Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
DIRECTORY
POLICY STATEMENT .......................................................................................4
ACKNOWLEDGEMENT BY HOST FAMILY .........................................................4
DEFINITIONS ..................................................................................................9
PROCEDURES ...............................................................................................16
ROLE OF DSL AND DDSL................................................................................25
PREVENT ......................................................................................................27
RECORD KEEPTING .......................................................................................27
TRAINING AND UPDATES..............................................................................28
DSL AND DDSL..............................................................................................28
WHISTLEBLOWING .......................................................................................28
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
MENTAL HEALTH ..........................................................................................32
UPSKIRTING .................................................................................................36
SERIOUS VIOLENCE.......................................................................................37
COUNTY LINES ............................................................................................37
CYBERCRIME ................................................................................................39
DOMESTIC ABUSE.........................................................................................41
ONLINE SAFETY ............................................................................................42
REVIEW ........................................................................................................42
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Compass Culture and Education Ltd.
Safeguarding and Child Protection Policy
POLICY STATEMENT
Compass Culture and Education recognise our moral and statutory responsibility to safeguard and
promote the welfare of all children. We acknowledge that “it could happen here”. We make every
effort to ensure that students and adults feel safe, secure, valued and respected, and feel confident
to talk if they are worried, believing they will be effectively listened to.
The purpose of this policy is to provide staff, volunteers and homestays with the framework they
need in order to keep children safe and secure whilst they are in our care. The policy also informs
parents, agents and partner schools how we will safeguard their children whilst they are in our care.
This policy is based on guidance from the most recent versions of KCSIE and Working Together to
Safeguard Children. It also makes use of guidance from the NSPCC website.
KEY SAFEGUARDING CONTACT DETAILS
Role
Name
Tina Liu
Telephone Number
07405 844 198
Email
Designated Safeguarding Lead (DSL)
Deputy Designated Safeguarding Lead (DDSL)
24-Hour emergency contact
Jessie Chang
Lucy Jin
07404 846 230
07912 847 858
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
CHILD PROTECTION PRINCIPLES
The following principles underpin our provisions and practices in relation to safeguarding and child
protection:
Compass Culture and Education will provide a safe and secure environment for all
students;
Homestays and transfer companies provide a safe and secure environment for all
students;
All students feel safe, secure and protected from harm;
All students know who to turn to for help, advice or support, can access services
confidentially, quickly and easily and have access to 24-hour support;
The company director of the company has overall responsibility and accountability for the
safeguarding and welfare of the students;
All staff, homestays and volunteers share in the responsibility to protect students from
harm, remain vigilant in identifying safeguarding and child protection issues and to follow
policies and procedures relating to safeguarding and child protection;
Students and staff have effective means by which they can raise child protection concerns
or report issues;
Staff have at least one reliable means to contact all students quickly and directly;
Staff are aware of the medical or learning needs of individual students via the Student
Record and these are shared with the homestay on a need to know basis;
In cases where the whereabouts of a student under Compass Culture and Education is not
known or the student is believed to be at risk of harm, procedures to locate the student by
the safest and quickest means possible, or secure the safety of the student will be invoked
immediately by following the Missing Student policy;
The company has procedures in place that enable child protection concerns and incidents
to be dealt with promptly and effectively and in line with relevant legislation.
Compass Culture and Education is committed to the protection of all children in its care. We are
committed to safeguarding student welfare and undertake rigorous checks on all who work with us
and we expect all staff, volunteers and homestays to share this commitment.
Safeguarding students is the responsibility of us all, including full-time, part-time, contracted, agency
and volunteer staff including those who do not have cause to come into direct or regular contact
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
with students in order to carry out their daily duties. It also applies to those who provide homestay
accommodation for our students and third party contractors.
Where there is a safeguarding concern Compass Culture and Education will ensure the child’s wishes
and feelings are taken into account when determining what action to take and what services to
provide. We provide clear information for students in the student handbook [alter to suit where
information can be found e.g. in our handbook, a keeping safe booklet, on emergency cards…]. We
check that students understand the information and are comfortable about how they can raise a
concern. We explain how concerns will be treated seriously, and that students can safely express
their views and give feedback.
All staff and homestays should be aware that children may not feel ready or know how to tell
someone that they are being abused, exploited, or neglected, and/or they may not recognise their
experiences as harmful. This should not prevent staff from having a professional curiosity and
speaking to the DSL if they have concerns about a child.
It is important that staff and homestays determine how best to build trusted relationships with
children and young people which facilitate communication
The safety and welfare of children, or Child Protection, means protecting children from physical,
emotional or sexual abuse or neglect where there is an identified risk. Safeguarding is the
minimisation of the risk to children from all forms of child abuse including for example:
Child sexual exploitation
Child on child abuse
Radicalisation and extremism
Female genital mutilation
Physical, emotional, sexual abuse or neglect
Domestic abuse
Online abuse
Bullying and cyber bullying
We aim to ensure that the students in our care experience at all times a caring and secure
environment in which they feel safe, respected and valued. In pursuit of this aim, Compass Culture
and Education undertakes the following:
1. We ensure that we lead from the top by ensuring that our [owner/ director] has the
appropriate safeguarding knowledge and involvement in the procedures we have in place.
This includes having oversight of arrangements.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
2. Training is provided for all staff and homestays to a level appropriate for their role (see
training section below);
3. We promote an environment of trust, openness and clear communication between
students, school and Compass Culture and Education staff and our Homestays, so that
student welfare, safety and pastoral care is recognised as the top priority;
4. We respond to any reported allegation or suspicion of child abuse in accordance with the
Compass Culture and Education procedures as outlined below;
5. We ensure that all guardianship personnel, homestays and personnel offering outsourced
services who come into direct contact with students in our care, are recruited using safer
recruitment practices and are formally screened through the completion of an
enhanced DBS check;
6. We maintain links with the appropriate agencies who have a statutory responsibility to
deal with child welfare and child protection concerns.
If you have any reason to believe that a child in your care is suffering from any form of abuse or
neglect then please report it immediately in confidence to the DSL or DDSL using the contact
details listed in this policy.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
SUPPORTING PROCEDURES AND DOCUMENTS
This policy is to be read in conjunction with the following policies and documents:
Anti-bullying and (including cyber-bullying) policy
Anti-Radicalisation Policy
Online safety policy
Emergency procedure (This includes information on the guardianship organisation’s
approach to foreseeable emergencies, such as a pandemic.)
Low Level Concerns Policy
Missing student Policy
Safer Recruitment Policy
Staff and Homestay Code of Conduct
Whistleblowing Policy
GOVERNMENT GUIDANCE
KEEPING CHILDREN SAFE IN EDUCATION
Part one of Keeping Children Safe in Education provides an overview for staff, homestays and
volunteers who are working with children. This is written with schools and colleges in mind, but
much of the information is relevant to guardianship organisations and homestays. Compass advises
all staff, homestays and volunteers who come into contact with children to have read this document.
This can be found here Keeping children safe in education: information for all school and college
Annex A of Keeping Children Safe in Education is a condensed version of Part one of Keeping
Children Safe in Education. Compass advises all staff who do not directly work with children to read
this document instead of part one.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
DEFINITIONS
Term
What this means
is defined as:
Safeguarding and • protecting children from maltreatment.
promoting the
welfare of
children
• preventing impairment of children's mental and physical health or development;
• ensuring that children grow up in circumstances consistent with the provision of safe
and effective care;
• taking action to enable all children to have the best outcomes.
Is a part of safeguarding and promoting welfare. It refers to the activity that is
undertaken to protect specific children who are suffering, or are likely to suffer,
significant harm.
Child Protection
Designated
Safeguarding
Lead (DSL)
This is the person identified as taking the lead in safeguarding matters in an
organisation. This person (and any deputy) will be trained to a higher level.
Prevent is the name given to part of the government's strategy to prevent terrorism by
reducing the possibility of radicalisation.
Prevent
Local
Safeguarding
Formerly Local Safeguarding Children Board (LSCB) and consisting of the local authority,
the clinical commissioning group within the local authority and the chief office of police
Partnership (LSP) within the local authority.
The role of the Local Authority Designated Officer (LADO) is to coordinate all allegations
and concerns made against a person who works with children.
LADO
Children
‘Children’ includes everyone under the age of 18.
WHAT IS ABUSE AND NEGLECT?
Knowing what to look for is vital to the early identification of abuse and neglect. All staff
and homestays should be aware of indicators of abuse and neglect so that they are able
to identify cases of children who may be in need of help or protection. If staff or
homestays are unsure, they should always speak to the DSL (or DDSL).
All staff and homestays should be aware that abuse, neglect and safeguarding issues are
rarely stand-alone events that can be covered by one definition or label. In most cases,
multiple issues will overlap with one another.
Contextual Safeguarding: All staff, volunteers and homestays should be aware that
safeguarding incidents and/or behaviours can be associated with factors outside the
guardianship organisation, school or college and/or can occur between children outside
of these environments. All staff, but especially the designated safeguarding lead (and
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
deputy) should consider whether children are at risk of abuse or exploitation in
situations outside their families. Extra-familial harms take a variety of different forms
and children can be vulnerable to multiple harms including (but not limited to)sexual
abuse (including harassment and exploitation), domestic abuse in their own intimate
relationships teenage relationship abuse), criminal exploitation, serious youth violence,
county lines and radicalisation.
All staff and homestays should be aware that technology is a significant component in
many
safeguarding and wellbeing issues. Children are at risk of abuse and other risks online as
well as face to face. In many cases abuse and other risks will take place concurrently
both online and offline. Children can also abuse other children online, this can take the
form of abusive, harassing, and misogynistic/misandrist messages, the non-consensual
sharing of indecent images, especially around chat groups, and the sharing of abusive
images and pornography to those who do not want to receive such content.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
TYPES OF ABUSE AND NEGLECT
(Taken from Keeping Children Safe in Education 2022)
Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm
or by failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the
impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation
to the impact on children of all forms of domestic abuse. Children may be abused in a family or in an
institutional or community setting by those known to them or, more rarely, by others. Abuse can
take place wholly online, or technology may be used to facilitate offline abuse. Children may be
abused by an adult or adults or by another child or children.
Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or
scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also
be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a
child.
Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and
adverse effects on the child’s emotional development. It may involve conveying to a child that they
are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another
person. It may include not giving the child opportunities to express their views, deliberately silencing
them or ‘making fun’ of what they say or how they communicate. It may feature age or
developmentally inappropriate expectations being imposed on children. These may include
interactions that are beyond a child’s developmental capability as well as overprotection and
limitation of exploration and learning or preventing the child from participating in normal social
interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious
bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the
exploitation or corruption of children. Some level of emotional abuse is involved in all types of
maltreatment of a child, although it may occur alone.
Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not
necessarily involving violence, whether or not the child is aware of what is happening. The activities
may involve physical contact, including assault by penetration (for example rape or oral sex) or non-
penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may
also include non-contact activities, such as involving children in looking at, or in the production of,
sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate
ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and
technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult
males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
children by other children is a specific safeguarding issue in education and all staff should be aware
of it and of their school or college’s policy and procedures for dealing with it.
Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to
result in the serious impairment of the child’s health or development. Neglect may occur during
pregnancy, for example, as a result of maternal substance abuse. Once a child is born, neglect may
involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion
from home or abandonment); protect a child from physical and emotional harm or danger; ensure
adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate
medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic
emotional needs.
(For specific types of abuse, please see the additional information at the end of this policy).
SIGNS OF ABUSE AND NEGLECT
The following information has been taken from the NSPCC website https://www.nspcc.org.uk/what-
is-child-abuse/types-of-abuse/.(This website page also includes further details on other specific signs
of abuse including bullying and cyberbullying, child sexual exploitation, child trafficking, criminal
exploitation and gangs, domestic abuse, FGM, grooming, non-recent abuse, and online abuse.)
Common signs
The NSPCC list the following as common signs that there may be something concerning happening in
a child’s life include:
unexplained changes in behaviour or personality
becoming withdrawn
seeming anxious
becoming uncharacteristically aggressive
lacks social skills and has few friends, if any
poor bond or relationship with a parent
knowledge of adult issues inappropriate for their age
running away or going missing
always choosing to wear clothes which cover their body
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
These signs don’t necessarily mean that a child is being abused, there could be other things
happening in their life which are affecting their behaviour – but we can help you to assess the
situation.
You may also notice some concerning behaviour from adults who you know have children in their
care, which makes you concerned for the child/children’s safety and wellbeing.
Indicators of Physical Abuse
Bumps and bruises don't always mean a child is being physically abused. All children have accidents,
trips and falls. And there isn't just one sign or symptom to look out for. But it's important to be
aware of the signs.
If a child regularly has injuries, there seems to be a pattern to the injuries or the explanation doesn't
match the injuries, then this should be reported.
Physical abuse symptoms include:
bruises
broken or fractured bones
burns or scalds
bite marks
It can also include other injuries and health problems, such as:
scarring
the effects of poisoning, such as vomiting, drowsiness or seizures
breathing problems from drowning, suffocation or poisoning
Head injuries in babies and toddlers can be signs of abuse so it's important to be aware of
these. Visible signs include:
swelling
bruising
fractures
being extremely sleepy or unconscious
breathing problems
seizures
vomiting
unusual behaviour, such as being irritable or not feeding properly
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Indicators of Emotional Abuse
There might not be any obvious physical signs of emotional abuse or neglect. And a child might not
tell anyone what's happening until they reach a 'crisis point'. That's why it's important to look out for
signs in how a child is acting.
As children grow up, their emotions change. This means it can be difficult to tell if they're being
emotionally abused. But children who are being emotionally abused might:
seem unconfident or lack self-assurance
struggle to control their emotions
have difficulty making or maintaining relationships
act in a way that's inappropriate for their age
The signs of emotional abuse can also be different for children at different ages.
Children might:
use language you wouldn't expect them to know for their age
act in a way or know about things you wouldn't expect them to know for their age
struggle to control their emotions
have extreme outbursts
seem isolated from their parents
lack social skills
have few or no friends.
Indicators of Sexual Abuse
Knowing the signs of sexual abuse can help give a voice to children. Sometimes children won't
understand that what's happening to them is wrong or they might be scared to speak out. Some of
the signs you might notice include:
Emotional and Behavioural signs
Avoiding being alone with or frightened of people or a person they know
Language or sexual behaviour you wouldn't expect them to know
Having nightmares or bed-wetting
Alcohol or drug misuse
Self-harm
Changes in eating habits or developing an eating problem
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Physical Signs
Bruises
Bleeding, discharge, pains or soreness in their genital or anal area
Sexually transmitted infections
Pregnancy
If a child is being or has been sexually abused online, they might:
spend a lot more or a lot less time than usual online, texting, gaming or using social
media
seem distant, upset or angry after using the internet or texting
be secretive about who they're talking to and what they're doing online or on their
mobile phone
have lots of new phone numbers, texts or email addresses on their mobile phone, laptop
or tablet
Children and young people might also drop hints and clues about the abuse
Indicators of Neglect
Neglect can be really difficult to spot. Having one of the signs doesn't necessarily mean a child is
being neglected. But if you notice multiple signs that last for a while, they might show there's a
serious problem. Children and young people who are neglected might have:
Poor appearance and hygiene
being smelly or dirty
being hungry or not given money for food
having unwashed clothes
having the wrong clothing, such as no warm clothes in winter
Health and development problems
anaemia
body issues, such as poor muscle tone or prominent joints
medical or dental issues
missed medical appointments, such as for vaccinations
not given the correct medicines
poor language or social skills
regular illness or infections
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
repeated accidental injuries, often caused by lack of supervision
skin issues, such as sores, rashes, flea bites, scabies or ringworm
thin or swollen tummy
tiredness
untreated injuries
weight or growth issues
Housing and family issues
living in an unsuitable home environment, such as having no heating
being left alone for a long time
taking on the role of carer for other family members
Change in behaviour
becoming clingy
becoming aggressive
being withdrawn, depressed or anxious
changes in eating habits
displaying obsessive behaviour
finding it hard to concentrate or take part in activities
missing school
showing signs of self-harm
using drugs or alcohol
PROCEDURES
When new staff, volunteers or homestays join our organisation, they are informed of the
safeguarding arrangements in place, the name of the DSL (and DDSL) and how to share concerns
with them. Please note that the usual reporting channel is via the DSL, however anyone can make a
referral direct to the LSP or LADO. The contact details are included in this document.
Compass will self-report to AEGIS by promptly informing them of any significant safeguarding
concerns, incidents that could be perceived as compromising or subject to misinterpretation, or
instances where behaviour falls below expected standards. This will be done through formal
communication channels to ensure transparency and compliance with safeguarding regulations.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Actions to be followed if there are concerns about a child or young
person
[Please note that your procedures will need to be consistent with those expected of your LSP and as
such this section may need to be adapted accordingly]
All staff members and homestays have a duty to identify and respond to suspected /
actual abuse or disclosures of abuse. Any member of staff, volunteer or homestays who
receives a disclosure or allegation of abuse, or suspects that abuse may have occurred
must report it immediately to the DSL (or, in their absence, the DDSL).
Where there is risk of immediate harm, concerns will be referred immediately by
telephone to the LSP [Add specific contact e.g MASH here] or the Police.
Less urgent concerns or requests for support, including for Early Help, will be sent by the
DSL to the LSP via [add specific LSP contact here, e.g. MASH].
The DSL may also seek advice from Social Care or another appropriate agency about a
concern, if we are unsure how to respond to it.
The DSL will refer any safeguarding concerns that relate to an incident in school to the
school. Concerns will be referred to the school DSL. If an allegation is made against a
member of school staff, the guardianship organisation will check the school policy to see
who to refer such matters so. This is usually the Head of the School. If the allegation
involves the Head, then usually the chair of governors should be informed.
Where a concern is not seen to reach the threshold for a referral, the DSL will keep the
concern on file and will monitor the situation. Should the concern escalate, a referral will
be made to the LSP.
Wherever possible, we will share any safeguarding concerns, or an intention to refer a
child to Children’s Social Care, with parents or carers. However, we will not do so where
it is felt that to do so could place the child at greater risk of harm or impede a criminal
investigation. On occasions, it may be necessary to consult with the LSP and/or Police
for advice on when to share information with parents / carers.
If a member of staff or homestay continues to have concerns about a child and feels the
situation is not being addressed or does not appear to be improving, the staff member or
homestay concerned should press for re-consideration of the case with the designated
safeguarding lead.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
If, for any reason, the DSL (or DDSL) is not available, or you do not feel that your concern
is being taken seriously, this should not delay appropriate action being taken. Any
individual may refer to the LSP or Police where there is suspected or actual risk of harm
to a child. The contact details are included at the beginning of this policy.
Full records of reports and action taken will be maintained by the DSL and securely
stored in a specific safeguarding file.
How Compass will respond to child on child Abuse
All staff and homestays should be aware that children can abuse other children (often referred to as
child on child abuse) and that it can happen both inside and outside of school or college and online.
That may mean it happens whilst students are in the care of homestays. It is important that all staff
and homestays recognise the indicators and signs of child on child abuse and know how to identify it
and respond to reports.
All staff and homestays should understand, that even if there are no reports in their organisation it
does not mean it is not happening, it may be the case that it is just not being reported. As such it is
important if staff or homestays have any concerns regarding child on child abuse they should speak
to the designated safeguarding lead (or deputy).
Compass Culture and Education adopts a zero- tolerance to abuse. It is essential that all staff and
homestays understand the importance of challenging inappropriate behaviours between peers,
many of which are listed below, that are actually abusive in nature. Downplaying certain behaviours,
for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of growing
up” or “boys being boys” can lead to a culture of unacceptable behaviours, an unsafe environment
for children and in worst case scenarios a culture that normalises abuse leading to children accepting
it as normal and not coming forward to report it. It is recognised that it is more likely that girls will
be victims and boys’ perpetrators, but all child on child abuse is unacceptable and will be taken
seriously.
Child on child abuse is most likely to include, but may not be limited to:
bullying (including cyber bullying, prejudice-based and discriminatory bullying);
abuse in intimate personal relationships between children (sometimes known as
‘teenage relationship abuse’)
physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing
physical harm (this may include an online element which facilitates, threatens and/or
encourages physical abuse);
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Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
sexual violence, such as rape, assault by penetration and sexual assault; (this may
include an online element which facilitates, threatens and/or encourages sexual
violence);
sexual harassment, such as sexual comments, remarks, jokes and online sexual
harassment, which may be standalone or part of a broader pattern of abuse;
causing someone to engage in sexual activity without consent, such as forcing someone
to strip, touch themselves sexually, or to engage in sexual activity with a third party;
consensual and non-consensual sharing of nudes and semi nudes images and or
videos(also known as sexting or youth produced sexual imagery);
upskirting, which typically involves taking a picture under a person’s clothing without
their permission, with the intention of viewing their genitals or buttocks to obtain sexual
gratification, or cause the victim humiliation, distress or alarm; and
initiation/hazing type violence and rituals (this could include activities involving
harassment, abuse or humiliation used as a way of initiating a person into a group and
may also include an online element).
Compass Culture and Education has the following procedures that help to minimise the
risk of child on child abuse:
Regular training for staff and homestays
Educating students through our handbooks and through discussion
Providing students with clear guidelines within the student handbook on how to raise a
concern.
Fostering effective channels of communication so that students feel comfortable
approaching their homestay carer or guardian with any concerns.
Effective communication between the DSL (and DDSL) with the DSL in schools where
students are placed.
In the event of a report of child on child abuse, staff and homestays should inform the DSL
or DDSL as soon as possible.
How students can raise a concern
It is important that students understand that any concern they raise will be treated
seriously.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Students will be encouraged to talk to any trusted adult, including school staff, their
parents, homestay carer, their guardian or the guardianship organisation DSL/ DDSL. This
will be explained to them verbally, with a written reminder included in the student
handbook.
How allegations will be recorded, investigated and dealt with
All reports of child on child abuse will be made on a case by case basis with the DSL or
the DDSL taking a leading role using their professional judgement and supported by
other agencies such as social care or the police as required.
Compass Culture and Education asks staff and homestay to follow the procedures
Where a report includes an online element Compass Culture and Education will follow
advice
on searching, screening and confiscation. Staff or homestays must not view or forward
images unless unavoidable and only if another member of staff (preferably the DSL) is
present. (The publication people section 2.10explains the procedure to follow if it is felt
that there is a clear reason to view such imagery.)
The DSL will notify the DSL of the school that the student attends as soon as possible.
Risk Assessment
When there has been a report of sexual violence, the DSL (or DDSL) will make an immediate risk and
needs’ assessment. Where there has been a report of sexual harassment, the need for a risk
assessment should be considered on a case-by-case basis. The risk and needs’ assessment should
consider:
The victim, especially their protection and support;
The alleged perpetrator; and
All the other children (and, if appropriate, homestay family members) residing at a
homestay, especially any actions that are appropriate to protect them;
Risk assessments will be recorded [written or electronic say where these are filed] and be kept under
review.
The DSL (or a DDSL) will ensure they are engaging with their LSP.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
How victims, perpetrators and any other children affected by child
on child abuse will be supported
Compass Culture and Education will support students who have been involved in child on child
abuse. This could include:
Maintaining regular contact with the student/s to check on their welfare and provide an
opportunity to talk.
Providing homestays and staff information on a need-to-know basis so that they are able
to offer support where appropriate.
Working with the student’s school to provide consistent support
Making available the details of charities and helplines who can help students who have
been affected by child on child abuse.
Management of the report
The DSL will decide how any cases of child on child abuse should be managed, in line with LSP
thresholds. Depending on the severity, a report may be handled in the following ways:
Manage internally(including liaising with the students’ school DSL where appropriate)
Early help
Report to the LSP: Where a child has been harmed, is at risk of harm, or is in immediate
danger, we will make a referral to the LSP.
Report to the police. Where a report of rape, assault by penetration or sexual assault is
made, Compass Culture and Education will consult with the police regarding how this
case should be managed.
Compass Culture and Education expects all staff and homestays to be clear on the policy and
procedures with regards to child on child abuse outlined in this policy and the important role they
have to play in preventing it and responding where they believe a child may be at risk from it.
Compass Culture and Education acknowledges that addressing inappropriate behaviour (even if it
appears to be relatively innocuous) can be an important intervention that helps prevent
problematic, abusive and/or violent behaviour in the future.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
ALLEGATIONS OF ABUSE AGAINST A MEMBER OF STAFF OR HOMESTAY
Allegations that meet the threshold
This guidance should be followed where it is alleged that anyone working, volunteering
or hosting students for Compass Culture and Education has:
behaved in a way that has harmed a child, or may have harmed a child and/or;
possibly committed a criminal offence against or related to a child and/or;
behaved towards a child or children in a way that indicates he or she may pose a risk
of harm to children; and/or
behaved or may have behaved in a way that indicates they may not be suitable to
work with children (known as transferable risk)
In the event that there is an allegation against a member of staff, volunteer or homestay,
Compass Culture and Education will follow the guidance in the most recent version of
Keeping Children Safe in Education Part 4.
Allegations against a member of guardianship organisation staff, volunteers or
homestays should be directed to the director of Compass Culture and Education, Lucy Jin,
who will act as “case manager”. The owner/director must contact the LADO immediately
and follow their advice. They must not investigate themselves. If the allegation is about
the owner/ director, please contact the LADO directly.
Compass Culture and Education will report promptly to the DBS any person whose
services are no longer used for regulated activity because they have caused harm or
posed a risk of harm to a child.
Any historical allegations should be referred to the police.
Allegations that do not meet the threshold
Low level concerns: Compass Culture and Education has a Low Level Concerns policy that outlines
the processes we will follow to deal with concerns (including allegations) which do not meet the
harm threshold set out above. We also have a staff code of conduct that explains professional
boundaries. Staff, homestays and volunteers are expected to act within these boundaries, and in
accordance with the ethos and values of Compass Culture and Education Ltd. It is imperative that
staff understand the importance of reporting any concerns that they may have.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Concerns may arise in several ways and from a number of sources. For example: suspicion;
complaint; or disclosure made by a student, parent or other adult within or outside of the
organisation; or as a result of vetting checks undertaken.
The term ‘low-level’ concern does not mean that it is insignificant, it means that the behaviour
towards a child does not meet the threshold set out above. A low-level concern is any concern – no
matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an
adult working in or on behalf of the school or college may have acted in a way that:
is inconsistent with the staff code of conduct, including inappropriate conduct outside of
work, and
does not meet the allegations threshold or is otherwise not considered serious enough to
consider a referral to the LADO.
Examples of such behaviour could include, but are not limited to:
being over friendly with children;
having favourites;
taking photographs of children on their mobile phone;
engaging with a child on a one-to-one basis in a secluded area or behind a closed door;
or,
using inappropriate sexualised, intimidating or offensive language.
Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that
may look to be inappropriate, but might not be in specific circumstances, through to that which is
ultimately intended to enable abuse.
The safety and wellbeing of students in our care is dependent on the vigilance of all our staff,
volunteers and homestays and their prompt communication to the DSL or [add job title here- usually
the owner/a director] of any concerns, no matter how small, about any conduct by an adult which
causes you to doubt that adult’s suitability to work with or have access to children. Compass Culture
and Education is conscious of its duty of care to students and will always act, including if alerted to
the possibility of abuse arising from situations or persons outside our care. The notification and
prompt handling of all concerns about adults is fundamental to safeguarding students. It helps to
identify and prevent abuse and to protect adults against misunderstandings or misinterpretations. It
also encourages openness, trust and transparency and it clarifies expected behaviours. Our separate
Low Level Concern Policy outlines how we will manage and record any low level concerns and take
appropriate action to safeguard children.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Learning Lessons
Throughout the process of handling allegations and at conclusion of a case in which an allegation is
substantiated, the LADO should review the circumstances of the case with the case manager to
determine whether there are any improvements to be made to our procedures to help prevent
similar events in the future.
This should include issues arising from any decision to suspend the member of staff, the duration of
the suspension and whether or not suspension was justified. Lessons should also be learnt from the
use of suspension when the individual is subsequently reinstated.
The LADO and case manager should consider how future investigations of a similar nature could be
carried out without suspending the individual.
For all other cases, where the allegation concluded to be either, unfounded, false, malicious or
unsubstantiated the case manager (and if they have been involved the LADO) should consider the
facts and determine whether any lessons can be learned and if improvements can be made
How to receive a disclosure from a child or young person
Victims should be taken seriously, kept safe and never be made to feel like they are
creating a problem for reporting abuse, sexual violence or sexual harassment
Reassure the child and listen carefully – it is important that they know you believe them
Do not say you will not say anything to anyone – in fact you have a duty to disclose this
to another person so do not promise confidentiality
Make sure you take detailed notes, write everything down. If you are unable to take
notes at the time, you should do so as soon as you are able.
Ask open questions if appropriate, do not lead the conversation to find out what has
happened. Use words such as tell me, explain or describe, and allow the student to speak
Avoid words such as what, why, how when – these will be asked by the relevant agency
if appropriate.
Ensure that you notify the police by calling 999 if you believe that the young person is at
immediate or serious risk of harm
Contact the DSL [add name] or DDSL [add name] as soon as practicable and in any case
within 24 hours
If the disclosure is made out of hours, please use the emergency phone number [add
number here].
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Sharing Safeguarding Information
There will be occasions when safeguarding information will need to be shared with other parties in
order to safeguard the individual/s concerned. Information will be shared with guardianship
organisation staff, homestays and the school’s DSL (of the school that the student attends) who
‘need to know’ and with children’s social care, the safeguarding partners, other organisations,
agencies,and practitioners as required. Staff and homestays must ensure that any confidential
information shared with them remains confidential and is handled in line with our data protection
policy.
Compass Culture and Education will be proactive in sharing information as early aspossible to help
identify, assess, and respond to risks or concerns about the safety andwelfare of children, whether
this is when problems are first emerging, or where a child isalready known to the local authority
children’s social care.
All staff and homestays must be aware that they have a professional responsibility to share
information with other agencies in order to safeguard children and that the Data Protection Act
1998 and General Data Protection Regulations are not a barrier to sharing information where a
failure to do so would place a child at risk of harm. There is a lawful basis for child protection
concerns to be shared with agencies who have a statutory duty for child protection.
All staff and homestays must be aware that they cannot promise a child to keep secrets which might
compromise the child’s safety or wellbeing. However, staff and homestays are aware that matters
relating to child protection and safeguarding are personal to children and families, in this respect
they are confidential and the DSL and DDSL will only disclose information about a child to other
members of guardianship organisation staff, homestays the DSL of the school that the student
attends on a need to know basis.
The DSL will always undertake to gain parent/carers consent to refer a child to Social Care unless to
do so could put the child at greater risk of harm, or impede a criminal investigation.
ROLE OF DSL AND DDSL
The DSL will take lead responsibility for safeguarding and child protection (including online safety).
This is explicit in the role holder’s job description. This person has the appropriate status and
authority within the guardianship organisation to carry out the duties of the post.
The DDSL is trained to the same standard as the DSL and the role is explicit in their job description.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
The designated safeguarding lead is expected to:
refer cases of suspected abuse to the local authority children’s social care as required;
support staff and homestays who make referrals to local authority children’s social care;
refer cases to the Channel programme where there is a radicalisation concern as
required(this may also be undertaken by the Prevent Lead, if the Prevent Lead is not the
DSL);
support staff and homestays who make referrals to the Channel programme(this may
also be undertaken by the Prevent Lead, if the Prevent Lead is not the DSL);
refer cases where a crime may have been committed to the Police as required.
act as a point of contact with the three safeguarding partners;
liaise with the [owner/ managing director]to inform them of issues
liaise with staff and homestays on matters of safety and safeguarding (including online
and digital safety) and when deciding whether to make a referral by liaising with relevant
agencies;
act as a source of support, advice and expertise for all staff and homestays.
understand the importance of information sharing, both within the guardianship
organisation, and with the safeguarding partners, the DSL for the school the student
attends, other agencies, organisations and practitioners
encourage a culture of listening to students and taking account of their wishes and
feelings, among all staff, homestays and volunteers and in any measures the
guardianship organisation may put in place to protect them; and,
understand the difficulties that students may have in approaching staff and homestays
about their circumstances and consider how to build trusted relationships which
facilitate communication.
ensure the guardianship organisation’s child protection policies are known, understood
and used appropriately;
ensure the child protection policy is reviewed annually (as a minimum) and the
procedures and implementation are updated and reviewed regularly, and work with the
Lucy Jin regarding this;
ensure the child protection policy is available for all relevant parties on
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
link with the safeguarding partner arrangements to make sure staff and homestays are
aware of any training opportunities and the latest local policies on local safeguarding
arrangements.
CONTACT DETAILS FOR THE DSL AND DDSL
Role
Name
Tina Liu
Telephone Number
07405 844 198
Email
Designated Safeguarding Lead (DSL)
Deputy Designated Safeguarding Lead (DDSL)
24-Hour emergency contact
Jessie Chang
Lucy Jin
07404 846 230
07912 847 858
PREVENT
Compass Culture and Education has a separate policy that outlines our procedure for Anti-
Radicalisation and Prevent. This can be requested from guardians.
PREVENT LEAD CONTACT DETAILS
Role
Name
Telephone Number
Email
Prevent Lead
Tina Liu
07405 844 198
RECORD KEEPTING
Compass Culture and Education will keep full records of any safeguarding concern reported to them.
All concerns, discussions and decisions made, and the reasons for those decisions, will be recorded
in writing. Safeguarding records will be stored securely and separately to the general student files.
These will be stored confidentially by the DSL in either a locked cabinet (hard copies) or a password
protected file. Only the DSL and DDSL will have access to these files.
Records will be detailed and accurate (either handwritten or using appropriate secure online
software). These will include all concerns about a student even if there is no need to make an
immediate referral and record the rationale for decisions made and action taken.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
In summary, records should include:
a clear and comprehensive summary of the concern;
details of how the concern was followed up and resolved;
a note of any action taken, decisions reached and the outcome.
Copies of any correspondence or notes from conversations with the LSP, school DSL or other
external agency will be included in the file.
Compass Culture and Education will ensure that the indication of the existence of the additional child
protection file is marked on the student file record. Information will only be shared in a need to
know basis in order to safeguard the student.
If in doubt about recording requirements, staff or homestays should discuss with the DSL (or DDSL).
TRAINING AND UPDATES
Compass Culture and Education will ensure that all staff and homestays receive training and regular
updates that is suitable for their roles. A formal record of all safeguarding training will be kept.
DSL AND DDSL
The DSL and DDSL will attend suitable face-to-face training as approved or provided by the Local
Safeguarding Partners (LSP), AEGIS or the NSPCC. This training will be renewed every two years.
OTHER STAFF AND HOMESTAYS
All other members of staff, volunteers and Homestays will receive appropriate safeguarding training
to an appropriate basic awareness level (previously referred to as level 1), every three years. This
will either be done online or in person. Members of staff, volunteers and Homestays who have
already have completed suitable safeguarding training for another provider that is still in date will
not be required to re-train. In this case the DSL will still need to ensure that the person fully
understands Compass’s own procedures for safeguarding.
Compass also encourages staff and homestays to self-report any situations where their actions may
be misinterpreted or fall short of the required standards outlined in the code of conduct. A clear,
confidential reporting system will be in place to document these incidents and escalate them to the
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
safeguarding team for review. Compass will manage these reports promptly, taking appropriate
action to address concerns and ensure ongoing compliance with safeguarding standards.
All staff and homestays will receive regular safeguarding updates, at least once per year – normally
in September. These will be given by the DSL.
WHISTLEBLOWING
Compass Culture and Education has a separate policy that outlines the whistleblowing procedures.
These protect staff members who report colleagues they believe are doing something wrong or
illegal, or who are neglecting their duties.
LOCAL SAFEGUARDING PARTNERSHIPS (LSPs)
Compass Culture and Education will liaise with their Local Safeguarding Partnership (LSP) and work in
partnership with other agencies in line with Working Together to Safeguard Children.
Partner schools have their own safeguarding policies. These can be found on their website and will
include the contact details for their LSP. Compass Culture and Education recognises that if any
safeguarding concerns occurred whilst a student was in a homestay that was out of the schools
county then a different/additional LSP arrangement would be required as well. In this case, Compass
Culture and Education will contact the relevant LSP and follow their procedures. The website below
provides a link to all of the LSPs in the country:
Details can be found on the Local Authority website and for the areas Compass Culture and
Education operates in the table below.
In the event of any contact information difficulties then Compass will call the police as they are one
of the partners.
The company is aware of how to access local agency contacts; this includes Local Safeguarding
Partnerships across the country and how to access locally agreed inter-agency procedures and
guidance. In addition, the company is aware of the non-emergency reporting procedures via the
Local Authority’s Children’s Services relevant to the area or Multi-Agency Safeguarding Hub (MASH),
or by telephoning the non-emergency Police number 101. For emergency situations, the company is
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
aware of the need to contact the relevant police force for the area by dialling 999, this includes in
Wales and Police Scotland.
The company is aware that in Scotland, for a non-emergency referral or concern they can contact
the local children’s social work team. Their contact details can be found on the website for the local
authority the child lives in, and in the table below. Alternatively they can contact the local office of
Scottish Children’s Reporter Administration: https://www.scra.gov.uk/contact-us/
The company is aware that in Wales for a non-emergency referral or concern they can contact the
local child protection services. Their contact details can be found on the website for the local
authority the child lives in, and on the table below.
CONTACT DETAILS FOR LSP AND LADO WHERE THE
GUARDIANSHIP ORGANISATION IS LOCATED
Role
Name
Telephone Number
Email
LSP
Barnet MASH Team
020 8359 4066
LADO
Barnet MASH Team
020 8359 4066
CONTACT DETAILS FOR LSPs AND LADOs ACROSS THE AREAS
THAT COMPASS CULTURE AND EDUCATION OPERATES
Area
Role and Name of contact
Telephone Number
Email
LSP: Enfield MASH Team
020 8359 4066
Enfield
LADO: Enfield MASH Team
020 8359 4066
LIAISON WITH PARENTS / AGENTS AND PARTNER SCHOOLS
The guardianship organisation may be required to share confidential safeguarding
information with the DSL of the school or college that the student attends. When a
student moves school or college, safeguarding information may be shared with the DSL
of the new school. All schools and colleges have their own safeguarding and child
protection policies that outline their procedures. These can be found on their websites.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Whilst the guardianship organisation will work openly with parents as far as possible, it
reserves the right to contact the LSP or the police, without notifying parents if this is
believed to be in the child’s best interests.
Compass Culture and Education will not usually share safeguarding information with
agents unless it is necessary to safeguard the student. In this case information will be
provided on a need-to- know basis and on the understanding that it should be kept
strictly confidential.
FURTHER DETAIL ON SPECIFIC TYPES OF ABUSE
The following information is taken from Keeping Children Safe in Education. It has been edited so
that where appropriate, references to schools and colleges has been replaced with reference to
guardianship organisations. This is to make it more relevant to the reader. Please refer to annex B of
Keeping_children_safe_in_education_2022 for further details, including additional types of abuse.
Safeguarding issues
All staff and homestays should have an awareness of safeguarding issues that can put children at risk
of harm. Behaviours linked to issues such as drug taking and or alcohol misuse, deliberately missing
education, serious violence (including that linked to county lines), radicalisation and consensual and
non-consensual sharing of nudes and semi-nudes images and/or videos can be signs that children
are at risk. Other safeguarding issues staff and homestays should be aware of include:
Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)
Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an
imbalance in power to coerce, manipulate or deceive a child into taking in sexual or criminal activity,
in exchange for something the victim needs or wants, and/or for the financial advantage or
increased status of the perpetrator or facilitator and/or through violence or the threat of violence.
CSE and CCE can affect children, both male and female and can include children who have been
moved(commonly referred to as trafficking) for the purpose of exploitation.
Child Criminal Exploitation (CCE)
Some specific forms of CCE can include children being forced or manipulated into transporting drugs
or money through county lines, working in cannabis factories, shoplifting or pickpocketing. They can
also be forced or manipulated into committing vehicle crime or threatening/committing serious
violence to others.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Children can become trapped by this type of exploitation as perpetrators can threaten victims (and
their families) with violence, or entrap and coerce them into debt. They may be coerced into
carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from
others. As children involved in criminal exploitation often commit crimes themselves, their
vulnerability as victims is not always recognised by adults and professionals, (particularly older
children), and they are not treated as victims despite the harm they have experienced. They may still
have been criminally exploited even if the activity appears to be something they have agreed or
consented to.
It is important to note that the experience of girls who are criminally exploited can be very different
to that of boys. The indicators may not be the same, however professionals should be aware that
girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being
criminally exploited may be at higher risk of sexual exploitation.
Further information about CCE including definitions and indicators is included in Annex B of Keeping
Children Safe in Education.
Child Sexual Exploitation (CSE)
CSE is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by
penetration (for example, rape or oral sex) or no penetrative acts such as masturbation, kissing,
rubbing, and touching outside clothing. It may include non-contact activities, such as involving
children in the production of sexual images, forcing children to look at sexual images or watch sexual
activities, encouraging children to behave in sexually inappropriate ways or grooming a child in
preparation for abuse including via the internet.
CSE can occur over time or be a one-off occurrence, and may happen without the child’s immediate
knowledge e.g. through others sharing videos or images of them on social media.
CSE can affect any child, who has been coerced into engaging in sexual activities. This includes 16
and 17 year olds who can legally consent to have sex. Some children may not realise they are being
exploited e.g. they believe they are in a genuine romantic relationship.
Further information about CSE including definitions and indicators is included in Annex B.
MENTAL HEALTH
All staff and homestays should be aware that mental health problems can, in some cases, be an
indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Only appropriately trained professionals should attempt to make a diagnosis of a mental health
problem. Guardianship staff and homestays, however, are well placed to observe children day-to-
day and identify those whose behaviour suggests that they may be experiencing a mental health
problem or be at risk of developing one.
Where children have suffered abuse and neglect, or other potentially traumatic adverse childhood
experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It
is key that staff and homestays are aware of how these children’s experiences, can impact on their
mental health, behaviour, and education.
Guardianship organisations can access a range of advice to help them identify children in need of
extra mental health support, this includes working with external agencies. The AEGIS Quality
Standards includes a Mental Health Support List (Appendix 10). More information can be found in
the mental health and behaviour in schools guidance, guardianship organisations may also wish to
follow this guidance as best practice. Public Health England has produced a range of resources to
support secondary school teachers to promote positive health, wellbeing and resilience among
materials and lesson plans.
If staff or homestays have a mental health concern about a child that is also a safeguarding concern,
immediate action should be taken, following their child protection policy, and speaking to the
designated safeguarding lead or a deputy.
There may be instances where Compass Culture and Education is asked to remove a student with
mental health issues from a school setting. Compass Culture and Education will work with the
students’ school to support the student in the best way possible.
In the event of a request to remove a student with a mental health issue from school, Compass
Culture and Education will ask a member of school staff to complete and return the student removal
form (see appendix 2) before removing the student from the school. This is to ensure that Compass
Culture and Education has enough information about the circumstances leading up to the removal of
the student in order to support the student suitably, and to ensure all appropriate steps have been
taken up to that point.
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
SEXUAL VIOLENCE AND SEXUAL HARASSMENT BETWEEN
CHILDREN IN SCHOOLS AND COLLEGES CONTEXT
Sexual violence and sexual harassment can occur between two children of any age and sex from
primary to secondary stage and into colleges. It can also occur online. It can also occur through a
group of children sexually assaulting or sexually harassing a single child or group of children.
Children who are victims of sexual violence and sexual harassment will likely find the experience
stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and
will be exacerbated if the alleged perpetrator(s) attends the same school or college. Sexual violence
and sexual harassment exist on a continuum and may overlap, they can occur online and face to face
(both physically and verbally) and are never acceptable.
It is essential that all victims are reassured that they are being taken seriously and that they will be
supported and kept safe. A victim should never be given the impression that they are creating a
problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel
ashamed for making a report. Detailed advice is available in Part five of the full version of KCSIE.
Staff and homestays should be aware that some groups are potentially more at risk. Evidence shows
girls, children with special educational needs and disabilities (SEND) and LGBT children are at greater
risk.
Staff and homestays should be aware of the importance of:
challenging inappropriate behaviours;
making clear that sexual violence and sexual harassment is not acceptable, will never be
tolerated and is not an inevitable part of growing up;
not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of
growing up”, “just having a laugh” or “boys being boys”; and
challenging physical behaviours (potentially criminal in nature), such as grabbing
bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts.
Dismissing or tolerating such behaviours risks normalising them.
WHAT IS SEXUAL VIOLENCE AND SEXUAL HARASSMENT?
Sexual violence
It is important that guardianship organisation staff, homestays and any volunteers are aware of
sexual violence and the fact children can, and sometimes do, abuse their peers in this way and that it
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
can happen both inside and outside of school/college. When referring to sexual violence we are
referring to sexual violence offences under the Sexual Offences Act 2003135 as described below:
Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or
mouth of another person (B) with his penis, B does not consent to the penetration and A does not
reasonably believe that B consents.
Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina
or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual,
B does not consent to the penetration and A does not reasonably believe that B consents.
Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches
another person (B), the touching is sexual, B does not consent to the touching and A does not
reasonably believe that B consents. (Schools should be aware that sexual assault covers a very wide
range of behaviour so a single act of kissing someone without consent, or touching someone’s
bottom/breasts/genitalia without consent, can still constitute sexual assault.)
Causing someone to engage in sexual activity without consent: A person (A) commits an offence if:
s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not
consent to engaging in the activity, and A does not reasonably believe that B consents. (This could
include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a
third party.)
What is consent?
Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given
to one sort of sexual activity but not another, e.g.to vaginal but not anal sex or penetration with
conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity
and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he
agrees by choice to that penetration and has the freedom and capacity to make that choice. Further
information about consent can be found here: Rape Crisis England & Wales -Sexual consent
a child under the age of 13 can never consent to any sexual activity;
the age of consent is 16;
sexual intercourse without consent is rape.
Sexual harassment
When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur
online and offline and both inside and outside of school/college. When we reference sexual
harassment, we do so in the context of child on child sexual harassment. Sexual harassment is likely
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or
create a hostile, offensive or sexualised environment.
Whilst not intended to be an exhaustive list, sexual harassment can include:
sexual comments, such as: telling sexual stories, making lewd comments, making sexual
remarks about clothes and appearance and calling someone sexualised names;
sexual “jokes” or taunting;
physical behaviour, such as: deliberately brushing against someone, interfering with
someone’s clothes (schools and colleges should be considering when any of this crosses a
line into sexual violence - it is important to talk to and consider the experience of the
victim) and displaying pictures, photos or drawings of a sexual nature; and
online sexual harassment. This may be standalone, or part of a wider pattern of sexual
harassment and/or sexual violence. It may include:
o consensual and non-consensual sharing of nudes and semi-nudes images and/or videos. As set out
young people (which provides detailed advice for schools and colleges) taking and sharing nude
photographs of U18s is a criminal offence;
sharing of unwanted explicit content;
upskirting (is a criminal offence);
sexualised online bullying;
unwanted sexual comments and messages, including, on social media;
sexual exploitation; coercion and threats.
UPSKIRTING
The Voyeurism (Offences) Act 2019, which is commonly known as the Upskirting Act, came into force
on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a persons clothing (not
necessarily a skirt) without their permission and or knowledge, with the intention of viewing their
genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim
humiliation, distress or alarm. It is a criminal offence. Anyone of any sex, can be a victim.
The response to a report of sexual violence or sexual harassment
The initial response to a report from a child is incredibly important. How a school, college or
guardianship organisation responds to a report can encourage or undermine the confidence of
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future victims of sexual violence and sexual harassment to report or come forward. Schools, colleges
and guardianship organisations not recognising, acknowledging or understanding the scale of
harassment and abuse and/or downplaying of some behaviours can actually lead to a culture of
unacceptable behaviour. It is essential that all victims are reassured that they are being taken
seriously and that they will be supported and kept safe. A victim should never be given the
impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor
should a victim ever be made to feel ashamed for making a report.
If staff or homestays have a concern about a child or a child makes a report to them, they should
follow the referral process as set out from paragraph 51 in Part one of Keeping Children Safe in
Education. As is always the case, if staff or homestays are in any doubt as to what to do they should
speak to the designated safeguarding lead (or a deputy).
SERIOUS VIOLENCE
All staff and homestays should be aware of the indicators, which may signal children are at riskfrom,
or are involved with serious violent crime. These may include increased absencefrom school, a
change in friendships or relationships with older individuals or groups, a significant decline in
performance, signs of self-harm or a significant change in wellbeing,or signs of assault or
unexplained injuries. Unexplained gifts or new possessions couldalso indicate that children have
been approached by, or are involved with, individualsassociated with criminal networks or gangs and
may be at risk of criminal exploitation(see above).
All staff and homestays should be aware of the range of risk factors which increase the likelihoodof
involvement in serious violence, such as being male, having been frequently absent orpermanently
excluded from school, having experienced child maltreatment and havingbeen involved in offending,
such as theft or robbery. Advice for schools and colleges isprovided in the Home Office’s Preventing
youth violence and gang involvement and its Criminal exploitation of children and vulnerable adults:
county lines guidance. This is also useful advice for guardianship organisations.
CHILDREN MISSING FORM EDUCATION
All staff and homestays should be aware that children going missing, particularly repeatedly, can act
as a vital warning sign of a range of safeguarding possibilities. This may include abuse and neglect,
which may include sexual abuse or exploitation and can also be a sign of child criminal exploitation
including involvement in county lines. It may indicate mental health problems, risk of substance
abuse, risk of travelling to conflict zones, risk of female genital mutilation, ‘honour’-based abuse or
risk of forced marriage. Early intervention is necessary to identify the existence of any underlying
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Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
safeguarding risk and to help prevent the risks of a child going missing in future. Staff should contact
the students’ school or college should they suspect a student is missing from education. The school
or college will have a procedure for reporting this absence.
COUNTY LINES
County lines is a term used to describe gangs and organised criminal networks involved in exporting
illegal drugs using dedicated mobile phone lines or other form of “deal line”. This activity can happen
locally as well as across the UK - no specified distance of travel is required. Children and vulnerable
adults are exploited to move, store and sell drugs and money. Offenders will often use coercion,
intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.
Children can be targeted and recruited into county lines in a number of locations including schools
(mainstream and special), further and higher educational institutions, pupil referral units, children’s
homes and care homes.
Children are also increasingly being targeted and recruited online using social media. Children can
easily become trapped by this type of exploitation as county lines gangs can manufacture drug debts
which need to be worked off or threaten serious violence and kidnap towards victims (and their
families) if they attempt to leave the county lines network.
A number of the indicators for CSE and CCE as detailed above may be applicable to where children
are involved in county lines. Some additional specific indicators that may be present where a child is
criminally exploited through involvement in county lines are children who:
go missing and are subsequently found in areas away from their home;
have been the victim or perpetrator of serious violence (e.g. knife crime);
are involved in receiving requests for drugs via a phone line, moving drugs, handing over
and collecting money for drugs;
are exposed to techniques such as ‘plugging’, where drugs are concealed internally to
avoid detection;
are found in accommodation that they have no connection with, often called a ‘trap
house or cuckooing’ or hotel room where there is drug activity;
owe a ‘debt bond’ to their exploiters;
have their bank accounts used to facilitate drug dealing.
Further information on the signs of a child’s involvement in county lines is available in guidance
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Compass Culture and Education Ltd.
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020 84490119
MODERN SLAVERY AND THE NATIONAL REFERRAL MECHANISM
Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory
labour. Exploitation can take many forms, including: sexual exploitation, forced labour, slavery,
servitude, forced criminality and the removal of organs.
Further information on the signs that someone may be a victim of modern slavery, the support
available to victims and how to refer them to the NRM is available in the Modern Slavery Statutory
CYBERCRIME
Cybercrime is criminal activity committed using computers and/or the internet. It is broadly
categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at
speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer).
Cyber-dependent crimes include;
unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s
computer network to look for test paper answers or change grades awarded;
denial of Service (Dos or DDoS) attacks or ‘booting’. These are attempts to make a
computer, network or website unavailable by overwhelming it with internet traffic from
multiple sources; and,
making, supplying or obtaining malware (malicious software) such as viruses, spyware,
ransomware, botnets and Remote Access Trojans with the intent to commit further
offence, including those above.
Children with particular skill and interest in computing and technology may inadvertently or
deliberately stray into cyber-dependent crime.
If there are concerns about a child in this area, the designated safeguarding lead (or a deputy),
should consider referring into the Cyber Choices programme. This is a nationwide police programme
supported by the Home Office and led by the National Crime Agency, working with regional and local
policing. It aims to intervene where young people are at risk of committing, or being drawn into, low
level cyber-dependent offences and divert them to a more positive use of their skills and interests.
Note that Cyber Choices does not currently cover ‘cyber-enabled’ crime such as fraud, purchasing of
illegal drugs on-line and child sexual abuse and exploitation, nor other areas of concern such as on-
line bullying or general on-line safety.
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020 84490119
SO-CALLED’ HONOUR’ -BASED ABUSE
(including Female Genital Mutilation and Forced Marriage)
So-called ‘honour’-based abuse (HBA) 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 HBA are abuse
(regardless of the motivation) and should be handled and escalated as such. Professionals in all
agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a
child being at risk of HBA, or already having suffered HBA.
Actions
If staff or homestays have a concern regarding a child who might be at risk of HBA or who has
suffered from HBA, they should speak to the designated safeguarding lead (or deputy). As
appropriate, the designated safeguarding lead (or deputy) will activate local safeguarding
procedures, using existing national and local protocols for multi-agency liaison with police and
children’s social care. Where FGM has taken place, since 31 October 2015 there has been a
mandatory reporting duty placed on teachersthat requires a different approach (see annex B of
Keeping Children Safe in Education for further details).
FGM
FGM comprises all procedures involving partial or total removal of the external female genitalia or
other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-
lasting harmful consequences.
Whilst all staff or homestays should speak to the designated safeguarding lead (or deputy) with
regard to any concerns about female genital mutilation (FGM), there is a specific legal duty on
teachers(and also regulated health and social care professionals in England and Wales). If a teacher,
in the course of their work in the profession, discovers that an act of FGM appears to have been
carried out on a girl under the age of 18, the teacher must report this to the police. See Annex B of
Keeping Children Safe in Education for further details.
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Forced marriage
Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered
into without the full and free consent of one or both parties and where violence, threats or any
other form of coercion is used to cause a person to enter into 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 as a way to coerce a person into marriage. Schools,
colleges and guardianship organisations can play an important role in safeguarding children from
forced marriage.
36 of which focus on the role of schools and colleges. Staff can contact the Forced Marriage Unit if
DOMESTIC ABUSE
Domestic abuse The Domestic Abuse Act 2021 received Royal Assent on 29 April 2021. The Act
introduces the first ever statutory definition of domestic abuse and recognises the impact of
domestic abuse on children, as victims in their own right, if they see, hear or experience the effects
of abuse. The statutory definition of domestic abuse, based on the previous cross-government
definition, ensures that different types of relationships are captured, including ex-partners and
family members. The definition captures a range of different abusive behaviours, including physical,
emotional and economic abuse and coercive and controlling behaviour. Both the person who is
carrying out the behaviour and the person to whom the behaviour is directed towards must be aged
16 or over and they must be “personally connected” (as defined in section 2 of the 2021 Act).
Types of domestic abuse include intimate partner violence, abuse by family members, teenage
relationship abuse and child/adolescent to parent violence and abuse. Anyone can be a victim of
domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background
and domestic abuse can take place inside or outside of the home. The government will issue
statutory guidance to provide further information for those working with domestic abuse victims
and perpetrators, including the impact on children.
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. Experiencing 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.
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Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Young people can also experience domestic abuse within their own intimate relationships. This form
of child on child abuse is sometimes referred to as ‘teenage relationship abuse’. Depending on the
age of the young people, this may not be recognised in law under the statutory definition of
‘domestic abuse’ (if one or both parties are under 16). However, as with any child under 18, where
there are concerns about safety or welfare, child safeguarding procedures should be followed and
both young victims and young perpetrators should be offered support. The Act’s provisions,
including the new definition, will be commenced over the coming months.
Guardianship organisation should be aware that students could potentially experience domestic
abuse both in their own homes or whilst staying with homestays.
ONLINE SAFETY
It is essential that children are safeguarded from potentially harmful and inappropriate online
material.
The breadth of issues classified within online safety is considerable, but can be categorised into four
areas of risk:
content: being exposed to illegal, inappropriate or harmful content, for example:
pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism,
radicalisation and extremism.
contact: being subjected to harmful online interaction with other users; for example:
peer to peer pressure, commercial advertising and adults posing as children or young
adults with the intention to groom or exploit them for sexual, criminal, financial or other
purposes’.
conduct: personal online behaviour that increases the likelihood of, orcauses, harm; for
example, making, sending and receiving explicit images(e.g consensual and non-
consensual sharing of nudes and semi-nudesand/or pornography, sharing other explicit
images and online bullying; and
commerce - risks such as online gambling, inappropriate advertising,phishing and or
financial scams. If Compass Culture and Education feelsour students or staff areat risk,
Compass Culture and Education recognises the risks posed to students online. Further information
can be found in the online safety and bullying (including cyber-bullying) policies.
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Compass Culture and Education Ltd.
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020 84490119
Compass Culture and Education provides training for staff, homestays and volunteers on online
safety.
REVIEW
We are committed to reviewing our policy and good practice annually.
This policy was last reviewed on: 20 Aug 2024
Signed: Tina Liu
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Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
APPENDIX 1 : INCIDENT FORM
CHILD PROTECTION RECORD – Report of a Concern
Date of record:
Date of incident:
Name of referrer:
Student name:
Role of referrer:
use initials for other children / young people involved, unless there is
a specific need to name them in full
Details of concern:
contemporaneous notes, if taken, may be attached to this form
Role of person
reported to:
Reported to:
Signed:
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Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
For DSL/ DDSL use:
Advice sought:
(from whom and what
was advice given)
Action taken:
Concern / referral
discussed with
parent / carer?
If not, state reasons
why – if yes, note
discussion with parent
If not, state reasons
why – if yes, record to
whom and any action
agreed
Referral made:
Feedback to
referring member of
staff or homestay:
By whom
By whom
Response to / action
taken with student:
Name and contact
number of key
workers:
Name and contact
details of GP:
Other notes /
information /
concerns:
Any other action
required:
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
Registered in England No. 9024815
Compass Culture and Education Ltd.
3 Union Street, Barnet EN5 4HY
020 84490119
APPENDIX 2:STUDENT REMOVAL FORM
In order for us to support our student as best as possible, we would appreciate it if you
could complete the following student removal form. Please note that a representative of
Compass Culture and Education Ltd. will not be able to collect the student until this form
has been completed and returned to us by email: gd2@compassedu.co.uk
School Name
Student Name
Date of Birth
Reason for request of removal of
student
Has the student been assessed by a
medical professional?
Yes ☐ No ☐
Date of assessment if applicable.
Please provide a summary of
assessment if applicable.
Is the student at risk of harm to
themself?
Yes ☐ No ☐
Yes ☐ No ☐
Is the student a risk to others?
Has the school followed its mental
health and child protection policies and
procedures?
Please provide a copy of any relevant
policies and procedures.
Yes ☐ No ☐
Any other additional information we
should be made aware of
Signature
Name
Position
Date
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