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Safeguarding Policy

Duty of Care

PLG will take reasonable steps to ensure the safety and wellbeing of all learners.   


PLG will ensure that suitable policies and processes are in place to cover learner safety and welfare while on  training venue premises during normal training hours this includes working on employer premises whilst  undertaking an apprenticeship programme. Learners are advised of the fire drill and procedures as well as  domestics at the start of each training programme or employment with their apprenticeship employer.  Learners are made aware that they have a responsibility for their own safety and the safety of others while  attending training or at work.  


For classroom-based learning and courses, learners must register with the course trainer on arrival at the  training venue each day. Learners must not leave the training venue during training hours without permission.  


  • Learners must abide by training venue rules and regulations  
  • Any learner feeling unwell while at a training venue will report immediately to their trainer and if  necessary, will be referred to a doctor or sent to hospital.  
  • All medical conditions will be treated in the strictest confidence.   
  • Employers and parents/guardians (if suitable) will be informed of learners who are unwell whilst attending  a training venue  
  • All absence will be logged on learner contact logs  
  • Learners must abide by the code of conduct issued to them.   

Safeguarding Definition

The term safeguarding describes the broader preventative and precautionary approach to planning and  procedures that are necessary to be in place to protect children, young people, and adults at risk from any  potential harm or damage.  


PLG has adopted a whole organisational approach to Safeguarding and is committed to fulfilling its  responsibilities and promoting the welfare of all learners and ensuring that their safety and well-being is a  priority.  


All learners have a right to feel safe and protected whilst using PLG services and in turn PLG has an obligation  to ensure their safety and protection.   


It is important to note that employees or associates of PLG are not responsible for deciding whether learners  have been abused. Employees are responsible for recording and reporting any concerns to the Designated  Safeguarding Officer, in a timely manner to ensure we are working together to safeguard learners under  arrangements in place within this policy and set down by the Local Safeguarding Children Board (LSCB).  

Policy Statement

PLG safeguarding policy governs the safeguarding of learners physical and mental wellbeing and safety.  


PLG recognises that All staff have responsibility with regards to safeguarding and promoting the welfare of  learners.  


Child Protection focuses on recognising abuse and neglect and acting on it, whereas Safeguarding looks at  keeping young people and adults at risk safe from a much wider range of potential harmful influences and  looks at preventative action rather than just reaction.  


The Children Act 2004 places new duties on organisations and provides them with additional powers including  a requirement to co-operate with the Children’s Services Authority, to make arrangements to safeguard and  promote welfare, to share information where necessary and appropriate with the Local Safeguarding  Children’s Boards. Within the definition of the law, this policy determines children as being all persons under  the age of eighteen.  


This policy sets out PLG’s commitment to Safeguarding arrangements and provides a clear framework for all  employees in fulfilling that obligation. The policy aims to reassure and protect employees or associates of PLG  who work in an environment where we promote the welfare of all learners and will also detail the skills  required to identify potential abuse and how to record and report it.   


This Policy will be reviewed on an on-going basis in accordance with changes to legislation or newly identified  good practice. The formal review and on-going development of the policy will be led by the Designated  Safeguarding Officer and the PLG board.   


This policy recognises that Radicalisation and Extremism are safeguarding issues and manages the handling of  such referrals relating to the prevent duty through the processes outlined within this policy. The management  of the Prevent Duty is undertaken through a risk-based approach and because of this PLG’s management of  the prevent duty incorporates a regularly updated risk assessment and subsequent action plan. 

Staff Training and Development

All staff undertake annual refresher training surrounding their responsibilities regarding the recognition and  referral of safeguarding & Prevent occurrences. This training is undertaken when a staff member joins PLG  and is updated annually around the anniversary of employment with PLG.  


In addition to this both the Designated Safeguarding Officer and the Deputy Designated Safeguarding Officer  hold formal qualifications in Safeguarding and Prevent in addition to undertaking annual refresher training in  both topics.  


Alongside these training and development opportunities, Safeguarding & Prevent are regular agenda items at  team meetings where any changes in policies, processes and procedures are communicated out to the team.  These ongoing training and development opportunities alongside consistent discussion regarding policy  updates through team meetings allow for PLG to gain commitment from all its employees regarding the  importance of these topics within any education setting. Ongoing learner review processes which include a  different Safeguarding and Prevent topic each month allows for the ongoing commitment from learners,  employers, and staff to be managed throughout the learner journey with PLG.   

Extremism & Radicalisation – The Prevent Duty

This policy is designed in line with the requirements of Section 26(1) of the Counter-Terrorism and Security  Act 2015 and the duty this act imposes on independent learning providers to prevent individuals from being  drawn into terrorism both violent and non-violent in nature. This policy states how PLG aims to achieve this  through a robust referral process should prevent issues arise but also to reduce the opportunities which  extremists have, to influence and exploit.  


Radicalisation is defined as the act or process of making or encouraging a person or group of persons to  display extreme behaviour whether this be in relation to political, economic, or social views and opinions.  


Extremism is defined as the holding and displaying of extreme political or religious views.  


It is the aim of PLG as defined through this policy and those policies linked to this policy, to be fully committed  to the safeguarding and promoting of welfare to all learners and staff and we recognise that the safeguarding  against extremism and radicalisation is no different from the safeguarding of any other vulnerability.  


It is the aim of this policy to ensure that staff are fully engaged and made responsible in being vigilant about  radicalisation; that they overcome professional disbelief that such issues will not happen within PLG and  ensure that we work alongside other professional and regulatory bodies and agencies to ensure that our  learners are safe from harm.  


This policy is design to prevent and protect apprentices and employees from radicalising influences and to  ensure apprentices and employees are resilient to extremist views and narratives. 

Prevent Objectives

All staff members, trainers and non-training staff will understand what radicalisation and extremism are and  why we need to be vigilant throughout all our work activities.  


All staff members, trainers and non-training staff will know what this policy states regarding anti-radicalisation  and extremism and will follow the policy when issues arise.    


All Learners will know that this policy is in place to keep learners safe from harm and that PLG regularly  reviews its systems and processes to ensure they are appropriate and effective.    


The design of all programmes offered by PLG promote respect, tolerance, promotion of equality and valuing  of diversity, and recognition and promotion of Fundamental British Values as part of our curriculum design  processes. Learners are encouraged to share their views and recognise that they are entitled to have their  own different beliefs or be of no faith, which should not be used to influence others.    


It is the responsibility of all staff to challenge unacceptable behaviour. 


It is recognised that learners with low aspirations are more vulnerable to radicalisation and therefore we  strive to develop our learners with confidence, self-belief, respect, and tolerance as well as setting high  standards and expectations for themselves.    


Learners are regularly taught about how to stay safe when using the Internet and are encouraged to recognise  that people are not always who they say they are online.       

Mental Health

Delivery staff should be aware that mental health problems can be an indication, in some cases, that a child or  at-risk adult is subject to abuse, neglect or exploitation.   


If staff have a mental health concern about an individual that is also a safeguarding concern, immediate action  should be taken, following the steps set out in this policy.  


PLG are ambassadors for the “Burnt Chef Project” which aims to support individuals working in Hospitality,  raise awareness of and reduce the stigma surrounding issues relating to mental health within the Hospitality  industry.  

Management of Safeguarding

All PLG Staff have a collective responsibility for the safeguarding of learners when in any PLG or work-based  training premises.  Learners are informed about safeguarding during induction and this is embedded  throughout the “learner journey”, continually raising awareness through progress review processes and  learner discussions. PLG regularly assesses learners’ awareness of Safeguarding through our ongoing learner  review processes and different topics relating to Safeguard, such as those stated below form the foundation  of these discussions via our ‘Let’s Talk’ resources.  


PLG also utilises a Virtual Learning Environment which hosts several support documents which learners can  access at any point during or after their programme to seek support and information regarding Safeguarding  issues.  


The DSL or appropriate person will provide access to appropriate safeguarding support/counselling for all PLG  staff members where this is required or identified as being something of value. PLG does this through its  partnerships with external bodies and health care providers. 

Learners in work placement companies

 Safeguarding is embedded as part of our placement vetting processes raising awareness of the importance of  Safeguarding with employers.  


The Safeguarding of learners in placement companies is reviewed during each formal review by delivery staff,  or more frequently if necessary.  


We also recognise our responsibility in ensuring that any of our learners who may encounter vulnerable  groups during work placements will also require appropriate checks prior to their work placement.   

Photographing Learners

All persons wishing to record any images of learners, for example to use at events must gain the necessary  consent.  Employees will challenge any persons acting suspiciously and recording images of learners without  consent.  


With advances in technology, especially with mobile phones being able to record and transmit images,  employees must be extra vigilant. Staff should challenge any persons using recording equipment without  consent.  


Images of Children/Young People should not be used to promote PLG without the express permission of the  parent or guardian.    

Administering First Aid to Learners

 If Staff are required to administer first aid to any learners, either as the result of abuse or as just the result of  an accident, staff should observe the following guidelines:  


  • Where possible two staff should be present.  
  • The staff, where possible, be a gender mix of male/female.  
  • Wherever possible, staff of the same gender as the injured learner should administer any first aid  required, however this should not prevent administering first aid if the same gender is not available in  any emergency.  


In certain circumstances the provision of first aid must be immediate and it may not be possible to comply  with all the above guidelines. In these circumstances, employees must remain vigilant and protect themselves  from any allegations of inappropriate behaviour. 

Staff Code of Professional Conduct

 It is recognised that staff may sometimes be victims of false or malicious allegations of learner abuse. All  allegations of abuse must be taken seriously. This will require that each allegation will be investigated in line  with PLG’s Safeguarding Policy and Procedures.  


All staff should clearly understand the need to maintain appropriate boundaries in their dealings with  learners. Intimate or sexual relationships between staff and learners may be regarded as a breach of  professional conduct. Employees need to re-examine their approaches to individual learners that they do not  give any grounds for doubt or suspicion on the part of learners or colleagues.  


Staff should take care that their relationships with learners reflects the age, gender, and maturity of the  learner. It is particularly important that all aspects of demeanour, language and attitudes do not give rise to  misunderstandings. Ambiguous or ambivalent comments and conduct should be avoided.  

Operational

All staff have a responsibility to Recognise, Respond, Report, Record and Refer any abuse whilst engaged on PLG  business, and must immediately report any concerns about learners’ welfare to the designated person.  


In all instances, the reporting of suspicions or incidents must be kept confidential. All reports will contain sensitive data and are subject to the Data Protection Act and GDPR regulations. 


It is considered good practice to inform any persons that you intend to refer their conduct or actions to Social  Services. However, the following exceptions apply: -  


• If sexual abuse is suspected within the family  

• If there is evidence of fabricated or induced illness  

• If to do so would place the child in more danger  

• If to do so would place the staff member in danger  


Anyone wishing to report concerns will also be protected through the “Whistle Blowing Policy”    

Observing Signs and Symptoms

If through observation or interaction with a learner, you suspect that abuse may be occurring, you must report your concerns to the Designated Person.  If necessary, the Designated Person will contact the Police, LADO or Child Protection Helpline for advice.  


For further guidance on signs and symptoms see Annex 1  

Disclosure

 All disclosures made by learners must be treated seriously and whilst the sensitivity and confidentiality of the situation should be respected, such disclosures should be reported immediately using the established reporting procedure.  If you are informed of a concern by another learner, employee, or colleague, you must act in accordance with the reporting procedure.   

Intervention

If during an investigation, you observe abuse taking place, intervention may be required to protect and safeguard the learner.  


Intervention is defined as being any direct action which is taken to safeguard learners which is over and above observing the suspect or merely completing the appropriate paperwork.  


Intervention will only occur once surveillance of the suspect has confirmed the need for direct action.  


Any intervening action should be taken with extreme caution.  


If intervention is required, it will be in response to an obvious incident e.g., a physical assault on a learner. The nature of the incident will dictate the response and action.  


Where possible the Police should be summoned to intervene. However, if a delay would place the learner in further danger, staff should take appropriate action. Anyone intervening must not place themselves at risk and must only use “reasonable force” as a last resort.  


Once appropriate action has been taken, the incident must be immediately reported to Senior Management,  the Police, Social Services or the Child Protection Helpline and the Designated Person.  


In appropriate cases, where it is safe to do so, the individual concerned should be made aware that their conduct or actions are unacceptable and are giving cause for concern.  


Do not attempt to detain the individual or get involved in any physical contact. 

Preventing unsuitable people from working with Vulnerable Learners.

PLG operates safe recruitment practices including ensuring enhanced DBS, and reference checks are undertaken upon recruitment and within the probationary period of 12 weeks. All associated staff members will need to provide an up-to-date DBS check which has been completed within the last 3 years.  


PLG will identify at the recruitment stage the level or requirement of DBS disclosure for each of its posts.  Where required an acceptable DBS check will be a condition of employment.  


PLG will also carry out additional online searches as part of the shortlisting process to help identify any incidences or occurrences which may wish to be explored and discussed further with applicants at interview stage.  


PLG will contact the relevant bodies in the event of an allegation being made against a member of staff and adhere to the safeguarding protocols as set out by this document. This includes making a referral to DBS via the gov.uk website where this is required either when dealing with an issue relating to a member of staff or those applying for positions with PLG.  


PLG will ensure that any disciplinary proceedings against staff relating to Safeguarding matters are concluded in full even when the member of staff is no longer employed, and that notification of any concerns is made to the relevant authorities and professional bodies and included in references where applicable.   


PLG will ensure that all staff, volunteers, and agency workers are aware of the need for maintaining appropriate and professional boundaries in their relationships with vulnerable learners, parents, guardians,  and carers.   


PLG will ensure that all staff, volunteers, and agency workers are aware that any sexual relationships with vulnerable learners are improper and could result in legal proceedings taken against them under the Sexual  Offences Act 2003 (Abuse of position of trust).  


PLG will ensure that all staff and volunteers are aware of the need for maintaining appropriate and professional boundaries in their relationships with young people, parents, and guardians.   


All staff and volunteers are aware that disclosure will be made to third parties where required and that they will be required to cooperate with any subsequent enquiry or investigation. 

Keeping safe online

The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation: technology often provides the platform that facilitates harm. An effective approach to online safety empowers a training provider to protect and educate the entire provider community in their use of technology and establishes mechanisms to identify, intervene in, and escalate any incident where appropriate.   


The breadth of issues classified within online safety is considerable, but can be categorised into three areas of  risk:   


• content: being exposed to illegal, inappropriate, or harmful material; for example, pornography, fake news,  racist or radical and extremist views.   

• contact: being subjected to harmful online interaction with other users; for example, commercial advertising  as well as adults posing as children or young adults; and   

• conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making,  sending, and receiving explicit images, or online bullying.   


To effectively manage and promote online safety to all its learners, PLG undertakes a process of education around potential issues and the warning signs of what to look out for. This is achieved through detailed induction processes which are completed with all learners as well as ongoing discussion using the ‘Let’s Talk’  which further educates and facilitates discussions around how to stay safe online. 

Monitoring & Filtering IT Usage

For PLG to effectively support its staff and learners it’s important that correct usage of IT is implemented and monitored. For this to take place PLG has a strict code of conduct for communicating with learners and the use of IT and Technology.  


All PLG employees are issued with an ‘@plgrp.co.uk’ email address upon joining the company and this email address is the only email address which is permitted to contact learners directly. In addition to this,  employees are issued with a company mobile phone which is permitted for use between learners and employers when communicating. Any non-email communication (WhatsApp etc) must only be undertaken using company mobile phones, this includes learner forums and WhatsApp group for sharing discussion points with learner cohorts.  


PLG also utilises its Virtual Learning Environment when communicating with learners, allowing for all communication to be traced and audited should further investigation surrounding Safeguarding concerns be required.  


PLG learners are work-based and complete their apprenticeship programmes on their own personal devices.  Therefore, the safe use of internet resources is covered through robust induction processes and ongoing discussion through the ‘Let’s Talk’ resources. It is not possible to filter internet content accessed on personal  devices and therefore the stance of PLG is to educate learners around the dangers of not staying safe online. 

Reporting Procedures

 All potential or suspected issues must be recorded using the PLG Safeguarding referral form (PLG051). This form must be completed in as much detail as possible recording all information obtained and sent over to the  Designated Safeguarding Officer (or Deputy) within 12 hours of the issue being identified.  


The Designated Safeguarding Officer within PLG is as follows:  


Andy Tait – Quality Director  

Email: safeguarding@plgrp.co.uk   

Contact: 07545537971  


Should the DSL be on leave from work the completed form will be actioned by Barry McNamara who is the organisations deputy safeguarding lead.  


The DSL will acknowledge receipt of the form within 12 hours and inform of the next steps or take over the referral action plan if necessary. 

Learners Reporting Procedures

PLG recognises the importance of learners being able to directly contact the Safeguarding team at PLG should this be required. Learners must have the ability to report safeguarding concerns without having to contact their trainer, this could be for a number of reasons but includes reporting a Safeguarding concern against their trainer.  


All learners are given the contact details of the Safeguarding team during their induction to the apprenticeship programme and should a report be logged by a learner the above procedure for handling and following up on reports remains the same.  

Record keeping and Governance

 All records relating to safeguarding referrals are held by the Designated Safeguarding Officer on a Secure  Server with restricted access to all other personnel in line with the General Data Protection Regulations 2018.  Where necessary and appropriate a brief and redacted overview of referrals are included in board meetings to provide assurance to the board of Directors and Governors that a safeguarding culture is adequately and robustly developed within the organisation. 

Roles and Responsibilities of Individuals in Handling Disclosures

Staff:  


• Recognise signs of abuse, neglect, exploitation, radicalisation, mental health concerns and contextual safeguarding risks.  

• Record the disclosure as soon as possible, ideally on the same working day.  • Use the learner’s own words wherever possible.  

• Include:  

                 o Date, time and location of disclosure  

                 o Names of those present  

                 o A factual account of what was said  

                 o Any visible injuries (without interpretation)  

                 o Immediate actions taken  

• Sign and date the record.  

• Submit the concern immediately to safeguarding@plgrp.co.uk   

• Contact emergency services (999) if a learner is in immediate danger, then inform the DSL without delay.  


Designated Safeguarding Lead:  


• Review the concern immediately.  

• Assess risk in line with local safeguarding partnership thresholds.  

• Clarify information where necessary (without investigating).  

• Determine appropriate action, which may include:  

                 o Early Help intervention  

                 o Referral to Children’s Social Care   

                 o Referral to Police  

                 o Prevent/Channel referral  

                 o Adult safeguarding referral (where appropriate)  

• Make referrals promptly and within statutory timeframes.  

• Record the rationale for all decisions, including decisions not to refer.  


The DSL must:  


• Report allegations against staff to the Head of Organisation immediately.  

• Ensure the Local Authority Designated Officer (LADO) is contacted within one working day.  

• Assess and manage risk where concerns relate to an employer or workplace supervisor.  

• Consider suspension of placement if required to safeguard the learner.  

• Maintain confidentiality and ensure fair process  

• Maintain secure, confidential safeguarding records.  

• Keep clear chronologies of concerns.  

• Ensure appropriate information sharing in line with statutory guidance.  

• Transfer safeguarding files securely when a learner leaves.  

• Monitor patterns and trends in safeguarding concerns.  

• Act as the main point of contact for safeguarding partners.  

• Attend strategy meetings and case conferences.  

• Contribute to multi-agency safeguarding arrangements.   

• Escalate concerns where professional challenge is required.  


Governors must ensure:  


• Safeguarding policies comply with KCSIE 2025 and are reviewed at least annually.  

• A suitably trained DSL and Deputy DSL(s) are appointed.  

• Safeguarding has sufficient resource and priority.  

• Safer recruitment procedures are implemented.  

• Appropriate training is provided to all staff.  

• Safeguarding arrangements extend to subcontractors and employers.  

• Prevent duty requirements are met.  

• Online safety is effectively managed.  


Governors must:  


• Receive regular anonymised safeguarding reports.  

• Monitor:  

                 o Number and types of disclosures  

                 o Referral rates and outcomes  

                 o Timeliness of action  

                 o Emerging risks and trends  

• Seek assurance that safeguarding practice is effective in reality, not just in policy.  

• Provide appropriate challenge and support to senior leaders.  

• Ensure lessons learned from cases are embedded into practice. 

A multi-agency approach to Safeguarding

PLG is committed to developing relationships with external partners and agencies in order to work together to safeguard children and vulnerable adults.  


In accordance with statutory guidance, any allegation that a member of staff, supply staff, subcontractor,  volunteer or employer representative may have behaved in a way that has harmed, or may have harmed, a child or vulnerable adult will be referred to the appropriate regional Local Authority Designated Officer  (LADO) within one working day. We will act in line with LADO advice and fully cooperate with any strategy meetings, investigations or actions required.  


The Designated Safeguarding Lead (DSL) acts as the organisation’s lead professional for multi-agency  safeguarding and will establish and maintain effective working relationships with:  


• Local Safeguarding Children Partnerships  

• Adult Safeguarding Boards  

• Children’s Social Care  

• Police  

• Prevent/Channel panels  

• Health and Early Help services  

• Employer safeguarding representatives (where applicable) 


We are committed to proactive information sharing, lawful and proportionate in line with data protection legislation, where it is necessary to safeguard and promote welfare. The welfare of the child or vulnerable adult will always be the paramount consideration.  Through strong multi-agency collaboration, the organisation seeks to ensure early identification of risk, timely intervention and coordinated support that protects learners from harm and promotes their safety and wellbeing.  

Related Legislation

The Safeguarding Policy affirms its commitment to the current and any subsequent enacted legislation governing safeguarding adults, the following list is not exhaustive: -  


• Human Rights Act 1998  

• Equality Act 2010  

• Sexual Offences Act 2003  

• Protection of Children Act 1999  

• Criminal Justice and Court Act 2000  

• Safeguarding of Vulnerable Groups Act 2006   

• Rehabilitation of Offenders Act Exceptions Order 1974  

• Counter-Terrorism and Security Act 2015  

• Working together to safeguard children 2023  

Honour-based violence inc. Female Genital Mutilation

So-called ‘honour-based’ violence (HBV) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM),  forced marriage, and practices such as breast ironing. Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators.   


It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take. All forms of HBV are abuse (regardless of the motivation) and should be handled and escalated as such.  


Any trainer who suspects or is made aware of an act of Female Genital Mutilation (FGM), in addition to the referral to the DSL the Police must also be informed.  

Forced marriage

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered without the full and free consent of one or both parties and where violence, threats or any other form of threat is used to cause a person to enter a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some perpetrators use perceived cultural practices to coerce a person into marriage.   

Up skirting

‘Up skirting’ typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation,  distress, or alarm.   


It is now a criminal offence.  

County Lines

Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity, drug networks or gangs that groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market, and seaside towns. Key to identifying potential involvement in county lines are missing episodes when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered.   

Homelessness

Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare. The designated safeguarding lead (and any deputies) should be aware of contact details and referral routes into the Local  Housing Authority so they can raise/progress concerns at the earliest opportunity. Indicators that a family may be at risk of homelessness include household debt, rent arrears, domestic abuse, and anti-social behaviour, as well as the family being asked to leave a property. Whilst referrals and/or discussion with the  Local Housing Authority should be progressed as appropriate, and in accordance with local procedures, this does not, and should not, replace a referral into children’s social care where a child has been harmed or is at risk of harm.   


The Homelessness Reduction Act 2017 places a new legal duty on English councils so that everyone who is homeless or at risk of homelessness will have access to meaningful help including an assessment of their needs and circumstances, the development of a personalised housing plan, and work to help them retain their accommodation or find a new place to live. The new duties shift focus to early intervention and encourage those at risk to seek support as soon as possible before they are facing a homelessness crisis. In most cases  school and college staff will be considering homelessness in the context of children who live with their families, and intervention will be on that basis. However, it should also be recognised in some cases 16- and  17-year-olds could be living independently from their parents or guardians, for example through their exclusion from the family home, and will require a different level of intervention and support.  

Peer on Peer abuse and Sexual Harassment

 Children can abuse other children. This is generally referred to as peer-on-peer abuse and can take many forms. This can include (but is not limited to): bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals as well as sharing of nude/semi-nude photos and videos which is illegal. PLG operates a zero-tolerance policy for any kind of peer-on-peer abuse and all staff should recognise and be aware of the signs of abuse and follow the safeguarding processes outlined above should they have concerns about any kind of abuse taking place either within or outside of the delivery setting. 

Child Criminal Exploitation (CCE)

CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity in exchange for something the victim needs or wants. The victim may have been criminally exploited even if the activity appears consensual.   


CCE does not always involve physical contact; it can also occur using technology, which is something which all staff should be aware of and look out for throughout their delivery. CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country, forced to shoplift or pickpocket, or to threaten other young people.   


Some of the following can be indicators of CCE:   


• children who appear with unexplained gifts or new possessions.   

• children who associate with other young people involved in exploitation.   

• children who suffer from changes in emotional well-being.   

• children who misuse drugs and alcohol.   

• children who go missing for periods of time or regularly come home late  

• children who regularly miss school or education or do not take part in education.  It is important to recognise that the experiences of girls and boys may be different and as such the indicators of CCE for girls and boys is different. 

Child Sexual Exploitation (CSE)

CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity in exchange for something the victim needs or wants. The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact; it can also occur using technology.  


CSE can affect any child or young person (male or female) under the age of 18 years, including 16- and 17-year-olds who can legally consent to have sex. It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity and may occur without the child or young person’s immediate knowledge (e.g., through others copying videos or images they have created and posted on social media).   


The above CCE indicators can also be indicators of CSE, as can:  


• children who have older boyfriends or girlfriends  

• children who suffer from sexually transmitted infections or become pregnant.  

Domestic abuse and violence

 The cross-government definition of domestic violence and abuse is any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence, or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass but is not limited to psychological; physical; sexual; financial; and emotional including where individuals see, hear, or experience its effects directly. All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.  

LGBT Children

The fact that a child identifies as LGBT is not a risk factor itself, however, can lead to these individuals being  targeted by other children or groups. In some cases, these children who are perceived to belong to an LGBT  group can be just as vulnerable as those who identify as LGBT. These trainers and support staff should work to reduce the barriers in communication between LGBT children and the organisation. LGBT inclusion is a mandatory requirement and the organisation endeavours to promote accessibility and inclusion for these groups and aims to eradicate any homophobic, transphobic or biphobic bullying and abuse.  

Policy Reviewing

This policy is reviewed and updated annually. This policy is next due for review in September 2026.  


Reviews and updates take account of changes in legislation and any updates to statutory guidance.  


This version of the PLG Safeguarding & Prevent Policy has been reviewed in line with Keeping Children Safe in  Education 2025 and the Prevent Duty 2025. 

Performance Learning Group LTD

Copyright © 2023 All Rights Reserved.

 Company registered in England and Wales: number 09618299. 

Registered office: 5 Ducketts Wharf, South Street, Bishop’s Stortford, Hertfordshire, CM23 3AR 

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