1. POLICY STATEMENT
a. 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.
b. 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.
c. Furthermore, safeguarding is the responsibility of everyone.
d. 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.
e. 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. This information is also available on the student noticeboard.
f. Under 18s themselves should look out for each other and raise concerns with adults if necessary.
g. This policy was last updated on 9th October 2019.
h. 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.
2. DESIGNATED SAFEGUARDING PERSONNEL
Designated Safeguarding Lead – Elena Logara-Panteli
In addition, the Director (Terry Panteli), Director of Studies (Steve Austin) and all Lexis teachers and other staff have completed at least Basic level Safeguarding.
3. CODE OF CONDUCT
a. 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.
b. 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).
c. Staff should avoid physical contact with Under 18s.
d. 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.
e. 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.
f. 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.
g. Staff should use appropriate language and actions when addressing Under 18s.
h. 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 e) above.
i. 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).
j. Socialising with Under 18s outside of school is not permitted, except during trips and activities arranged by the school. During these trips / activities, staff should continue to behave in an appropriate manner, just as they would on the school premises.
k. Staff should avoid alcohol and smoking.
l. Staff must not (by any means or in any circumstances) make, view or access illegal or inappropriate images of children.
m. 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.
The number for this is 0800 028 0285.
n. Here in table format is a summary of appropriate conduct when dealing with Under 18s:
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
Touch a child inappropriately. Where possible avoid all physical contact
Report any concerns to the DSL / authorities, as detailed in this document
Form inappropriate relationships with Under 18s e.g. sexual, socialising, social media
Always put the needs of children first
Take / post online photos or videos of Under 18s without the express permission of the school management and of the parents / guardian
4. CHILD PROTECTION
a. 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. The following paragraphs outline the main types of abuse and how to recognise them. 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.
b. 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.
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
c. 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.
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
d. 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.
e. Sexual abuse - Involving a child in any form of sexual activity, whether voluntary or forced. Here are some examples:
- Physical contact - penetration, masturbation, touching even if outside clothing
- Making a child watch sexual acts
- Using them to produce sexual imagery
- Encouraging them to behave in sexually inappropriate ways
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 ‘i’ ‘Child sexual exploitation’.
f. 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. It takes many forms, including:
- Actual physical harm or the threat to harm
- Use of insulting names or language in reference to someone
- Jokes made at someone’s expense
- Racist or sexual harassment
- Cyber bullying – Use of text, email and social media to make ‘bullying’ comments. It 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.
- Changes in behaviour – becoming withdrawn; unwillingness to mix with others where previously they had been part of a group.
- Unhappiness when reading a message sent via text or online
- Frequent absence from lessons
- Poor attention in lessons
g. Other types of abuse – The following paragraphs give examples of other types of abuse. Although less common among language school students, staff should nevertheless be aware of these.
h. 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
i. 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
j. 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
k. 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.
l. Inappropriate conduct of students in class on 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.
5. 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.
6. RESPONDING TO CONCERNS
a. 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.
b. 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.
c. Here in table format is a summary of how to respond to a possible concern:
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
d. 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
e. Staff can also contact the NSPCC Helpline on 0808 800 5000.
7. RESPONDING TO SERIOUS ISSUES / ALLEGATIONS
a. 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.
The DSL should then contact the LSCB for guidance. In most cases 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.
b. Lexis has a duty of care to safeguard both Under 18s and their employees.
c. 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.
d. 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.
e. 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.
8. 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.
9. IDENTIFYING VULNERABLE STUDENTS
a. Some cultures will not disclose information about Special Educational Needs and Disability (SEND).
b. Staff members have the responsibility to pay attention to vulnerable students and not to confuse signs of abuse with SEND.
c. SEND students are more susceptible to grooming and abuse.
a. 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.
b. The School Director and Director of Studies have also completed Basic Level Safeguarding Training. In addition the Designated Safeguarding Lead (DSL) has completed Specialist Safeguarding for Designated Lead (formerly Level 3).
c. All other adults working with Lexis (host families, group leaders, activity organisers etc.) are also expected to complete Basic Level online safeguarding training.
11. PREVENT – ANTI-RADICALISATION
a. ‘Prevent’ was introduced by the UK government to reduce the risk of people becoming radicalised or involved in extremism.
b. 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.
c. Extremism includes hatred or intolerance of others due to factors such as their race, gender, sexual orientation or religious beliefs.
d. 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.
e. All staff are given free online prevent training: https://www.elearning.prevent.homeoffice.gov.uk/.
12. SCHOOL VALUES
We promote the following values at Lexis School of English:
- Rule of Law
- Individual Liberty
- Mutual respect
- Tolerance of those of different faiths and beliefs
13. PARENTAL CONSENT
a. Parents / guardians of Under 18s are required to complete a Parental Consent Form when enrolling their children on a course of study at Lexis. The following paragraphs detail the information required.
b. Student details – name, gender, date of birth, nationality, first language, passport number and expiry date
c. Parents’ / guardian’s details ( For each person) – name, relationship to child, first language, level of English, address, mobile phone number, email address.
d. Travel – In general, permission for the child to travel to the UK and study at Lexis. Specifically, whether the child can travel unaccompanied to/from London at the start/end of their course, and between school/ their accommodation during their course. Arrival / departure information e.g flight details for individual travellers in case anything goes wrong.
e. Accommodation – Whether permission is given for Lexis to arrange accommodation for the child and confirmation that the child agrees to follow the ‘house rules’. If parents are arranging accommodation, details of responsible adult in the accommodation.
f. Leisure activities – Permission to participate in general, and which activities in particular.
g. Unsupervised time – Whether permission is given for this and the exact nature.
h. Medical – Details of any known medical problems and medicine / treatment required. Whether permission is given for Lexis staff to give non-prescription medication and arrange medical help if necessary.
i. Attendance – Parents / guardians are informed that attendance of all scheduled 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.
j. 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.
k. Long-stay students (3months +) – Details of family doctor in their country and whether permission is given to register the child with a GP in the UK
l. 16/17 year olds on adult courses – Parents / guardians are informed that their child will come into regular contact with over 18s during their course; they are responsible for buying their own lunch; they may be excluded from some age-restricted activities.
m. 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.
14. UNDER 18s IN CLASSES
a. 16 and 17 year olds will be allowed to join adult group classes if we are provided with parental/ guardian consent. Teachers will be informed by the DoS if a 16/17 year old is joining their class, and they will be highlighted on the register.
b. 12 – 15 year olds will be taught separately from those aged 16+, i.e. in their own junior class.
They will have minimal supervision outside of class times. Therefore they must be accompanied by a parent / guardian outside of class including travelling to/from Lexis.
c. 5 – 11 year olds will only be taught in closed group classes or private lessons. They must be accompanied by a parent or grandparent in class as a chaperone.
d. For more details, please see our Terms and Conditions
e. 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.
15. UNDER 18s ON SCHOOL TRIPS
a. The following maximum supervision ratios will be followed during off-site activities:
16-18 year olds – 1:15 (1 adult for up to 15 students, 2 adults for 16-30 students etc.)
12-15 year olds – 2:15 (2 adults for up to 15 students, 3 adults for 16 – 30 students).
b. Under 12s will not be allowed to participate in off-site activities, unless accompanied by their parent / legal guardian who will accept all responsibility for their safety.
c. All group leaders leading off-site activities, in addition to basic safeguarding training, will be fully briefed on the itinerary for the trip and will have completed individual risk assessment(s) for each activity.
16. E- SAFETY
a. Generally Lexis does not allow students to use their phones in class. However, as part of their course, students may at times need to go online, either via a school computer or their own 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.
b. The same conditions also apply outside class to staff-led activities such as trips.
17. SAFER RECRUITMENT
a. 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.
b. Measures taken by the school include: DBS checks, interview questions, safeguarding training.
c. 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.
17. ADDENDUM – 02/10/19
* Under 18s are required to report to reception when they arrive at school each morning and again when they leave at the end of the day. This is to enable reception staff to tick them off and be aware of who is in the building and any absences.
* The requirement to sign in applies to:
- 16-17 year olds throughout the year on adult courses (with parental consent).
- 12-15 year olds on Teen Summer courses, and in any closed group courses at other times of the year.
* If an Under 18 is more than 10 minutes late for class or fails to return after break, reception staff will attempt firstly to contact the student themselves. If reception staff are unable to get hold of the student, they will contact the student’s responsible adult in the UK and/or their parents/guardians.
* Teachers should inform reception immediately if an Under 18 is not present at the start of the lesson or after break.
* There is a 24-emergency contact telephone number, so that students or their parents / guardians can contact the school in the event of an emergency out of hours.
The number is: +44 (0) 7774 915050
This number is also printed on all International student ID cards.
* All Under 18s are required to wear their green lanyard containing their ID card at all times when on the school premises or on social activities organised by the school.
* If a student forgets to bring their lanyard and/or ID card to school, please inform reception staff immediately, so that we can issue a replacement.