POLICY: School Governance and Management - Safeguarding Policy (including Prevent) POLICY URL: https://lsi-ac.uk/policy/2432a047-03a0-4876-965e-1537742476de POLICY STATEMENT: The School is committed to safeguarding and promoting the welfare of all community members, recognising that a secure environment is essential for effective learning and personal development. Our Safeguarding Policy, including Prevent duties, outlines our proactive approach to preventing harm, abuse, and extremism. This policy ensures all students, staff, and visitors are protected through prevention, intervention, and responsive measures. POLICY PRINCIPLES: ------------------ - Protection : Providing a secure environment to protect community members from harm and abuse; - Awareness : Raising awareness of safeguarding issues and the signs of abuse or radicalisation; - Prevention : Implementing strategies to prevent the risk of harm, abuse, or radicalisation; - Responsibility : Affirming everyone's duty to report safeguarding concerns promptly; - Training : Ensuring adequate safeguarding training for all staff members; - Support : Offering support and guidance for individuals affected by safeguarding issues; - Response : Responding to safeguarding concerns swiftly and appropriately; - Collaboration : Working with external agencies to address safeguarding issues effectively; - Resilience : Fostering resilience to radicalisation through education and open dialogue; - Transparency : Maintaining clear and transparent procedures for handling safeguarding concerns; - Confidentiality : Respecting confidentiality while prioritising safety and legal obligations; - Review : Regularly reviewing safeguarding policies and practices to ensure they remain effective. REGULATORY CONTEXT: ------------------ This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following: R1. UK Government : Equality Act 2010 - Equalities law to prohibit harassment and victimisation, and eliminate discrimination, including in the area of further and higher education, particularly with regards to specified personal characteristics. R2. UK Home Office: Prevent Duty Compliance - A duty that requires universities and colleges in the UK to take steps to prevent terrorism. R3. Quality Assurance Agency (QAA): The Quality Code - This code represents a shared understanding of quality practice across the UK higher education sector, protecting public and student interests and championing the UK's reputation for quality. R4. Office for Students (OfS): Regulatory Notices and Advice - Regulatory notices are additional information about OfS' regulatory requirements and are part of the regulatory framework. Regulatory advice helps providers understand and meet OfS requirements. R5. Office for Students : Prevent duty: Framework for monitoring in higher education in England - The Prevent Duty: Framework for Monitoring in Higher Education in England sets out how the Office for Students ensures universities comply with their legal duty to prevent individuals being drawn into terrorism. It outlines expectations for governance, risk assessment, staff training, welfare support, and external speaker management, ensuring a proportionate, safeguarding-led approach across all registered higher education providers. R6. Universities UK: Guidance on online harassment - A comprehensive guidance on tackling online harassment and promoting online welfare in the higher education sector. R7. Quality Assurance Agency (QAA): Advice - Enabling Student Achievement - METRICS: ------------------ The following metrics will be measured and regularly reviewed as performance indicators for the School to ensure the effectiveness of this policy and associated operations: M1. Compliance with Prevent Duty: Monitor adherence to Prevent Duty requirements through audits. Achieve at least 100% compliance in annual audits; Compliance with Prevent Duty is essential for preventing radicalisation and ensuring a safe environment. M2. DBS Check Completion Rate: Monitor the percentage of new staff who complete their DBS checks before starting work. Aim for 100% compliance within one month of recruitment. Ensuring all staff undergo DBS checks is crucial for maintaining a safe environment and protecting vulnerable individuals. M3. Incident Reporting Rate: Track the number of safeguarding incidents reported each month compared to the total number of students and staff. High reporting rates indicate that the safeguarding systems are accessible and effective. This helps in early identification and intervention. M4. Staff Training Completion Rate: Measure the percentage of staff who complete mandatory safeguarding and Prevent training within the required timeframe. Target 100% completion annually. Regular training ensures staff are well-informed about safeguarding and Prevent duties, improving their ability to respond effectively. M5. Timeliness of Response to Safeguarding Concerns: Track the average time taken to respond to safeguarding concerns from reporting to initial action. Set a target response time of 24 hours. Prompt responses are critical in safeguarding to ensure timely interventions and support. SECTION 1: Safeguarding, Children, and Vulnerable Adults ------------------ 1.1. Safeguarding Measures for At-Risk Students (by Executive Committee): The School implements safeguarding measures to protect at-risk students, including children and vulnerable adults, from abuse and exploitation. Safeguarding promotes their welfare by addressing significant risks while upholding the duty of care. Safeguarding is the protection of individuals' welfare; abuse refers to mistreatment causing harm; and neglect is the failure to provide necessary care. This policy applies to all students, staff, visitors, and contractors, ensuring clarity around roles and responsibilities within the safeguarding framework; This approach is crucial as it fosters a safe environment, allowing vulnerable individuals to receive the protection they need. By promoting understanding through clear definitions and a defined scope, everyone knows their responsibilities in safeguarding those who may be unable to protect themselves from harm. 1.2. Designated Safeguarding Lead (DSL) and Responsibilities (by Student Success Team): The Student Success Team assumes the role of Designated Safeguarding Lead (DSL), responsible for overseeing safeguarding policies and procedures. They ensure the welfare of students by providing support and guidance in safeguarding matters. All staff, students, and volunteers must understand their responsibilities in safeguarding, including recognising signs of distress, reporting any concerns promptly and accurately, and maintaining confidentiality regarding sensitive information. They are required to follow established protocols and procedures to maintain a safe and supportive environment for everyone; This assumption is vital as it centralises safeguarding responsibilities, ensuring that trained professionals are available to support students effectively. By clearly defining roles within the Student Success Team, the institution fosters a culture of accountability and vigilance, promoting student safety and well-being while empowering everyone to contribute to a secure educational environment. SECTION 2: Mandatory DBS Checks ------------------ 2.1. Pre-Recruitment DBS Checks (by Executive Committee): All staff members must complete a Disclosure and Barring Service (DBS) check prior to recruitment; This ensures that staff are vetted for any criminal convictions or safeguarding issues, thereby protecting students and maintaining a safe educational environment. SECTION 3: Maintaining Professional Conduct ------------------ 3.1. Dignity at Work and Anti-Harassment Policy (by Executive Committee): The School’s Dignity at Work, Bullying, and Harassment Policy ensures a safe, inclusive, and respectful environment for all members of our community. Harassment, abuse, sexual misconduct, and discrimination are strictly prohibited. All students and staff must adhere to the School’s Disciplinary Policies, with disciplinary action enforced for breaches, whether they occur on or off School premises, in person, or via digital platforms such as Microsoft Teams, social media, emails, or text messages; This policy promotes a zero-tolerance approach to behaviour that undermines dignity and respect, reinforcing our commitment to a safe and supportive environment. It ensures that all incidents of bullying, harassment, or victimisation are addressed consistently, regardless of where or how they occur. SECTION 4: Regulations on Staff-Student Interactions ------------------ 4.1. Staff and Student Relationship Policy (by Executive Committee): The Staff and Student Relationship Policy prohibits specific relationships between staff and students to prevent conflicts of interest and safeguarding issues. All other relationships must be disclosed to ensure transparency and uphold professional boundaries; This policy is crucial for maintaining a professional and safe educational environment. It helps prevent conflicts of interest, exploitation, and safeguarding risks, ensuring that all relationships within the School are conducted with integrity and transparency. SECTION 5: Role of Personal Academic Tutors (PAT) ------------------ 5.1. Personal Academic Tutor (PAT) Assignment (by Student Success Team): The School assigns each student a Personal Academic Tutor (PAT) to offer both academic guidance and broader support throughout their studies; This ensures that students receive personalised assistance and mentorship, fostering their academic development and overall well-being. It also helps in identifying and addressing any issues early, contributing to a supportive learning environment. SECTION 6: Policy on Mental Health Support ------------------ 6.1. Mental Health Support Policy (by Executive Committee): The School has a dedicated Mental Health Policy detailing various methods for supporting students with their mental health needs; This policy ensures that students receive comprehensive mental health support, fostering a healthier and more supportive learning environment. By outlining specific support mechanisms, the policy addresses students' mental well-being proactively and effectively. SECTION 7: Support Services Provided by the Student Success Team ------------------ 7.1. Comprehensive Student Support and Wellbeing (by Student Success Team): The Student Success Team provides free, independent, and confidential support for academic, financial, and personal well-being issues. Students can seek assistance from the Team, their Personal Academic Tutor (PAT), or any staff member at any time. The School’s strategy places students at the centre, linking educational and life experiences to enhance overall success and satisfaction. This approach integrates academic and personal support to offer a holistic student experience, ensuring comprehensive care and addressing all aspects of student life effectively; Providing comprehensive support through the Student Success Team ensures that students have access to necessary resources for their academic and personal needs. By integrating support services and prioritising student well-being, the School optimises the educational experience and addresses all aspects of student life, fostering overall success and satisfaction. SECTION 8: Safeguarding and Reporting Practices ------------------ 8.1. Reporting Responsibilities and Student Input (by All Staff and Students): All staff and students must report safeguarding and Prevent concerns promptly. To report suspicions or incidents, individuals should contact the Designated Safeguarding Lead (DSL) via email or in person. Support for those making reports includes access to counselling services and peer support groups. The School guarantees confidentiality throughout the reporting process, ensuring that individuals feel safe to disclose information without fear of repercussions. This structured reporting informs the School’s safeguarding strategy, allowing teams like the Student Success Team to address issues, make informed decisions, and allocate resources effectively. Students are also encouraged to participate in feedback sessions, ensuring their voices shape decision-making processes; This rule is essential as it establishes clear pathways for reporting concerns, fostering a proactive culture around safeguarding and Prevent. By encouraging open communication and ensuring confidentiality, the School promotes a supportive environment where everyone feels empowered to contribute to safety and well-being. This inclusive approach ultimately enhances the effectiveness of the School’s safeguarding strategies. 8.2. Risk Assessment Procedures (by Student Success Team): The School implements robust risk assessment procedures to identify and manage potential risks to student safety, particularly for vulnerable groups. Regular assessments are conducted to evaluate environments and activities, considering factors like physical safety, mental health, and external threats. Action plans are developed to mitigate identified risks, ensuring appropriate measures are in place to protect all students; These procedures are crucial for maintaining a safe educational environment. By proactively identifying risks, the School can implement effective strategies to protect vulnerable students and address concerns before they escalate. This commitment to safety enhances overall student well-being and fosters a culture of vigilance and care within the institution. 8.3. Emergency Procedures (by Student Success Team): The School has established clear emergency procedures to guide responses in critical situations. These include detailed contact numbers for emergency services, internal support teams, and the Designated Safeguarding Lead (DSL). Response protocols outline steps for evacuations, lockdowns, and medical emergencies, ensuring that all staff and students are informed and prepared to act swiftly and effectively; Having well-defined emergency procedures is essential for safeguarding the safety and well-being of everyone on campus. These guidelines enable quick, coordinated responses during emergencies, reducing confusion and ensuring appropriate action is taken. By familiarising the entire community with these protocols, the School enhances preparedness and resilience in the face of unexpected incidents. SECTION 9: Comprehensive Induction and Training for Staff ------------------ 9.1. Staff Induction and Training on Safeguarding (by Executive Committee): All staff must complete an induction on the School’s policies and receive ongoing training. This training covers the identification of safeguarding issues and how to provide appropriate support; This requirement is crucial for ensuring the safety and well-being of the School community. Regular training equips staff with the knowledge and skills needed to address safeguarding concerns effectively, thereby enhancing the overall safety and support within the institution. SECTION 10: Compliance with the Prevent Duty and Implementation Steps ------------------ 10.1. Governance and Oversight (by Board of Governors): The School complies with the Prevent Duty as required under the Counter-Terrorism and Security Act 2015 . The President is the designated Prevent Lead and is responsible for ensuring effective implementation. The Board of Governors has overall accountability and includes Prevent within its wider institutional risk management framework. Prevent responsibilities are embedded across relevant policies including safeguarding, freedom of speech, and IT use. The Board receives an annual report and signs an accountability declaration for submission to the Office for Students (OfS); Clear leadership and oversight are required under the Prevent statutory guidance. Embedding Prevent into existing governance processes ensures effective coordination, legal compliance, and protection of both student safety and academic freedom. 10.2. Risk Assessment and Policy Review (by Executive Committee): The Executive Committee conducts an annual Prevent-related risk assessment, which is reviewed and approved by the Board. Prevent policies and associated documents (e.g. risk registers, action plans) are also reviewed annually to ensure alignment with current legislation and best practice; A risk-based approach enables the School to identify and respond to emerging threats. Annual reviews ensure policies remain fit for purpose and proportionate to the institution’s size, activities, and context. 10.3. Training and Awareness (by Executive Committee): All staff receive Prevent and safeguarding training at induction and at regular intervals thereafter. Additional training is provided for staff with specific responsibilities, such as pastoral leads, IT staff, and event organisers. Student-facing information is also provided to raise awareness of support pathways and safeguarding responsibilities; Training ensures that staff are confident in recognising signs of radicalisation, applying Prevent procedures, and responding appropriately. It also supports compliance with OfS expectations for evidence of active implementation. 10.4. External Speakers and Events (by Executive Committee): All proposed events involving external speakers—whether delivered on-site, online, or asynchronously—must be submitted in advance for a structured risk assessment. Risk is assessed in relation to the potential for extremist content, unlawful speech, and overall impact. Outcomes, including any conditions or decisions to modify or decline events, must be clearly recorded and retained. Event organisers must be trained to apply the process correctly; This ensures freedom of expression is upheld within the boundaries of the law and institutional policy. It also provides evidence for OfS that the School manages risk appropriately and proportionately in line with Prevent guidance. 10.5. IT Systems and Digital Safety (by Director of Technology ): The School’s IT systems are reviewed annually to ensure appropriate filtering, monitoring, and logging systems are in place. These arrangements are designed to prevent access to extremist material while respecting user privacy and academic freedoms. Compliance with related requirements such as PCI-DSS is also maintained; Effective digital safeguards support the School’s wider Prevent responsibilities by reducing access to harmful content, ensuring data security, and protecting the institution from reputational and operational risk. 10.6. Reporting of Serious Incidents and Material Changes (by Executive Committee): Any serious Prevent-related incident or material change must be reported promptly to the OfS. This includes:; ; Substantial changes to Prevent-relevant policies or structures; ; A new Prevent Lead or governance structure; ; Significant operational shifts (e.g. new campuses or delivery modes); ; Incidents involving reputational or safeguarding concerns; Reports are submitted via the OfS portal or to the Prevent team directly, with relevant documentation and explanation; Timely reporting supports transparency and helps the OfS assess provider risk and compliance. It also demonstrates that the School is taking a proactive approach to managing potential threats. 10.7. Internal Monitoring and Continuous Improvement (by Executive Committee): Prevent implementation is reviewed internally at least once per academic year. This includes:; ; Evaluation of training completion and effectiveness; ; Review of risk assessments, incident logs, and external speaker decisions; ; Feedback from staff and students through surveys, consultations, or focus groups; ; Review of any Prevent-related complaints or concerns; Outcomes are documented in an internal report, with actions tracked and reviewed by the Executive Committee and shared with the Board; Regular internal monitoring enables the School to identify gaps, make timely improvements, and provide assurance that the duty is being implemented effectively. It supports a culture of learning and reflection. 10.8. External Engagement and Review (by Executive Committee): The School maintains open communication with the OfS Prevent Monitoring Team and relevant external partners, including local Prevent Coordinators. This includes:; ; Participation in Prevent Review Meetings (PRMs) if selected; ; Responding to OfS requests for information or thematic reviews; ; Contributing to sector-wide initiatives and good practice sharing; Collaboration with regulators and external agencies ensures the School remains aligned with national expectations, has access to current guidance, and contributes to wider sector learning on Prevent delivery. SECTION 11: Prevent Duty: Serious Incident and Material Change Reporting Protocol ------------------ 11.1. Serious Prevent-Related Incidents (by Executive Committee): All serious Prevent-related incidents must be reported to the Office for Students (OfS) without delay. A serious incident may include:; ; Reputational damage linked to extremism or radicalisation; ; An internal safeguarding failure involving Prevent concerns; ; Police involvement or emergency response due to radicalisation concerns; ; A Channel referral or multi-agency case requiring escalation; Designated staff must submit a report via the OfS portal or to the OfS Prevent team. Reports must include a description of the incident, actions taken, and any policy changes arising; Prompt reporting ensures the OfS has full visibility of potential risks and can support sector-wide safeguarding. It also demonstrates that the School has effective escalation, governance, and response procedures in place. 11.2. Material Changes to Key Policies or Leadership (by Executive Committee): The School must report material changes that may impact its implementation of the Prevent Duty. These include:; ; Substantive revisions to Prevent-related policies (e.g. welfare, IT, external speaker management); ; Appointment of a new Prevent Lead, Designated Safeguarding Lead, or significant leadership restructure; ; Major changes to institutional operations (e.g. mergers, campus expansion, or delivery format changes such as from online to in-person); ; Major changes to partnership or franchise arrangements affecting Prevent responsibilities; Reports should be submitted through the OfS portal, accompanied by relevant documentation (e.g. revised policies, updated governance charts) and an explanation of the likely impact on Prevent delivery; Material changes may alter how the School meets its statutory Prevent obligations. Timely disclosure helps maintain transparency, ensures updated records, and allows the OfS to assess risk and provide appropriate oversight or support. 11.3. Reporting Responsibilities and Procedure (by Executive Committee): The Prevent Lead is responsible for coordinating the identification, documentation, and reporting of both serious incidents and material changes. Where relevant, they will liaise with:; ; The Designated Safeguarding Lead (DSL); ; The President or relevant Executive Committee members; ; The IT and Governance teams (for technical or policy changes); The Prevent Lead will:; ; Record the incident or change using the internal Prevent log; ; Collate relevant documents and a summary explanation; ; Submit the report via the appropriate OfS channel (portal or email); ; Inform the Board of Governors at the next scheduled meeting or earlier if urgent; Staff involved in safeguarding, compliance, or leadership changes must notify the Prevent Lead immediately when a reportable matter arises; A clear procedure ensures accountability and timely reporting. It also provides assurance that the School has appropriate oversight and is able to meet regulatory requirements confidently and consistently. SECTION 12: Prevent Duty: Self-Assessment and Continuous Improvement Mechanism ------------------ 12.1. Routine Prevent Self-Evaluation (by Executive Committee): The School must conduct an annual self-assessment of its Prevent Duty implementation. This process will:; ; Review performance against internal Prevent objectives and risk assessments; ; Audit key processes such as training uptake, external speaker management, and incident reporting; ; Assess the effectiveness of reporting lines and governance oversight; ; Identify areas for improvement and record outcomes in a formal internal report; This self-assessment is led by the Prevent Lead and submitted to the Executive Committee and Board of Governors for review. 12.2. Scenario Testing and Simulated Case Review (by Executive Committee): As part of the annual self-assessment, the School will conduct hypothetical scenario testing to evaluate how staff would respond to Prevent-related risks. Scenarios may include:; ; An external speaker proposing controversial content; ; A safeguarding referral for potential radicalisation; ; IT misuse involving extremist material; ; A student expressing views that cause concern among peers; Findings are discussed in small-group workshops or working groups, with outcomes documented and used to refine procedures and training content; Scenario testing provides a practical way to assess preparedness and test whether existing policies work in real-life situations. It also enhances staff confidence and supports a learning culture within the School. 12.3. Learning from Review Meetings and Audits (by Executive Committee): The School will use feedback from Prevent Review Meetings (PRMs), internal audits, or external quality reviews to update its policies, procedures, and risk assessment. Any recommendations from OfS engagement or sector evaluations must be recorded, reviewed by the Executive Committee, and acted upon within a defined timeframe; Learning from formal reviews helps ensure that the School’s Prevent arrangements are not only compliant but continually evolving. It demonstrates commitment to best practice and provides assurance to regulators, students, and staff. 12.4. Sector Engagement and Thematic Reviews (by Executive Committee): Where possible, the School will participate in sector-wide activities led by the OfS or related bodies, including:; ; Thematic reviews or deep dives on topics such as staff training or welfare; ; Case-sharing workshops and peer-learning events; ; Pilot studies or evaluation frameworks linked to Prevent; Participation is coordinated by the Prevent Lead and recorded in the School’s Prevent activity log; Engaging with sector-wide Prevent activities keeps the School up to date with national developments, fosters collaboration, and supports evidence-based improvements. It also helps shape the future direction of Prevent policy through constructive contribution. SECTION 13: Monitoring and Review Procedures ------------------ 13.1. Continuous Improvement (by Executive Committee): The School implements procedures for the regular review and updating of its safeguarding policy. This includes scheduled evaluations at least annually and mechanisms for gathering feedback from students and staff, such as surveys and focus groups. These processes ensure that the policy remains effective, relevant, and responsive to the changing needs of the School community; Regular monitoring and review of the safeguarding policy are crucial for maintaining its effectiveness and relevance. By actively seeking input from students and staff, the School fosters a culture of collaboration and transparency, ensuring that safeguarding measures adapt to emerging challenges. This commitment to continuous improvement ultimately enhances the safety and well-being of all members of the School community.