91̽»¨

A. Policy statement, scope and purpose

1. Policy statement

a.  91̽»¨ (the University) is committed to ensuring the safety of everyone involved in its activities and aims to provide a safe environment for all students, apprentices and staff studying and working at the University and for all visitors to its facilities.

b. The University recognises that it has social, moral and legal obligations to safeguard the wellbeing and safety of children, young people and adults at risk involved in any University activities, whether these are conducted in person or online. 

c. It further believes that students, apprentices, staff and visitors to the University have the right to learn and work in a positive environment that is free from harm and all forms of harassment, discrimination and bullying.

d. This includes the University’s duty to safeguard children, young people and adults at risk, from harm and exploitation during the course of any activity relating to the University, irrespective of duration or location.

e. This Policy sets out the University’s responsibilities in ensuring the protection of these groups in accordance with Keeping Children Safe in Education 2024. This applies to all staff, students and volunteers (irrespective of whether they act in a paid or unpaid capacity), who may be working with children, young people or adults at risk of harm through the University’s teaching, research, accommodation provision or other activities, including outreach programmes.

f. It is expected that all staff will be aware, through effective communication of this Policy and associated training, of how to recognise and respond appropriately to safeguarding concerns.

g. Those with specific responsibilities as set out in this Policy are expected to have read and understood their responsibilities, to attend training, to ensure that appropriate records are kept relating to safeguarding matters and to ensure that local procedures/arrangements for meeting safeguarding responsibilities are kept up to date and are in line with this Policy.

h. Relevant legislation: The Policy is informed by a collection of legislation and guidance, including:

• Children Act 1989, 2004
• Data Protection Act 1998,
• Sexual Offences Act 2003,
• Safeguarding Vulnerable Groups Act 2006,
• Equality Act 2010,
• Protection of Freedoms Act 2012,
• Counter-Terrorism and Security Act 2015,
• Protecting Vulnerable Adults 2017
• Keeping Children Safe in Education 2024
• Care Act 2014

2. Scope

a. The University has a diverse staff, student, apprentice and visitor population. There are a variety of circumstances when children, young people and adults at risk may interact with staff and students of the University in the course of its activities. These include, but are not limited to:

• teaching, supervision and support of students 
• summer schools, school visits and other activities
• outreach or widening participation activities taking place on or off campus
• sport and physical activity 
• student accommodation
• research activities
• public events and conferences
• placements and other professional activities
• field trips, excursions and other volunteering activities

b. The University is responsible for ensuring appropriate policy, procedures, guidance, risk assessment, action planning and training are in place to facilitate effective safeguarding of children, young people and adults at risk. This includes ensuring it takes reasonable steps to ensure that contractors understand, accept and are responsible for their, or their employees’ conduct in connection with these groups on University premises.

3. Policy aims:

a. This Policy aims to ensure reasonable and effective steps are taken by the University to safeguard children, young people and adults at risk, both through the provision of a safe environment and through the provision of effective and supportive mechanisms for responding to safeguarding concerns, disclosures and allegations.

b. The Policy is designed to support the activities of the University involving children, young people and adults at risk and demonstrates that the University takes safeguarding seriously. The University will do so by taking the following actions:

• seeking to make the University a safe and welcoming environment for all that is free from harm and all forms of prejudice, harassment, discrimination and bullying
• giving all staff information, training and guidance about how to recognise potential harm when it has occurred, how to respond appropriately and how to report it
• making sure anyone can raise safeguarding concerns about any child, young person or adult at risk involved in the activities of the University
• ensuring that staff are suitable to act in their roles, through the provision of relevant checks (including DBS) and appropriate training
• ensuring there are staff with designated safeguarding responsibilities who are trained in responding to safeguarding concerns and disclosures and take survivor-focussed, trauma informed approach
• having an appropriate referral system in place for dealing appropriately and effectively with serious safeguarding incidents, including reporting to the relevant external organisations
• providing high quality, coordinated and accessible support services for students and staff

Through the execution of this policy, we will deliver the University's vision of fostering an ambitious, inclusive, collaborative community and both transform the lives of our graduates and shape the world we live in.

B. Safeguarding roles and responsibilities

1. Designated Safeguarding Roles

a. Designated Safeguarding Lead:  The University has a Designated Safeguarding Lead (DSL) who is responsible for ensuring legal and regulatory compliance and for ensuring this Policy is implemented.

b. The DSL has operational responsibility for ensuring that appropriate arrangements for keeping children and young people safe are in place at the University of 91̽»¨. The DSL reports directly to the Chief Operating Officer as the senior executive sponsor with overall responsibility for regulatory compliance on all matters relating to safeguarding and the Prevent Duty. The DSL chairs the Safeguarding and Prevent Steering and Operations Groups, which have oversight for the strategic and operational delivery of safeguarding and Prevent at the University respectively.

c. The DSL is the primary point of contact at the University with regard to safeguarding and Prevent, working closely with external local, regional and national partners relating to both individual case referrals and wider information sharing.  

d. Safeguarding and Prevent Key Contact: Key Contacts are senior staff in nominated roles who are responsible for ensuring that appropriate arrangements for keeping children and young people safe are in place at the University of 91̽»¨. Key contacts comprise the membership of the Safeguarding and Prevent Steering and Operations Groups in an ex-officio capacity, as determined by the DSL.

e. Safeguarding and Prevent Department/School Contact: Department/School Contacts are staff in nominated roles who are responsible for ensuring that the University’s arrangements for keeping children and young people safe are implemented at a department/school level. Working closely with the relevant Safeguarding and Prevent Key Contact, they act as the department/school point of contact for all safeguarding and Prevent related concerns and ensure that information and updates related to safeguarding and the Prevent Duty are disseminated to relevant staff in the department/school.

f. For full details of the responsibilities for each designated safeguarding role, a list of the nominated role holders, and the training role holders are required to undertake see the Safeguarding and Prevent Roles and Responsibilities Framework 

2. Safeguarding Governance

a. Safeguarding and Prevent Steering Group

The Safeguarding and Prevent Steering Group meets quarterly and is an advisory group reporting to the University’s Chief Operating Officer. 

The Group reports annually to Senate Education Committee, University Executive Board and Council to provide assurance to the University’s governing bodies that the institution is effectively discharging its duties and maintains compliance with regard to safeguarding and the Prevent Duty.

The Safeguarding and Prevent Steering Group provides strategic oversight of all matters relating to Safeguarding and Prevent and is responsible for the effective delivery of the overarching policies and procedures, and for ensuring that all identified risks are appropriately mitigated. 

The Group seeks to ensure the University’s compliance with legislation, regulation and guidance relating to Safeguarding and Prevent. 

b. Safeguarding and Prevent Operations Group

The Safeguarding and Prevent Operations Group is a subgroup of the Safeguarding and Prevent Steering Group. 

The Group provides operational oversight of matters relating to Safeguarding and Prevent and is responsible for supporting the effective delivery of the University’s policies and procedures, and for ensuring the mitigation of identified risks related to the operational delivery of safeguarding and Prevent matters. 

Through operational oversight, and through delivery against the Safeguarding and Prevent risk registers and action plans, the Group will ensure the University’s compliance with legislation, regulation and guidance relating to safeguarding and Prevent. 

c. Risk Assessment Panel

The Risk Assessment Panel is chaired by the Director of Student Services, or their nominee, and is convened where there are circumstances involving student(s) which warrant an evaluation of risk to the student(s) involved, the University community and/or the reputation of the University.

The Panel meets weekly and can consider cases relating to safeguarding concerns, Prevent concerns, Fitness to Practise concerns or reports of serious non-academic misconduct. 

The Risk Assessment Panel will continue to monitor and review cases until they reach their conclusion in line with the relevant procedure.    

d. Full details of each group can be found in the corresponding Terms of Reference:

• Safeguarding and Prevent Steering Group 
• Safeguarding and Prevent Operations Group 
•  (staff login required)

C. Safeguarding Procedures

1. Safeguarding Examples

a. The term "safeguarding" is used in a variety of different contexts inside and outside of the University. As such it is important to define what is included in the scope of this policy with regard to our usage of the term. Types of situations from which children, young people and adults at risk should be safeguarded include, but are not limited to, the following:

• financial exploitation
• sexual harassment, abuse or exploitation
• physical, emotional, psychological abuse
• recruitment to radical extremist organisations
• enticement into illegal activities
• domestic violence
• cyber abuse
• modern day slavery
• bullying or harassment
• forced marriage
• female genital mutilation
• discrimination
• data breaches

b. Identifying abuse or exploitation can be difficult, but there are a number of ways in which this might become apparent:

• disclosure of the abuse – self disclosure or disclosure by a third party. This might be full disclosure or that which raises suspicions of abuse
• signs of abuse, including physical injury for which there appears to be no satisfactory explanation
• particular behaviour that leads to a suspicion that someone is being or has been abused or exploited

c. It is not a staff member’s responsibility to decide whether a child, young person or adult at risk has been abused or harmed or subjected to abuse or harm, only to raise concerns that they may have.

2. Responding to safeguarding concerns relating to University staff, students or visitors

a. If someone is in immediate danger, the emergency services should be called without delay and before following the safeguarding procedure.

b. The safeguarding procedure should be followed whenever a concern is raised or a disclosure made that a child, young person or adult at risk who is involved in university activities may be a victim of abuse or exploitation.

c. Where any member of the University becomes aware of a possible safeguarding concern or receives a disclosure or an allegation, in line with the reporting procedures outlined in section 5 of this policy, they should:

• make a written record of all the relevant details: name, student number (if relevant), detail(s) of the person raising the concern, reasons for the cause for concern including any specific incidents, actions or observations
• contact the relevant Safeguarding and Prevent Key Contact/Safeguarding and Prevent Department/School Contact without delay and securely share the written record

d. The Safeguarding and Prevent Key Contact/Safeguarding and Prevent Department/School Contact will be responsible for responding to the concern at a local level and should usually:

• Where appropriate, meet with the person about whom the concerns have been raised, usually with an appropriate professional member of staff, in order to obtain their views of the situation (unless in exceptional circumstances where this is impossible or inappropriate)
• Inform the Designated Safeguarding Lead via the Safeguarding and Welfare Unit, who will assess the case and determine whether the concerns constitute a safeguarding issue and the appropriate next steps 
• Act as the key point of contact between the department/school and the Safeguarding and Welfare Unit
• In consultation with the Designated Safeguarding Lead reach a decision on what action is required appropriate to the person’s safeguarding needs and the situation, including referral to external agencies where appropriate
• Where deemed appropriate the Designated Safeguarding Lead may refer the case to the Risk Assessment Panel for further consideration.  

3. Responding to safeguarding concerns relating to children, young people or adults at risk who are not members of the University

a. If someone is in immediate danger, the emergency services should be called without delay and before following the safeguarding procedure.

b. The University engages in a range of activities which include children, young people and adults at risk who are not members of the University, for example; access and participation initiatives, commercial sport and physical activity, academic research and placements related to academic programmes. 

c. For some of these activities, it is likely that the Safeguarding Policy of another organisation may need to be followed

d. Where any member of the University staff or student becomes aware of a possible safeguarding concern or receives a disclosure in these circumstances they should:

• make a written report of all the relevant details: name, student number (if relevant), detail(s) of the person raising the concern, reasons for the cause for concern including any specific incidents, actions or observations 
• contact the relevant Safeguarding and Prevent Key Contact/Safeguarding and Prevent Department/School Contact without delay and securely share the written record

e. The Safeguarding and Prevent Key Contact/Safeguarding and Prevent Department/School Contact will be responsible for responding to the concern at a local level and should usually:

• respond to the concern, primarily in the first instance by referring the matter to the relevant organisation’s named contact (for example, by contacting the Safeguarding Lead of the school where this relates to a school visit at the University)
• Inform the University’s Designated Safeguarding Lead via the Safeguarding and Welfare Unit
• Act as the key point of contact between the department/school, the Safeguarding and Welfare Unit and the third party organisation 
• Where the organisation’s Safeguarding Lead cannot be contacted immediately, in consultation with the Designated Safeguarding Lead reach a decision as to whether the matter can wait or whether urgent action needs to be taken to safeguard the individual concerned 

4. Prevent Duty related safeguarding concerns

a. Prevent is a national programme that aims to stop people from becoming terrorists or supporting terrorism. It works to ensure that people who are susceptible to radicalisation are offered appropriate interventions, and communities are protected against radicalising influences.

b. The University is required to have due regard to the need to prevent people from being drawn into terrorism, known as the Prevent Duty.  

c. Prevent related safeguarding concerns should be responded to in the same way as any other safeguarding concern and must be referred to the Designated Safeguarding Lead via the Safeguarding and Welfare Hub.   

5. Reporting

a. The University is responsible for ensuring it maintains accurate records of safeguarding concerns, allegations and disclosures in accordance with the University Data Protection Policy. The Designated Safeguarding Lead is responsible for ensuring mechanisms for appropriate recording are in place and for (anonymised) reporting to the University’s Safeguarding and Prevent Steering Group, University Executive Board and Council. 

b. Safeguarding concerns, allegations and disclosures are treated in confidence and processed in line with the University’s Data Protection Policy.

c. Any staff member who makes a written record of a safeguarding concern must ensure that this record is appropriately disposed of once it has been shared onwards to ensure the management of data security. Localised records should not be kept.

d. To ensure the safety and welfare of all children, young people and adults at risk, information is shared with organisations who will be involved in addressing the safeguarding concern (this may include other educational organisations, the local authority, the police). 

e. Every effort will be made to gain the consent of the individual prior to sharing information but information may be shared without consent where there is good reason to do so. The child, young person or adult at risk should be advised that the information will be shared with those who will address the concern. The University’s record will include who has been given the information and why.