

• coercion, exploitation or grooming.  

• peer pressure or manipulation.  

• online abuse or harassment.  

• criminal behaviour.  

We recognise that in many cases, children may not fully understand: 

• the risks and consequences of sharing images.  

• issues of consent.  

• the permanence and reach of online content.  

• the legal implications.  

At Elevate Learning Alternative Provision, all incidents are managed using a child-centred, trauma-informed and non-judgemental approach, ensuring that: 

• children are safeguarded first and foremost.  

• they are not criminalised unnecessarily.  

• they are supported to understand risk and make safer choices.  

• any response is proportionate, appropriate and informed by safeguarding thresholds.  

12.5 Procedures for Dealing with sharing of nudes/semi- Nudes  

Staff Responsibilities When Responding to an Incident 

If a member of staff becomes aware of an incident involving the sharing of nude or semi-nude images, they must respond immediately and appropriately. 

Staff must: 

• treat the incident as a safeguarding concern.  

• report the incident to the DSL without delay.  

• listen calmly and reassure the pupil that they will be supported.  

• explain clearly that the information cannot be kept confidential and must be shared to keep them safe.  

• record the concern factually, using the child’s own words where possible.  

Staff must understand that their role is to recognise, respond, record and report, not to investigate. 

Staff must not: 

• view, copy, print, share or store the imagery.  

• ask a pupil to show, send or download the image.  

• delete the imagery or instruct the pupil to do so.  

• question pupils in detail or conduct an investigation.  

• share information with others unnecessarily.  

• use language or behaviour that could be perceived as blaming or shaming.  

If a member of staff has already viewed the imagery unintentionally, this must be reported to the DSL immediately and recorded. 

 Initial Review by the DSL 

Following a report, the DSL will take immediate responsibility for managing the incident. 

The DSL will convene an initial review, which may involve appropriate members of staff, to establish the facts and assess risk. This stage is critical in determining the appropriate safeguarding response. 

The initial review will consider: 

• whether there is an immediate risk of harm to any child.  

• whether the incident involves consensual or non-consensual sharing.  

• whether there is any indication of coercion, exploitation, grooming or abuse.  

• the age, vulnerability and capacity of the children involved.  

• whether the imagery has been shared more widely and via which platforms.  

• whether it is necessary to view the imagery to safeguard the child (this should be avoided unless essential and only carried out by the DSL).  

• what immediate actions are required to safeguard those involved.  

• whether parents/carers should be informed.  

• whether external agencies need to be involved.  

The DSL will ensure that all decisions are clearly recorded, including the rationale for actions taken. 

Referral to External Agencies 

The DSL will make an immediate referral to Children’s Social Care and/or the police where there are concerns that the incident involves significant harm or criminal behaviour. 

This includes where: 

• an adult is involved in the incident.  

• there is evidence of coercion, grooming, exploitation or blackmail.  

• a pupil lacks the capacity to consent (including due to SEND or vulnerability).  

• the imagery is extreme, violent or developmentally inappropriate.  

• a child under the age of 13 is involved.  

• there is reason to believe a child is at immediate risk of harm, including emotional distress, self-harm or suicidal ideation.  

The DSL will liaise with relevant agencies and follow their advice, ensuring that safeguarding remains the priority. 

Managing Incidents Internally 

Where the threshold for external referral is not met, the DSL may decide to manage the incident internally. This decision will always be: 

• proportionate.  

• risk informed.  

• clearly recorded.  

In these cases, the DSL will: 

• undertake a full risk assessment.  

• establish the facts through appropriate conversations with pupils.  

• consider the wider context, including peer relationships and online activity.  

• ensure that all children involved are safeguarded and supported.  

Further Review and Ongoing Management 

The DSL will lead on all ongoing management of the case. 

This will include: 

• regular review of risk and support needs.  

• ongoing communication with pupils and staff.  

• liaison with parents/carers, unless doing so would place the child at increased risk.  

• monitoring of any ongoing online risk.  

• ensuring appropriate boundaries and safety measures are in place within the provision.  

If at any stage the level of risk increases, the DSL will make an immediate referral to Children’s Social Care and/or the police. 

All actions, decisions and outcomes will be fully documented in line with safeguarding record-keeping requirements. 

Supporting Pupils 

Elevate Learning Alternative Provision will ensure that all pupils involved receive appropriate support. 

This includes: 

• emotional and pastoral support for the victim.  

• appropriate intervention and support for the child who shared the image.  

• consideration of any underlying safeguarding concerns.  

• access to external services where required (e.g. CAMHS).  

Support will be provided in a way that is: 

• non-judgemental.  

• proportionate.  

• focused on education and safeguarding.  

• responsive to individual needs.  

12.6 Education and Prevention (Age-Appropriate Approach: 4–11 Provision) 

Elevate Learning Alternative Provision recognises that education is a key protective factor in preventing harm related to the sharing of nudes and semi-nudes. As a provision supporting children aged 4–11, all teaching and preventative work is carefully adapted to be developmentally appropriate, sensitive and safeguarding-led. 

We do not deliver explicit content relating to sexual imagery. Instead, our approach focuses on building the foundations of safe behaviour, boundaries, and help-seeking, ensuring that pupils are equipped with the knowledge and confidence to stay safe both offline and online. 

Our curriculum is differentiated across age and stage, recognising that children’s understanding, language and experiences vary significantly between early years and upper Key Stage 2. 

Early Years and Key Stage 1 (Ages 4–7) 

For younger pupils, education focuses on: 

• understanding personal boundaries and “private” vs “public”.  

• recognising safe and unsafe situations.  

• identifying trusted adults.  

• understanding that they should not share pictures of their bodies.  

• developing confidence to say no and seek help.  

• learning basic online safety, including not sharing personal information or images.  

Teaching is delivered through: 

• stories, play-based learning and discussion.  

• consistent adult modelling.  

• simple, clear and reassuring messages.  

• repetition and reinforcement.  

The emphasis at this stage is on safety, trust and communication, rather than detailed explanations. 

Key Stage 2 (Ages 7–11) 

For older pupils, teaching is gradually developed to include: 

• understanding online risks, including pressure to share images.  

• recognising peer pressure, manipulation and coercion.  

• developing awareness of digital permanence and consequences.  

• understanding privacy, consent and respect in an age-appropriate way.  

• knowing what to do if they are asked to send or receive an image.  

• understanding that they should never share images of themselves or others.  

• how to report concerns and seek help confidently.  

Pupils are supported to: 

• recognise unsafe situations.  

• challenge harmful behaviour.  

• develop resilience and decision-making skills.  

• understand that they will not be in trouble for reporting concerns.  

Teaching Principles 

All education delivered at Elevate Learning Alternative Provision will: 

• be age-appropriate, inclusive and differentiated.  

• prioritise safeguarding and emotional wellbeing.  

• be delivered in a trauma-informed and sensitive manner.  

• avoid explicit or inappropriate content.  

• promote open discussion, trust and understanding.  

• reinforce that pupils can always speak to a trusted adult.  

We recognise that pupils in Alternative Provision may have: 

• varied developmental levels.  

• additional needs (including SEND).  

• previous exposure to risk or trauma.  

Teaching will therefore be adapted to individual need, not just chronological age. 

13. Online Safety and the Mobile Technology 

Elevate Learning Alternative Provision recognises that safeguarding children from potentially harmful and inappropriate online material is a critical aspect of our wider safeguarding responsibilities. We understand that technology is a significant component in many safeguarding and wellbeing concerns, including exploitation, bullying, grooming and exposure to harmful content. 

As a provision supporting pupils aged 4–11, we recognise that children’s understanding of online risk varies significantly depending on their age, development and individual needs. Many pupils within Alternative Provision may also have increased vulnerability, including SEND, SEMH needs, or previous exposure to risk. 

Our approach to online safety is therefore: 

• age-appropriate and developmentally informed.  

• trauma-informed and supportive.  

• embedded within a whole-provision safeguarding culture.  

Our Aims 

To ensure effective online safeguarding, Elevate Learning Alternative Provision aims to: 

• have robust processes in place (including filtering and monitoring systems) to safeguard pupils, staff and visitors.  

• protect and educate the whole provision community in the safe and responsible use of technology.  

• establish clear expectations and boundaries around the use of devices, including mobile technology.  

• identify, respond to and escalate concerns promptly and effectively.  

• work in partnership with parents/carers and commissioning schools/Local Authorities.  

1. The 4 Key Categories of Risk 

Our approach to online safety is based on the four key categories of risk identified in national guidance: 

1.Content 

Exposure to inappropriate or harmful material, including: 

• violent or distressing content.  

• pornography (even if accessed unintentionally).  

• discriminatory or extremist material.  

• content linked to self-harm or unsafe behaviours.  

For younger pupils, this may occur accidentally through games, videos or shared devices. 

2.Contact 

Risk of harmful interaction with others online, including: 

• strangers attempting to communicate with children.  

• grooming or manipulation.  

• peer pressure or coercion.  

• inappropriate communication through games or platforms.  

Children in Primary/AP settings may not recognise risk and may trust online interactions. 

3. Conduct 

Behaviour by a child that may increase risk, including: 

• sharing personal information.  

• sending or receiving images.  

• unkind or harmful communication.  

• misuse of devices.  

This may be exploratory rather than intentional but still requires safeguarding response. 

4. Commerce 

Risks associated with online financial activity, including: 

• in-app purchases.  

• scams or advertising.  

• exposure to inappropriate commercial content.  

Younger pupils may not understand financial implications or intent. 

13.2 How We Manage and Reduce Risk 

To meet our safeguarding responsibilities, Elevate Learning Alternative Provision will implement the following: 

Education for Pupils (Ages 4–11) 

Online safety education is delivered in an age-appropriate and differentiated way. 

For younger pupils (EYFS/KS1), this includes: 

• understanding what is safe and unsafe online.  

• not sharing personal information.  

• knowing to tell a trusted adult if something worries them.  

• simple rules about using devices safely.  

For older pupils (KS2), this includes: 

• recognising unsafe or inappropriate content.  

• understanding peer pressure and online behaviour.  

• knowing how to report concerns.  

• understanding basic privacy and boundaries.  

• recognising that images should not be shared.  

Teaching is: 

• adapted to individual needs and developmental stage.  

• reinforced through daily interactions.  

• delivered in a way that prioritises safety rather than fear.  

Staff Training and Awareness 

All staff will: 

• receive safeguarding training that includes online safety.  

• understand the risks associated with technology for primary-aged pupils.  

• be aware of signs of online harm, including behavioural changes.  

• understand filtering and monitoring systems and their responsibilities within them.  

• receive regular updates (at least annually).  

Staff will maintain professional curiosity and recognise that online harm may present through behaviour. 

Parental Engagement 

We recognise the importance of working in partnership with parents/carers. 

We will: 

• provide information and guidance on online safety.  

• support parents to understand risks relevant to primary-aged children.  

• share concerns where appropriate.  

• provide clear reporting routes for concerns.  

Use of Mobile Technology 

As a primary Alternative Provision: 

• pupils are not routinely permitted to use mobile phones within the provision.  

• where devices are brought in, clear procedures are followed (e.g. secure storage where appropriate).  

• any use of devices is supervised and risk assessed.  

Staff will: 

• only use personal devices during non-contact time.  

• never use personal devices to photograph or record pupils.  

• always follow the Staff Code of Conduct and Online Safety Policy.  

Acceptable Use 

All members of the provision community (staff, pupils, parents/carers) are expected to understand and follow expectations regarding: 

• safe use of technology.  

• appropriate behaviour online.  

• safeguarding responsibilities.  

These expectations are reinforced through: 

• acceptable use agreements (where appropriate for age).  

• staff training.  

• consistent messaging across the provision.  

Filtering and Monitoring 

Elevate Learning Alternative Provision has monitoring systems in place to reduce exposure to harmful content. 

We will ensure: 

• systems are appropriate for the age and needs of pupils.  

• clear roles and responsibilities are in place (DSL/IT support).  

• concerns or alerts are responded to promptly.  

• systems are reviewed at least annually.  

Alternative Provision Context 

As a non-school Alternative Provision: 

• we do not have statutory search powers.  

• we use consent-based approaches where appropriate.  

• we involve parents/carers and/or police where risk or suspected criminal behaviour is identified.  

• we follow national guidance, including NPCC ‘When to Call the Police’.  

We will also: 

• share safeguarding concerns with commissioning schools/LA where appropriate.  

• ensure consistency of approach across settings.  

13.3 Artificial Intelligence (AI) 

Elevate Learning Alternative Provision recognises the increasing use of AI technologies. 

While AI can support learning, it may also: 

• expose pupils to harmful content.  

• be used to create misleading or harmful material (e.g. deepfakes).  

• increase risks of bullying or manipulation.  

Staff will: 

• be aware of emerging risks.  

• supervise and risk assess any use of AI tools.  

• respond to misuse in line with safeguarding and behaviour policies.  

13.4 Notifying Parents and Carers 

Where appropriate, concerns regarding online safety will be shared with parents/carers. 

The DSL will: 

• lead communication in safeguarding cases.  

• consider whether informing parents increases or reduces risk.  

• liaise with Children’s Social Care where necessary.  

Elevate Learning will also: 

• inform the commissioning school/LA of significant safeguarding concerns on the same day.  

• work collaboratively to agree next steps.  

Supporting Children and Families 

Where online safety concerns arise, the DSL (and relevant agencies where appropriate) will: 

• meet with parents/carers.  

• explain the concern and actions being taken.  

• provide guidance and support.  

• ensure the child’s safety and wellbeing are prioritised.  

This may include: 

• support for the victim.  

• support for the child responsible for the behaviour.  

• adjustments within the provision to reduce risk.  

14. Safeguarding Vulnerable Groups  

14.1 Pupils with Special Educational Needs, Disabilities or Health Issues (SEND) 

Elevate Learning Alternative Provision recognises that pupils with special educational needs and/or disabilities (SEND) or certain medical or health conditions can face increased safeguarding vulnerability. 

Within an Alternative Provision context, many pupils may present with: 

• social, emotional and mental health (SEMH) needs.  

• communication and interaction difficulties.  

• neurodevelopmental differences (e.g. ASD, ADHD).  

• trauma-related behaviours.  

• unmet or complex needs.  

These factors can increase both the risk of harm and the difficulty in recognising or reporting abuse. 

We recognise that children with disabilities are statistically more likely to be abused than their peers, and that safeguarding concerns may be overlooked or misinterpreted if not carefully considered. 

Additional Safeguarding Vulnerabilities 

Barriers to recognising abuse, neglect or exploitation in pupils with SEND may include: 

• assumptions that change in behaviour, mood or presentation are linked solely to the child’s needs or diagnosis, rather than potential safeguarding concerns.  

• increased likelihood of peer isolation, making pupils more vulnerable to bullying, exploitation or manipulation.  

• disproportionate impact of harmful behaviour without obvious external indicators.  

• communication barriers, including limited vocabulary to describe concerns or experiences.  

• difficulties understanding risk, consent, boundaries or appropriate relationships.  

• challenges distinguishing between safe and unsafe situations, particularly online.  

• increased dependence on adults, which may increase vulnerability to abuse.  

Staff must be particularly vigilant and avoid over-reliance on diagnostic explanations where safeguarding concerns may be present. 

Provision Approach 

Elevate Learning Alternative Provision will ensure that: 

• safeguarding responses are adapted to individual need and communication style.  

• pupils are supported to understand and express concerns in ways that are accessible to them.  

• behaviour is considered in context and explored with professional curiosity.  

• safeguarding is embedded within PBS (Positive Behaviour Support) approaches, recognising behaviour as communication.  

Multi-Disciplinary Working 

Any safeguarding concern involving a pupil with SEND will involve close liaison between: 

• the DSL (or deputy DSL).  

• the SENCO or relevant lead practitioner.  

• external professionals where appropriate.  

This ensures that: 

• safeguarding concerns are not missed or minimised.  

• support is coordinated effectively.  

• decisions are informed by a full understanding of the child’s needs.  

Staff Responsibilities 

All staff must: 

• recognise the additional vulnerability of pupils with SEND.  

• remain alert to subtle or non-verbal indicators of harm.  

• adapt communication to support disclosure.  

• report concerns promptly to the DSL.  

• avoid assumptions or minimisation of risk.  

14.2 Pupils with a Social Worker 

Elevate Learning Alternative Provision recognises that pupils who have a social worker are likely to have experienced significant adversity, trauma or safeguarding concerns, which may continue to impact their safety, wellbeing and development. 

These experiences may create additional barriers to: 

• attendance and engagement.  

• emotional regulation.  

• behaviour and relationships.  

• mental health and wellbeing.  

Provision Commitment 

The DSL and all staff will work proactively with social workers and partner agencies to: 

• support and protect vulnerable children.  

• ensure that safeguarding information is shared appropriately.  

• contribute to multi-agency planning and intervention.  

• provide a consistent and supportive environment.  

DSL Responsibilities 

Where a pupil has a social worker, the DSL will ensure that this information informs all safeguarding decisions. 

This includes: 

• responding to absence or missing education with heightened awareness of risk.  

• ensuring that safeguarding concerns are escalated appropriately.  

• contributing to safeguarding plans and reviews.  

• maintaining effective communication with external professionals.  

Whole-Staff Responsibility 

All staff must understand that pupils with a social worker may: 

• present with complex needs or behaviours.  

• require additional support and consistency.  

• be at ongoing risk of harm.  

Staff will therefore: 

• prioritise relationship-building and trust.  

• maintain clear communication with the DSL.  

• act promptly on any concerns.  

14.3 Looked-After and Previously Looked-After Children 

Elevate Learning Alternative Provision recognises that children who are looked-after (LAC) or previously looked-after (PLAC) are among the most vulnerable groups. 

These children may have experienced: 

• abuse, neglect or trauma.  

• disrupted attachments.  

• instability in care or education.  

Provision Responsibilities 

We will ensure that: 

• staff understand the specific safeguarding needs of LAC and PLAC pupils.  

• relevant staff have access to key information, including:  

• legal status.  

• care arrangements.  

• contact arrangements.  

• the DSL maintains contact details for:  

• social workers.  

• virtual school heads.  

Safeguarding Approach 

Support for these pupils will be: 

• trauma informed.  

• consistent and relational.  

• responsive to individual need.  

Safeguarding decisions will always consider: 

• the child’s care experience.  

• their emotional wellbeing.  

• their educational stability.  

14.4 Pupils who are Lesbian, Gay, Bisexual or Gender Questioning (LGBTQ+) 

Elevate Learning Alternative Provision recognises that pupils who are, or are perceived to be, LGBTQ+ may be at increased risk of: 

• bullying, including prejudice-based bullying.  

• social isolation.  

• mental health difficulties.  

• discrimination or harm.  

We also recognise that such pupils may face additional barriers to speaking out, particularly where they do not feel safe or understood. 

Provision Approach 

We are committed to creating an environment where: 

• all pupils feel safe, respected and valued.  

• diversity is recognised and supported.  

• discriminatory behaviour is challenged.  

• pupils can speak to trusted adults.  

Any concerns regarding bullying, wellbeing or safeguarding must be reported to the DSL. 

14.5 Supporting Gender Questioning Pupils (Primary Context) 

As a provision for pupils aged 4–11, we recognise that children may begin to explore identity at different developmental stages. 

Our approach will be: 

• age-appropriate and cautious.  

• focused on safeguarding and wellbeing.  

• informed by professional and clinical guidance where appropriate.  

We will: 

• work in partnership with parents/carers, unless doing so places the child at risk.  

• consider the full range of the child’s needs, including:  

• mental health.  

• neurodevelopmental needs (e.g. ASD, ADHD).  

• social and emotional wellbeing.  

• ensure that decisions are child-centred and safeguarding-led.  

Reducing Barriers and Promoting Safety 

We recognise that safeguarding risks increase where children do not have trusted adults to speak to. 

Elevate Learning Alternative Provision will therefore: 

• ensure that pupils have access to trusted, consistent adults.  

• promote a culture of openness and listening.  

• actively reduce barriers to communication. 

15.Complaints, Concerns, Record-Keeping and whistleblowing  

15.1 Complaints and Concerns About Safeguarding Practice 

Elevate Learning Alternative Provision recognises that a strong safeguarding culture depends on openness, transparency and the ability for concerns to be raised and addressed promptly. 

All concerns relating to safeguarding practice, staff conduct, or the welfare of children will be taken seriously, recorded appropriately, and responded to without delay. 

Complaints Against Staff 

Any complaint or concern about a member of staff, volunteer, contractor or visitor that indicates they may: 

• have behaved in a way that has harmed, or may harm, a child.  

• may have committed a criminal offence against or related to a child.  

• have behaved in a way that indicates they may pose a risk to children.  

will be treated as a safeguarding allegation. 

Such concerns will be managed in line with: 

• the Managing Allegations Against Staff Policy.  

• local authority procedures.  

• guidance from the Local Authority Designated Officer (LADO).  

The Provision Lead will act as the case manager for allegations against staff.[Text Wrapping Break]Where concerns relate to the Provision Lead, this responsibility will sit with the Education Leadership Team/Directors. 

In all cases: 

• concerns must be reported immediately.  

• staff must not investigate allegations themselves.  

• confidentiality will be maintained appropriately.  

• safeguarding takes precedence over organisational reputation.  

Where relevant, the commissioning school/LA will be informed promptly, in line with AP safeguarding responsibilities. 

Other Complaints 

Complaints that do not meet the threshold for safeguarding intervention will be managed in accordance with the Elevate Learning Alternative Provision Complaints Policy. 

However, all staff must remain alert to the possibility that: 

a complaint may indicate an underlying safeguarding concern. 

Where this is the case, the concern must be immediately escalated to the DSL. 

15.2 Whistleblowing 

Elevate Learning Alternative Provision promotes a culture where staff feel safe and supported to raise concerns about: 

• poor safeguarding practice.  

• unsafe behaviour.  

• failures in leadership or systems.  

Staff are expected to raise concerns: 

• internally, via the DSL or Provision Lead; or  

• externally, where appropriate, in line with whistleblowing procedures.  

The provision’s Whistleblowing Policy is: 

• available to all staff.  

• included within induction.  

• accessible via internal systems and on request.  

Staff will not be subject to detriment for raising genuine concerns in good faith. 

15.3 Record-Keeping and information management  

Accurate, timely and secure record-keeping is a critical safeguarding responsibility. 

Elevate Learning Alternative Provision ensures that all safeguarding activity is clearly recorded, enabling effective monitoring, accountability and multi-agency working. 

Recording Safeguarding Concerns 

All staff must ensure that: 

• all safeguarding concerns, disclosures and observations are recorded as soon as possible, and on the same day.  

• records are factual, clear and written in the child’s own words where appropriate.  

• professional opinions are clearly distinguished from facts.  

• all actions taken, decisions made and rationales are documented.  

Records will include: 

• a clear summary of the concern.  

• relevant context and background information.  

• actions taken.  

• decisions made and by whom.  

• outcomes and follow-up actions.  

If staff are unsure whether to record something, they must consult the DSL immediately. 

Storage and Security 

Safeguarding records will be: 

• stored separately from general pupil files.  

• held securely, in line with data protection legislation (DPA 2018 and UK GDPR).  

• accessible only to those with a legitimate safeguarding need.  

Confidentiality will be always maintained, while recognising that information sharing is essential to safeguarding. 

Information Sharing and AP Context 

As a non-school Alternative Provision, Elevate Learning operates within a shared safeguarding framework with commissioning schools and local authorities. 

Therefore: 

• significant safeguarding information is shared the same day with the commissioning school/LA where risk dictates.  

• safeguarding decisions are made collaboratively where appropriate.  

• attendance, welfare and safeguarding concerns are aligned with commissioner processes (including CME and missing protocols).  

Transfer of Safeguarding Records 

When a child transfers to another setting: 

• the DSL will ensure that safeguarding records are transferred securely and promptly.  

• records will be shared separately from the main pupil file.  

• transfer will occur:  

• within 5 days for in-year moves, or  

• within the first 5 days of a new term.  

Where cases are complex or high-risk: 

• the DSL will make direct contact with the receiving DSL.  

• key information will be shared verbally to ensure continuity of safeguarding.  

Elevate Learning will also support the commissioning school/LA to ensure appropriate transfer arrangements are completed. 

Related Policies 

Record-keeping responsibilities are also detailed within: 

• Safer Recruitment Policy  

• Managing Allegations Policy  

• Data Protection Policy  

16. Training and Safeguarding Development 

Elevate Learning Alternative Provision is committed to ensuring that all staff are appropriately trained, confident and competent in safeguarding practice. 

16.1 Training for All Staff 

All staff, including temporary staff, contractors and volunteers, will: 

• receive safeguarding and child protection training at induction.  

• understand:  

• safeguarding systems and procedures.  

• the role of the DSL.  

• how to recognise abuse, neglect and exploitation.  

• receive training in:  

• online safety.  

• whistleblowing.  

• Prevent duty (radicalisation awareness).  

Training will: 

• be updated regularly and at least annually.  

• reflect local safeguarding partner guidance.  

• be aligned with a whole-provision safeguarding approach.  

• consider the needs of pupils in an Alternative Provision context, including trauma and SEMH.  

Staff will also receive: 

• regular safeguarding updates (e.g. briefings, emails, meetings).  

• opportunities to discuss safeguarding practice and concerns.  

16.2 DSL and Deputy DSL Training 

The DSL (Claire May) and Deputy DSL (Rebekah Toro Pérez) will: 

• undertake formal safeguarding training at least every 2 years.  

• update knowledge at least annually.  

• engage with:  

• local safeguarding networks.  

• inter-agency learning.  

• emerging safeguarding risks.  

They will also receive: 

• enhanced Prevent training.  

• training in managing complex safeguarding cases. 

16.3 The Education Leadership Team/Directors 

All Education Leadership Team/Directors members receive training about safeguarding and child protection (including online safety) at induction, which is regularly updated. This is to make sure that they: 

• Have the knowledge and information needed to perform their functions and understand their responsibilities, such as providing strategic challenge 

• Can be assured that safeguarding policies and procedures are effective and support the school to deliver a robust whole-school approach to safeguarding   

 A Director may be required to act as the ‘case manager’ in the event that an allegation of abuse is made against the Provision Lead, they receive training in managing allegations for this purpose. 

16.4 Safer Recruitment 

At least one member of every recruitment panel will have completed: 

• accredited safer recruitment training.  

Recruitment processes will: 

• comply with Keeping Children Safe in Education.  

• ensure all appropriate checks are completed.  

• prioritise safeguarding at every stage.  

(See our Safer Recruitment Policy for more information about our recruitment procedures) 

17. Visitors and Site Safety 

(please also see our visitor procedure) 

Checking the identity and suitability of visitors 

All visitors will be required to verify their identity to the satisfaction of staff and to leave their belongings, including their mobile phone(s), in a safe place during their visit. 

If the visitor is unknown to the setting, we will check their credentials and reason for visiting before allowing them to enter the setting. Visitors should be ready to produce identification. 

Visitors are expected to sign the visitors’ book and wear a visitor’s badge. 

Visitors to the school who are visiting for a professional purpose, such as educational psychologists and school improvement officers, will be asked to show photo ID and: 

• Will be asked to show their DBS certificate, which will be checked alongside their photo ID; or  

• The organisation sending the professional, such as the LA or educational psychology service, will provide prior written confirmation that an appropriate level of DBS check has been carried out (if this is provided, we will not ask to see the DBS certificate)  

All other visitors, including visiting speakers, will be accompanied by a member of staff at all times. We will not invite into the school any speaker who is known to disseminate extremist views and will carry out appropriate checks to ensure that any individual or organisation using school facilities is not seeking to disseminate extremist views or radicalise pupils or staff. Visitors’ mobile devices are not used to photograph/record children; visiting speakers are supervised and briefed on Elevate Learning safeguarding expectations. 

18 Policy Context 

Elevate Learning Alternative Provision operates as a non-school Alternative Provision (AP). Commissioning schools/LAs retain statutory responsibilities for admissions, attendance registers/coding, exclusions and Children Missing Education (CME).  

Elevate Learning Alternative Provision provides same-day safeguarding/attendance information to commissioners and aligns procedures with KCSIE and local safeguarding partner arrangements.  

Where school-specific statutory powers (e.g., searching/screening) do not apply to AP, Elevate Learning Alternative Provision uses consent-based approaches and police engagement when risk warrants. 

This policy relates to the following legislative requirements, standards and internal documents: 

Legislation/Standards 

• Department for Education’s (DfE’s) statutory guidance Keeping Children Safe in Education (2025) and Working Together to Safeguard Children (2023).  

• DfE non-school alternative provision: voluntary national standards (31 Aug 2025) — adopted as [provider name] benchmarks ahead of mandation.  

• Out-of-school settings (OOSS) safeguarding code (as applicable to AP context)  

• The Children Act 1989 (and 2004 amendment) 

• Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015,  

• Statutory guidance on FGM,  

• The Rehabilitation of Offenders Act 1974,  

• Schedule 4 of the Safeguarding Vulnerable Groups Act 2006,  

• Statutory guidance on the Prevent duty,  

• The Human Rights Act 1998,  

• The Equality Act 2010,  

• The Public Sector Equality Duty (PSED),