Safeguarding Policy for Online Courses

POLICY STATEMENT

1. This policy is aimed at all those involved in the provision of Lexis online teaching and social activities to children. A separate policy entitled ‘Safeguarding Policy for Face-to-face Courses’ covers face-to-face provision.
2. According to UK law, any person under the age of 18 is classed as a child. Therefore for the purposes of this document, the terms child(ren) and Under 18(s) are used synonymously.
3. At Lexis School of English we firmly believe that all Under 18s have the right to study in a safe, protective learning environment and that it is our duty to provide this. This is true regardless of their gender, language, race, age, religion or sexual orientation.
4. Furthermore, safeguarding is the responsibility of everyone.
5. All adults whose contact with Lexis brings them into contact with Under 18s are governed by the terms of this policy. This includes but is not limited to all staff members whether paid or unpaid, parents, visitors, group leaders, adult students.
6. All adults who come into contact with Under 18s have a duty and responsibility to protect them. This is often referred to as a ‘Duty of care’. They must be vigilant and prepared to report any concerns to the appropriate person(s) within the school or the relevant authorities outside the school. It is therefore vital that they familiarise themselves with the name of the Designated Safeguarding Lead, as detailed in the section ‘Designated Safeguarding Personnel’ below.
7. Under 18s themselves should look out for each other and raise concerns with adults if necessary.
8. This policy was last updated on 1st February 2021.
9. As part of our on-going commitment to safeguarding Under 18s, we will continually review this policy and make changes as necessary. In doing so, we will listen to feedback from staff, students, visitors and other parties. A formal review of this policy will take place every 6 months and will be signed off by the School Director.

DESIGNATED SAFEGUARDING PERSONNEL

Designated Safeguarding Leads – Steve Austin (Director of Studies) (Specialist Safeguarding)

& Elena Logara-Panteli (Admissions Officer)

In addition, the Director (Terry Panteli), and all Lexis teachers and other staff have completed at least Basic level Safeguarding.

CODE OF CONDUCT

1. At Lexis we firmly believe in building trust between Under 18s and adults and creating a safe culture within the school. As such, we aim to protect both Under 18s and adults from any actions or behaviour which might be misconstrued.
2. Under the terms of the Sexual Offences Act 2003, any person in a Position of Trust engaged in sexual activity of any sort with students under the age of 18 is breaking the law (even though the legal age of consent is 16). Please see section 4 ‘Child Protection’ for examples of how sexual activity is defined within the online environment.
3. Where staff are using their own device (because they are working remotely), this fact will be recorded by the school and staff must agree to follow the safety guidelines contained in this policy.
4. Staff should only use online accounts / platforms that have been authorised by Lexis School of English to communicate with Under 18s. Under no circumstances should staff use their personal accounts for this purpose.
5. Privacy settings must be turned on for accounts used for online communication with children.
6. All online communications must be relevant to the individual child’s course at Lexis School of English..
7. Staff should avoid anything in their dress or general appearance which might be construed as sexually provocative e.g. revealing clothing or overuse of make-up.
8. Staff should be even-handed when dealing with Under 18s and avoid any behaviour which suggests either preferential or disadvantageous treatment of individuals. In particular, they should avoid displaying favouritism (and thus causing others to feel left out), or acting in a way that they lay themselves open to accusations of favouritism.
9. Staff should show caution when accepting gifts from students. Whereas in some cultures, giving gifts to teachers and other adults is normal, it can lead to accusations of bribery. Lexis only allows staff members to accept small gifts up to an approximate value of £10. Whilst this situation is perhaps less likely to occur online, staff should still be aware as students may offer to post gifts to the school or directly to them. On no account should staff members share their address or other contact details with any students.
10. Staff should use appropriate language and actions when addressing Under 18s.
11. Staff should show that they respect Under 18s. For example, they should treat them as individuals who each have a valid contribution to make, pay attention to what they are saying, use positive language and praise them as appropriate, while at the same time remembering paragraph d) above.
12. Teaching staff should ensure that all teaching material given to Under 18s is suitable for that purpose, always keeping in mind whether they would be happy for their own child to have access to such material. If in doubt, staff should consult the Director of Studies (See also section on ‘E-Safety’ below).
13. Socialising with Under 18s outside of class is not permitted, except during online social activities arranged by the school. During these activities, staff should continue to behave in an appropriate manner, just as they would in class or on the school premises.
14. Staff should avoid drinking alcohol and smoking during online lessons / activities with Under 18s.
15. Staff must not (by any means or in any circumstances) make, view or access illegal or inappropriate images of children.
16. If any staff member believes another member of staff is not following the Code of Conduct as outlined above, they have a legal obligation to inform the school management immediately (often referred to as whistleblowing). They will not be penalised for reporting their concerns and their report will remain confidential. The NSPCC also have a Whistleblowing Advice Line which offers free advice if staff are worried about how child protection issues are being dealt with by Lexis or any other organisation.
17. The number for this is 0800 028 0285.
18. Here in table format is a summary of appropriate conduct when dealing with Under 18s:

DO:	DO NOT:
Behave professionally at all times	Use inappropriate verbal or body language
Respect children and listen to what they say	Act or speak in any way which might be threatening or harmful to a child
Be aware of all relevant policies and procedures	Form inappropriate relationships with Under 18s e.g. sexual, socialising, social media
Report any concerns to the DSL / authorities, as detailed in this document	Take / post online photos or videos of Under 18s without the express permission of the school management and of the parents / guardian
Always put the needs of children first when deciding on

CHILD PROTECTION

1. Child abuse is harming a child or through inaction, allowing a child to be harmed. Child abuse is not always physical and therefore the signs may not always be obvious. It is easy to assume that certain types of abuse associated with traditional face-to-face teaching do not apply in the online environment. However, in reality, the online platform merely facilitates the more conventional forms of abuse, although the signs may be less visible as the victim is not directly in front of you. It is therefore vital that all staff members are aware of and on the lookout for any potential incidences of child abuse while teaching online. The following paragraphs outline the main types of abuse and how to recognise them, starting with those that are most relevant to the online environment. Please note that the list of signs and symptoms is by no means exhaustive and it is impossible to predict how every child will react if they are the subject of abuse. It is important to remember that a child suffering from one category of abuse may well also display symptoms of other kinds of abuse. All staff must remember that they have a responsibility to treat any concern seriously and report it, regardless of whether they feel their suspicions are justified.
2. Online abuse – Using technology such as social media, online games or other forms of digital communication to facilitate abusive behaviour towards children. The most common types of online abuse are given in the paragraphs below:
3. Sexting  - pressurising a child to create and sexual images, videos or messages using technology. Once a child has shared the content, they have no control over how others use it. For instance, within peer groups it may cause bullying and lead to the individual becoming isolated. The content may also be exploited to blackmail or groom a child.
4. Emotional abuse – Making a child feel useless, unloved and not wanted through regular negative treatment e.g. ignoring the child, telling them they are useless or making fun of things they say and do. Such actions can leave the child feeling unsafe and frightened, particularly if they are being bullied. Symptoms of emotional abuse are often symptomatic of other kinds of abuse.

In the online environment, it can also include emotional blackmail whereby technology is used to pressurise children into agreeing to requests of a sexual nature.

Signs / Symptoms

• State of withdrawal; appears to have few friends and lack social skills
• Fear / anxiety of doing something wrong
• Extreme behaviour e.g. passive / aggressive
• Inappropriate behaviour for age i.e. adult-like (e.g. over-protective of other children, uses adult language or refers to adult situations when talking) or infant-like (e.g. tantrums, thumb-sucking)
• Appearance of isolation from parent / guardian etc.
• Signs of delayed emotional or intellectual development

5. Sexual abuse - Involving a child in any form of sexual activity, whether voluntary or forced. Here are some ‘non-contact’ examples which may occur online:

• Making a child watch sexual acts
• Producing images of child abuse or viewing or distributing them; or allowing others to do so
• Using a child to produce, view or share such images (for example sexual activity performed via the internet, sexting, making them watch pornography).
• Encouraging them to behave in sexually inappropriate ways
• Flashing at a child
• Making a child masturbate while others watch via webcam, smartphone etc.
• Failure to protect a child from exposure to sexual activity by others

Preparing children for sexual activity (‘grooming’) is illegal. Sexual abuse and grooming may happen in person or online. The abuser can be an adult or another child.  See also paragraph ‘7’ ‘Child sexual exploitation’.

6. Bullying – Repeatedly and deliberately hurting or making fun of another person. The bully has some ‘advantage’ over the person they are bullying, which they exploit. Online bullying is often called cyber bullying and includes:

• Sending messages which are intended to threaten, abuse or upset a child
• ‘Trolling’ – The posting of such messages on social media networks, chat rooms, online games etc.
• Excluding a child from online social groups or activities
• Producing and distributing embarrassing or malicious content
• Creating hate platforms about a particular child
• Voting for / against a particular child in an abusive poll
• Making a child embarrassed or causing trouble using their name e.g. via fake accounts, online identity theft
• Cyber bullying is often anonymous and can be ongoing.

Signs / Symptoms

• Reluctance to interact or spend time with certain people. The child may make an effort to avoid them completely. Online this might take the form of reluctance to be in a break room with these people or complete refusal to take part in the same lesson or activity
• Changes in behaviour – becoming withdrawn; unwillingness to mix with others where previously they had been part of an online group.
• Unhappiness when reading a message sent via text or online
• Frequent absence from lessons
• Poor attention in lessons

7. Child sexual exploitation (CSE) – The forced participation by adults of a child in sexual activity in return for something the child wants or needs e.g. a toy, food. Initially the adult(s) may show special interest in the child and give them gifts etc. As their hold over the child strengthens, the abuser refuses to give any more unless the child participates in sexual activity.

Signs / Symptoms

CSE is a form of sexual abuse and therefore many of the signs and symptoms are similar (See paragraph ‘e’). Additional signs to be aware of include:

• Unexplained gifts
• A much older boy- or girlfriend
• Frequent absence from lessons

In the online environment CSE may involve a child being coerced into:

• participating in conversations of a sexual nature e.g. via social media or text
• sharing sexually explicit photos / videos of themselves
• participating in sexual activities using technology e.g. a webcam or smartphone

Blackmail (in this case, threatening to share the sexually explicit content with a child’s friends or family) may be used to ensure they continue to participate in sexual activity. Explicit content may still be shared even when the abuse itself has stopped.

 

8. Other types of abuse – The following paragraphs give examples of other types of abuse. Some are  less common among language school students generally, while others are more likely to occur in a face-to-face environment. Nevertheless, staff should be aware of these as they may explain unusual behaviour during online lessons and activities.
9. Physical abuse – Acting in a way which causes physical harm to the child e.g. hitting, kicking, shaking, burning, forcing them to be ill etc. Whilst it is not possible for physical abuse to take place within the online environment, it is still possible for it to occur in the setting in which the child is situated e.g. their home.

Signs / Symptoms

• Frequent and / or unexplained injuries or bruises.
• Injuries that appear to have a pattern e.g. marks from a hand or belt
• Injuries in unusual places e.g. back, neck, buttocks, thighs, torso
• Over-dressing to cover up injuries e.g. a long-sleeved shirt worn on a hot day
• Constant state of alert, as if expecting something bad to happen
• Constant avoidance of any touch
• Flinching at sudden movements
• Fear of going home or spending time with particular individuals

10. Neglect - Not meeting a child’s basic needs, e.g. by denying them adequate food, clothing, or medical care, but also includes failing to protect children from danger or failing to provide adequate supervision.
11. Female Genital Mutilation (FGM) – The cutting or altering of a girl’s external genitals without any medical reason. This is illegal under UK Law. All staff members have a legal duty to report any case they become aware of to the DSL who must in turn inform the police.

Signs / Symptoms

• Long period(s) of absence from class
• Unusual behaviour upon their return to class
• Difficulty walking, standing and/or sitting
• Withdrawal, anxiety or depression
• Non-explicit requests for help

12. Child trafficking – Taking children from their home to another place where they are exploited, forced to work, or sold for sexual exploitation or benefit fraud purposes. Victims of child trafficking suffer multiple forms of child abuse (including physical, sexual and emotional violence, as well as physical and emotional neglect), which the perpetrator uses as a means of control.

Study is a legitimate reason for coming to the UK on a visa, but it can also be used by child traffickers as a means of getting children into the country. It is therefore our responsibility as a language school to check that all our students, and especially Under 18s, are travelling here to study and that they are attending their classes. Teaching staff can play their part by keeping accurate records of attendance and immediately reporting all absences of Under 18 students to reception.

Signs / Symptoms

Since victims of child trafficking are subject to other forms of abuse they may display some/any of the signs / symptoms mentioned in previous paragraphs. Additional signs to be aware of include:

• Substandard accommodation
• Reluctance to give details relating to accommodation or personal information
• Lack of knowledge relating to present location (town, city, country)
• Unexplained gifts or money
• ‘Housework’ taking up large amounts of time
• Little or no time for playing
• Little or no freedom to leave the house or their room
• No contact with parents / guardians
• Presence in locations normally inappropriate for children e.g. adult parties

13. Peer on peer abuse – Any form of abuse where the perpetrator is of the same or a similar age to the victim i.e. everyone involved is Under 18. This is just as unacceptable as adults abusing children and must be dealt with in the same way.
14. Inappropriate conduct of students in class or social activities – If a student behaves in an inappropriate manner to other students either in class or on a social activity organised by Lexis, the teacher / activity staff member must act immediately to ‘nip the problem in the bud’ i.e. they must tell the student that such behaviour is unacceptable.

MENTAL HEALTH & EMOTIONAL WELLBEING ONLINE

It is the responsibility of anyone working with Under 18s to promote their mental health and emotional wellbeing. Ways of doing this in an online environment include:

• Allowing time and space for children to open up and express any concerns they may have
• Playing games to take their mind off their worries
• Making online lessons and activities fun and stimulating
• Allowing regular breaks and opportunities for movement / exercise.
• Building and maintaining routines online

For more information and advice about promoting mental health and emotional wellbeing in children online , please visit the NSPCC website:

https://learning.nspcc.org.uk/child-health-development/promoting-mental-health-wellbeing#heading-top 

   

RECOGNISING THE DIFFERENCE BETWEEN A CONCERN AND A SERIOUS ISSUE

A concern is something that seems not to be right although there is no immediate danger to the child. With a serious issue on the other hand, the Under 18 could be in imminent danger of harm and abuse. Serious issues therefore require quick/urgent response.

RESPONDING TO CONCERN

All staff members have a duty to report any concerns they may have to the Designated Safeguarding Lead or relevant authorities. This applies whether the concern is reported to them by the child or another person, or they themselves suspect that abuse has taken place. It is not up to any staff member to decide whether allegations of abuse are substantiated. The fact that a concern has been raised requires the appropriate procedures to be followed.

When responding to concerns, it is useful to remember the four ‘R’s:

• Receive – Listen to the child, without judgement or over-reacting either positively or negatively.
• Reassure - Tell them they have done right to tell you and that you will only inform those who need to know.
• React – Report the concern to the Designated Safeguarding Lead.
• Record – Take brief notes at the time and write them up as soon as possible afterwards. Use the exact words the child tells you and stick to the facts.

Here in table format is a summary of how to respond to a possible concern:

DO:	DO NOT:
Stay calm	Panic
Tell them they have done right to inform you.	Ask leading questions
Listen to what is said without judgement	Try to get more information from the child
Tell them you will only inform those who need to know i.e. the Designated Lead and / or the relevant authorities.	Promise not to tell anyone
Take notes which accurately report what is said	Promise that everything will be ok now.
Ask open questions	Paraphrase or try to second-guess what they mean
Reassure them that they have done nothing wrong in telling you	Ask them to repeat what they’ve told you to another member of staff
Take immediate action in accordance with this policy.	Wait or think that the issue will ‘blow over’.
Report what you have been told to the DSL.	Try to deal with the matter yourself.
	Discuss the issue with anyone else (including colleagues) other than the DSL

 

If after reporting a concern to the DSL, staff feel that the issue is not being handled adequately, they can contact the Local Safeguarding Children Board (LSCB) for Barnet. Their contact details can be found by clicking on the following link:

https://www.barnet.gov.uk/directories/directme/barnet-safeguarding-children-board

Staff can also contact the NSPCC Helpline on 0808 800 5000.

 

RESPONDING TO SERIOUS ISSUES / ALLEGATIONS

1. The Designated Safeguarding team should :

• Check the child is safe
• Immediately inform the DSL or senior manager.
• Discuss with other Designated Safeguarding staff if the concern involves the DSL / senior manager.
• Ensure a written record is made by the person who made the allegation.

2. The DSL should then contact the LSCB for guidance. In most case they will direct the organisation to deal with the allegation. In more serious cases the police and/or children’s services may become involved and due process takes over.
3. Lexis has a duty of care to safeguard both Under 18s and their employees.
4. Therefore, Lexis will provide an employee facing an allegation with effective support and the matter will be dealt with quickly and fairly in accordance with our disciplinary procedure.
5. Suspension is not automatic but may be necessary if :

• Children are in danger of harm.
• The allegation is serious enough to potentially result in dismissal.

6. If suspension is deemed necessary:

• A named staff contact will support the employee facing investigation.
• The reason for suspension must be communicated within 24 hours.

 

RECORD KEEPING

Lexis keeps a single record of all safeguarding concerns/issues, which is accessible only by designated staff and if necessary, an official outside agency.

IDENTIFYING VULNERABLE STUDENTS

1. Some cultures will not disclose information about Special Educational Needs and Disability (SEND).
2. Staff members have the responsibility to pay attention to vulnerable students and not to confuse signs of abuse with SEND.
3. SEND students are more susceptible to grooming and abuse.

TRAINING

 

1. All staff members are given this policy as well as online Safeguarding training (Basic Level, formerly Level 1) during induction. This is enforced by face-to-face training during induction and regular revision.
2. The School Director has also completed Basic Level Safeguarding Training. In addition the Designated Safeguarding Leads (DSL) have completed Specialist Safeguarding for Designated Lead (formerly Level 3).
3. All other adults working with Lexis in the provision of online courses / activities are also expected to complete Basic Level online safeguarding training.

PREVENT – ANTI-RADICALISATION

1. ‘Prevent’ was introduced by the UK government to reduce the risk of people becoming radicalised or involved in extremism.
2. Everyone has the right to their own beliefs and opinions. However, if they seek to harm others as a means of achieving/enforcing their beliefs, this is extremism.
3. Extremism includes hatred or intolerance of others due to factors such as their race, gender, sexual orientation or religious beliefs.
4. All students (including Under 18s) at a language school may well be living in an unfamiliar environment or culture and therefore at risk of exposure to those who wish to encourage extreme views and behaviour such as acts of violence or terrorism. It is therefore a safeguarding issue and staff should report any concerns to the DSL.
5. All staff are given free online prevent training:

https://www.elearning.prevent.homeoffice.gov.uk/.

PARENTAL CONSENT

1. Parents / guardians of Under 18s are required to complete a Parental Consent Form when enrolling their children on a course of online study at Lexis. The following paragraphs detail the information required.
2. Student details – name, gender, date of birth, nationality, first language, passport number and expiry date
3. Parents’ / guardian’s details ( For each person) – name, relationship to child, first language, level of English, address, mobile phone number, email address.
4. Leisure activities – Permission to participate in general,.
5. Medical – Details of any known medical problems and medicine / treatment required. This is still necessary online in case a medical emergency occurs during an online class/activity where the parent / guardian is not present.
6. Attendance – Parents / guardians are informed that attendance of all scheduled online course lessons / activities is compulsory. If they wish their child to be absent at any time during the course, they must contact the school directly so that suitable arrangements can be made.
7. Photographs and video clips – Whether permission is given for images of the child to be taken, and whether the images can be used for publicity purposes.
8. Consent – Both the parent / guardian and student must sign the agreement to say that they have discussed the arrangements and rules and agree to the terms and conditions.

UNDER 18s IN ONLINE CLASSES

1. Under 18s will NOT be allowed to join adult online group classes. Instead they will be split into different age groups as follows:
2. 16 – 17 year olds
3. 12 – 15 year olds will be taught separately from those aged 16+, i.e. in their own junior class.
4. 5 – 11 year olds will only be taught in closed group classes or private lessons, and a parent/guardian must be present.
5. No mixing of the different age groups outlined above will be permitted
6. For more details, please see our Terms and Conditions
7. Students are placed in classes according to age, based on the criteria above and the information their parents/guardian provide when enrolling them in the school. If teachers subsequently find out that a student is in the wrong class for their age, they must report this immediately to the DoS, so that the student can be moved to the correct group.

UNDER 18s ON ONLINE SOCIAL ACTIVITIES

1. 16 – 17 year olds will be allowed to participate in certain adult online social activities, providing their parent / guardian has provided written consent for them to do so. In such cases, the parent / guardian will need to sign them in at the start of the activity.
2. Under 16s will not be allowed to participate in adult online activities, but will have their own separate activities. These will be ‘closed group’ i.e. no adults or over 16s will be allowed to join in.
3. All staff members leading or participating in online activities, in addition to basic safeguarding training, will be fully briefed on the programme for the activity and will have completed an individual risk assessment(s) that activity.​​​​​​​

​​​​​​​E- SAFETY

1. The very nature of an online course requires students to connect to the internet while in class via a laptop or other device. It is the responsibility of the class teacher to ensure that internet access during lessons is supervised and restricted to planned activities and that any sites and material accessed are age-appropriate.
2. The same conditions also apply outside class to staff-led online social activities. Please also see section 14 above.

​​​​​​​SAFER RECRUITMENT

1. Lexis School of English is committed to a safer recruiting policy. As such every effort is made to ensure that all prospective staff that are likely to come into contact with Under 18s through their work with Lexis are suitable to do so. This is not limited to actual staff members, but also includes homestays, group leaders, agents and transport providers.
2. Measures taken by the school include: DBS checks, interview questions, safeguarding training.
3. Delayed Suitability checks - Applicants who do not have a completed enhanced DBS check will not be able to work / be alone with Under 18s until a satisfactory disclosure has been received.