Welcome to September 2021, which for many settings is the start of the next academic year, and a time of new beginnings.
As a safeguarding trainer who supports the professional development of designated safeguarding leads (DSLs), I am aware of the sense of overwhelm that many of them experience. And the publishing of new key statutory guidance can sometimes play into that sense of overwhelm. To help your setting get a head start I offer you 5 specific ways to ensure that your setting is compliant with the new Keeping Children Safe in Education (KCSIE).
Top tip: the work of the DSL can be delegated to a team of deputies – share the load! The news is that, regarding several concerns raised about peer abuse and other recent developments in safeguarding, there has been major revisions to KCSIE. Even if you aren’t in a registered setting (and therefore expect a visit from Ofsted at some point), KCSIE is still the main document that describes in detail how organisations working with children should safeguard effectively, and this is the best time to check out the most recent amendments.
So here is my advice:
- Peer Abuse
Please fully review your understanding, your policies and procedures, and your knowledge and skills as a setting on peer abuse. The influence of the Ofsted Review of sexual abuse in schools & colleges published earlier this year can be seen throughout the new KCSIE guidance, reminding settings of the importance of tackling the widespread and harmful form of peer abuse. Your setting’s safeguarding policy should state:
- A definition of peer abuse that states that includes intimate personal relationships between peers, and that peer abuse can happen inside or outside of school and online.
- That your setting recognises the scale and impact of harassment and abuse, makes clear there should be a zero tolerance approach to abuse, and acknowledges that non-recognition/downplaying the scale and scope leads to a dangerous culture in the setting and will impact future victims of sexual violence or sexual harassment.
- A responsibility for all staff to be vigilant and, rather than waiting for a direct disclosure of abuse, that they recognise young people may not always make a direct report, and information may come from overheard conversations or observed behaviour changes.
- Clear procedures for dealing with peer abuse (these are detailed in the guidance but should be made specific to each setting), which affirm that victims should be taken seriously, kept safe and never be made to feel like they are creating a problem for reporting, the UKCIS guidance on the sharing of nude and semi-nude images (which has replaced their sexting advice), how to recognise the signs of peer on peer abuse, how to respond to reports or disclosures, what to do when a report is found to be unsubstantiated, unfounded, false or malicious (including the need to consider whether the person making the allegation did so as a cry for help) or whether disciplinary action (in line with the behavioural policy) is indicated, how to signpost victims and perpetrators to sources of support, how to monitor for patterns of inappropriate behaviour.
- A link to and a reminder that staff should read related and also very recently updated government advice on peer abuse Sexual violence and sexual harassment between children in schools and colleges (September 2021)
As well as revising your policy and procedures, you need to also ensure that your staff induction and safeguarding training, and staff supervision, include reference to peer supervision to support and develop the understanding of your staff team on this vital topic.
Importantly, the Ofsted ‘Inspecting safeguarding in early years, education and skills’ has also been amended to align with the latest version of KCSIE and the importance of addressing Peer Abuse. A new section has also been added to the inspection guidance about the outcomes from Ofsted’s review of sexual abuse, and there are further references throughout the guidance outlining expectations of providers. One of the keys messages from the research was that ‘even where school and college leaders do not have specific information that indicates sexual harassment and online sexual abuse are problems for their children and young people, they should act on the assumption that they are‘ – and Inspectors will be looking for a ‘whole school approach’ to this.
It’s a good time to update your safeguarding policy, not just regarding KCSIE and peer abuse, but in other ways. Have the names of the key safeguarding leaders in your setting changed – or their contact details? Are you defining safeguarding using the most up to date wording set out in the most recent edition of Working Together to Safeguard Children? Here it is:
- ‘protecting children from maltreatment
- preventing impairment of children’s mental and physical [my emphasis] health or development
- ensuring that children are growing up in circumstances consistent with the provision of safe and effective care
- taking action to enable all children to have the best outcomes.’
But there are, of course, changes in KCSIE which should also ideally be reflected your safeguarding policies (if they aren’t already). These include:
Reference to ‘whole school and college approach to safeguarding’ which make clear the importance of safeguarding.
The importance of putting ‘child centric’ systems in place.
The importance of contextual safeguarding.
More detail on the effective management of children’s disclosure of abuse.
The definition of sexual abuse – there is no longer a reference to a “high level of violence”, instead now reading “Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence…’
Detailed and defining information on a variety of different forms of abuse and welfare concerns (besides peer abuse) so that staff can spot the signs and safeguard victims, including: bullying and cyberbullying (and understanding prejudice-based and discriminatory bullying), modern slavery, county lines, cybercrime, domestic abuse (to reflect Domestic Abuse Act 2021 which will introduce the statutory definition of DA and recognises children as victims of DA in their own right), radicalisation, child criminal exploitation (including how children can be exploited, making clear that the experiences of girls being criminally exploited can be very different to boys), child sexual exploitation (which makes clear that CSE is a form of child sexual abuse and includes information on what it may involve, and the support for children’s mental health needs.
Record keeping – additional information is added in the latest KCSIE which further clarifies what safeguarding records should include.
The correct use of school/college premises for non-school/college activities.
The additional risk of harm of alternative provision.
3. Online safety
Linked to both peer abuse and policy is looking at online safety. There is an increased emphasis in KSIE on understanding the impact of technology on increasing risks to children added throughout, understanding that young people can be both victims and perpetrators of cyber abuse. The risks include: remote learning, filters and monitoring, information security, cybercrime, reviewing online safety provision and information and support for victims. Annex D is a source of useful resources to help support DSLs and other staff in ensuring that online safety is considered throughout the setting. My advice is to review at the start of term your staff training on online safety (and how they receive updates), the role and skills of the online safety coordinator, the incident log, and the curriculum content of the setting devoted to this subject.
4. Training and supervision
It’s a good time of year to also review and meet the safeguarding training needs of the organisation. In the most recent edition of KSIE, emphasis on all staff reading Part one annually has been replaced by a clear requirement that everybody in the setting understands their safeguarding responsibilities. But staff who work directly with children should still read at least Part one of this guidance annually – on the other hand staff who aren’t working directly with children can now just read the condensed version of Part one which is the new Annex A.
The new KCSIE sets out new information on a ‘one stop shop’ for teachers which includes teacher training modules on RSHE. It emphasises that there should not be a ‘one size fits all’ approach and that teaching children about safeguarding and online safety will need a personalised strategy. There are a variety of different resources in KCSIE suggested to support this teaching.
There is a theme around accountability that is reflected throughout KCSIE, with new clearer responsibilities for managers, governors, proprietors and the (newly added) senior leadership team, a description of the additional risks this cohort may face and how they should address these challenges. This suggests that for many settings, inhouse training for managers to review and update their understanding of their responsibilities may be a priority.
As well as training on peer abuse and online safety, staff must have safeguarding training that is integral and aligned as part of a whole school or college approach. The guidance also refers to the Teacher’s Standards, and the expectations within the standards around behaviour and understanding of the needs of all pupils (including those with SEND).
The guidance affirms that DSLs need support – as well as highlighting and their need to support others. The need for formal supervision isn’t mentioned specifically (we still wait for that clarity), but there is an implication that DSLs need to be considering their own need for supervision and that of other staff members. There are also new changes in the storing of records and access to those records, with the expectation that the DSL will oversee this. A paragraph has also been added to ensure the DSL understands the importance of information sharing, the regulations around information sharing and the need to keep accurate and detailed records.
A new section on understanding the views of children has been added to ensure the DSL is supported in developing knowledge and skills to encourage a culture of listening and reducing barriers to disclosure. Consideration (in my opinion) should be given to providing safeguarding leaders with appropriate advanced safeguarding training which would clarify all these issues.
5. Staff recruitment and allegations procedures
The Safer Recruitment section of KCSIE has been substantively restructured to align it with the practical recruitment process (although the legal duties of settings, it states, have not changed). The new KCSIE emphasizes the need to need to ensure that those involved in recruitment and employment of staff have received safer recruitment training.
The Allegations section now includes information on how settings should manage low level concerns about staff that don’t make thresholds for abuse. Any changes in your procedures should of course be reflected in your safeguarding and recruitment policies and communicated to staff.
For more information on the detailed changes in the guidance – check out Annex G, the table of substantive changes in Keeping Children Safe in Education September 2021
Final top tip – don’t bother printing out statutory guidance! It won’t be long before there will be further amendments, probably in January 2022, and your hard copy will be out of date. I always use the most up to date online version for reference, which is more accurate and saves a little of the planet in the process.
If you need any support with safeguarding training, policy or supervision please do not hesitate to contact me. I can offer you a range of bespoke training to address a variety of training needs, and I can assist you with the review of your safeguarding policies. I can also offer non-managerial safeguarding supervision for your safeguarding leaders. For more information, please see my new brochure for this academic year.