Safeguarding Policy

1. Introduction

1.1          The Academy acknowledges its duty of care to safeguard and promote the welfare of all individuals that engage in its activities.

1.2          The purpose of this safeguarding policy (the Policy) is to set out the Academy's commitment to safeguarding, what systems the Academy has in place to ensure its beneficiaries and those who come into contact with the Academy are safe, and what the Academy expects from other organisations and individuals with whom it works in carrying out the Academy's objects and in its operations.

1.3          The Academy aims to ensure that all individuals, regardless of any personal characteristics, protected or otherwise:

1.3.1            have a positive and enjoyable experience of any activities or engagement with the Academy in a safe environment; and

1.3.2            are protected from any form of abuse whilst participating in any activities under the auspices of the Academy, whether at the Academy premises or elsewhere and at                any time of the day or night.

1.4          The Academy will not tolerate practices which promote or facilitate abuse, harm, and/or exploitation and is committed to ensuring its safeguarding practice reflects statutory responsibilities, government guidance and complies with best practice and Charity Commission requirements.

1.5          This Policy applies in relation to all of the Academy's activities. It applies to anyone working or volunteering on behalf of the Academy including staff, Trustees, Fellows, consultants, contractors and all third-party providers working with the Academy. These individuals and organisations are required to comply with the requirements in this Policy. In the case of staff working for the Academy, safeguarding training is part of the compulsory compliance training. Failure to complete this training will lead to disciplinary action.

2.             What is Safeguarding

2.1          Safeguarding is action that is taken to protect and promote the health, wellbeing and welfare of people (especially children and adults at risk) and protect them from harm.

3.             Our Safeguarding obligations

3.1          The Academy's Trustee Board has a legal duty to act prudently which means that it must take all reasonable steps within its power to ensure that those who come in contact with the Academy are not harmed. This is particularly important where such persons are children and young people under 18 years of age, or adults at risk, in receipt of Regulated Activities (vulnerable groups).

3.2          The Academy will do this by ensuring:

3.2.1            all concerns or suspicions of a safeguarding nature arising in the course of the Academy's work will be taken seriously and responded to swiftly and appropriately;

3.2.2            all members of the Trustee Board, staff and volunteers are clear about their safeguarding responsibilities and know how to respond to concerns appropriately;

3.2.3            the Academy is aware of, and complies with, all statutory guidance, good practice guidance and legislation relating to safeguarding that is relevant to the Academy (see section 5 below);

3.2.4            the Academy records and reports any safeguarding concerns of which it is made aware to the relevant agencies, including the Police, and, in the case of a serious incident, to the Charity Commission; and

3.2.5            all third parties with whom the Academy works, share its commitment to safeguarding. We will expect them to either, have adequate policies and procedures in place which are legally compliant and appropriate to their work (see section 5 below), or to adhere to the Academy’s own safeguarding policy and procedures, as laid out in the Academy standard contracts. The Academy will take a risk-based approach to monitoring this, and in particular circumstances, such as when a third party is working with children or vulnerable adults, a member of the Academy safeguarding team will review the provider’s safeguarding documentation.

4.             Our policies and procedures

4.1          The Academy recognises that there is a wide range of risks and harms against which it must safeguard those who come into contact with the Academy. Accordingly, the Academy has a suite of policies in place to protect individuals from such harms. These include:

4.1.1            Diversity and Inclusion policy;

4.1.2            Anti Bullying and Harassment policy;

4.1.3            Whistleblowing policy;

4.1.4            Health and Safety policy;

4.1.5            Modern Slavery statement;

4.1.6            Anti-Bribery policy;

4.1.7            General Privacy policy;

4.1.8            the General Code of Conduct; and

4.1.9            the Fellows Code of Conduct.

4.2          In addition, the Academy has a separate Safeguarding Procedure document for reporting safeguarding concerns, and internal safeguarding guidance documents for staff, in particular for those working with vulnerable groups and those working internationally and engaging people in different countries and cultures.

4.3          The Academy will:

4.3.1            ensure all staff, volunteers and third parties have access to, are familiar with, and know their responsibilities within this policy;

4.3.2            design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with the Academy. This includes the way in which information about individuals participating in its programmes is gathered and communicated;

4.3.3            implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel;

4.3.4            ensure staff receive training on safeguarding at a level commensurate with their role in the organisation;

4.3.5            appoint a designated Trustee (to provide oversight of safeguarding, provide advice to the executive and provide regular updates to the Trustee Board). The safeguarding Trustee will be provided with the necessary information to assess the effectiveness of the Academy’s safeguarding policy and procedures;

4.3.6            appoint a designated safeguarding team (lead and deputies), to manage all aspects of safeguarding, including updating the policy, reporting procedure and other guidance documents, oversee training of Academy staff, including specific training requirements for staff working with vulnerable groups, undertake the reporting of safeguarding incidents and will with the leadership of the Academy and safeguarding Trustee; and

4.3.7            ensure that any activities being undertaken by Academy staff or by organisations and individuals working on behalf of the Academy in international settings follow the additional safeguarding guidance related to international activities;

4.3.8            ensure that any activities undertaken by Academy staff or by organisations and individuals working on behalf of the Academy working with vulnerable groups (including children and adults at risk) follow the additional safeguarding guidance related to working with vulnerable people;

4.3.9            follow up on reports of safeguarding concerns promptly and according to the Academy’s procedures.

4.4          The Academy regularly reviews this policy and the reporting procedure document to ensure they remain relevant to the Academy's activities, compliant with all statutory guidance and that they also reflect sector best practice.

5.             Third party safeguarding obligations

5.1          These obligations apply to all third parties with whom the Academy engages during the course of its operations.

5.2          The Academy expects these organisations and individuals to:

5.2.1            take all steps within their power to ensure that all people with whom they come into contact are protected and kept safe;

5.2.2            ensure that all people have the same protection regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identify, or any characteristic;

5.2.3            in the case of working with children, comply, with the government inter-agency statutory guidance Working together to safeguard children (as may be replaced or updated from time to time) unless exceptional circumstances arise;

5.2.4            in the case of working with children, have a named person with a clearly defined role and responsibilities in relation to safeguarding and child protection, appropriate to the level at which they operate;

5.2.5            either have relevant safeguarding policies in place which are robustly enforced and reviewed annually or when relevant changes to legislation occur (whichever is earlier), or agree to adhere to the Academy’s safeguarding policy;

5.2.6            where appropriate, in particular for those organisations working with children or vulnerable adults, provide their staff with training on their safeguarding policy as part of their induction, and to receive refresher training on the policy shortly after the policy is next reviewed and updated;

5.2.7            demonstrate a commitment to safe recruitment, selection and vetting.  For example:

(a)     where they are working with vulnerable groups in the UK:

(i)       they must ensure that all individuals employed or engaged to work in Regulated Activities are subject to a valid enhanced disclosure check for Regulated Activity undertaken through the Disclosure and Barring Service (or its successor body); it is a criminal offence for you to permit a person to engage in Regulated Activity if you know or have reason to believe that person is barred;

(ii)      where it is not possible to request a DBS check (e.g. because the individual is a non UK national), then they must use all reasonable endeavours to obtain a 'Certificate of Good Conduct' or equivalent document(s) from the relevant country's police force; and

(iii)     they must monitor the level and validity of the checks carried out for each member of staff;

(b)     where they are a charity and are looking to recruit a trustee:

(i)       they must comply with the Charity Commission's guidance, Finding new trustees (CC30) (as may be replaced or updated from time to time) in relation to the checks and safeguards that must be in place when recruiting trustees;

5.2.8            have in place systems to ensure that all staff working with vulnerable groups are monitored and supervised and that they have opportunities to learn about child protection and safeguarding adults and other issues relevant to their roles and responsibilities;

5.2.9            have a clear process for recording incidents, concerns and referrals, and dealing with those through proper procedure and investigation, and ensure that referrals and reports to the statutory safeguarding partners are made properly and promptly;

5.2.10         foster a culture in which their staff, volunteers and anyone else with whom they come into contact are encouraged to notify them of any safeguarding concerns or incidents as they arise;

5.2.11         have clear guidance on confidentiality and information sharing;

5.2.12         have in place a code of behaviour for staff, with the consequences of breaching the code clearly linked to disciplinary and grievance procedures and/or termination of their contract;

5.2.13         promptly provide the Academy with evidence of their compliance with the above if requested; and

5.2.14         inform the Academy immediately of significant safeguarding concerns or incidents that take place within the organisation and in particular (but not exclusively) any incident that is reported to the Charity Commission as a serious incident.

5.3          The Academy recognises that third parties with whom it works will vary widely in terms of their size, the resources available to them. The Academy therefore acknowledges that the manner and the extent to which third parties meet and adopt the expectations set out above will be different to the manner and the extent to which other organisations meet and adopt them.

5.4          The Academy will provide a copy of this policy to all third parties to whom this policy applies.

6.             Dealing with breaches of this policy

6.1          If you become aware of, or have reasonable grounds to suspect or believe there has been, a breach of this Policy you must report it to Dr Rhys Morgan, Director Engineering and Education [email protected] (the Designated Safeguarding Lead). In their absence a report should be submitted to Lynda Mann, Head of Education Programmes (Deputy Safeguarding Lead (UK)) [email protected] or Meredith Ettridge, Associate Director, International (Deputy Safeguarding Lead (International)) [email protected]. Alternatively, you may submit a report to the Governance, Risk and Compliance team [email protected] who will allocate it to the appropriate safeguarding lead.

6.2          Similarly, if you receive a disclosure of harm or abuse, follow the procedure document for reporting a safeguarding concern.

6.3          The action taken will depend upon the nature of the concern referred. An investigation will be undertaken followed by appropriate action, according to the reporting procedure document.

6.4          The Academy reserves the right, at any time, to request evidence from any person engaged by the Academy, or with whom it works, of their compliance with the law, this Policy and good safeguarding practice. If the Academy does not receive that evidence within a reasonable timeframe, or is not satisfied with the evidence that has been received, it may:

6.4.1            where it is concerned about something, report them to the relevant authorities, where considered appropriate;

6.4.2            take such action as may be necessary to ensure the ongoing safety of the Academy's beneficiaries;

6.4.3            take such action as is necessary to recover any funds given (including legal action); and

6.4.4            terminate the Academy’s association.

7.             DEFINITIONS

7.1          For the purpose of this Policy, the following definitions apply:

7.2          beneficiaries means all individuals who are deriving a benefit from the Academy.

7.3          harm means ill-treatment or impairment of health and development, including but not limited to

(a)                 physical harm which is physical contact that results in discomfort, pain or injury;

(b)                 emotional and psychological harm which is action or inaction that causes mental anguish or distress;

(c)                 sexual harm and exploitation which is any form of sexual activity which involving children under the age of consent or force/enticement to engage in sexual activity or involvement in sexual activity without consent including female genital mutilation;

(d)                 neglect and acts of omission which is the failure to meet the needs of vulnerable groups;

(e)                 bullying, harassment and discrimination;

(f)                  institutional harm; and

(g)                 financial harm.

7.4          Regulated Activity are those activities as defined in The Safeguarding Vulnerable Groups Act 2006 (as amended or replaced from time to time) i.e.:

(a)                 those activities which, if any adult requires them, will mean that the adult will be considered vulnerable at that particular time. These activities are: the provision of healthcare, personal care, and/ or social work; assistance with general household matters and/or in the conduct of the adult’s own affairs; and/or an adult who is conveyed to, from, or between places, where they receive healthcare, relevant personal care or social work because of their age, illness or disability; and

(b)                 unsupervised activities with children, and work for a limited range of establishments with the opportunity for contact with children. These activities are: teaching, training, instructing, caring for or supervising, or providing advice/guidance, providing health or personal care or driving a vehicle for children. Relevant establishments are schools, children's homes and childcare premises.

8.             Reviewing and amending this policy

8.1          The Academy is committed to continuous development and improvement and shall accordingly review this Policy at least every two years to ensure that its provisions continue to meet the Academy's legal obligations and reflect best practice.