CONTENTS
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TTA PREVENT and Safeguarding Policy |
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| 1 | Introduction |
| 2 | Overall Aims and Objectives of the Policy |
| 3 | What We Will Do |
| 4 | Accountability, Roles and Responsibilities |
| 5 | TTA Apprentices and Learners on other TTA Programmes |
| 6 | Safeguarding apprentices and learners on other TTA programmes, who may be vulnerable to exploitation, forced marriage, female genital mutilation or trafficking |
| 7 | Safer Recruitment & Selection of Staff, Associates and Volunteers |
| 8 | Staff Support |
| 9 | Partner/Subcontractor Provision |
| 10 | Related Policies and Documentation |
| 11 | Review of Prevent & Safeguarding Policy |
The Prevent & Safeguarding Policy for TTA Limited reflects the importance of our responsibility to safeguard and promote the welfare of all our apprentices, learners on other TTA programmes and staff by protecting them from physical, sexual or emotional abuse, neglect, and bullying. We are committed to providing a caring, friendly, and safe environment for all our apprentices/learners so that they can learn in a relaxed and secure atmosphere. We believe every apprentice/learner should be able to participate in all learning and social activities in an enjoyable and safe environment and be protected from harm.
Safeguarding is defined as:
TTA has a statutory requirement to protect the health, wellbeing, and human rights of adults at risk, enabling them to live safely, free from abuse and neglect. It is about people and organisations working together to prevent and reduce both the risks and experience of abuse or neglect.
TTA has a statutory requirement to promote the welfare of children in compliance with the DfE guidance Keeping Children Safe in Education (July 2015).
TTA as a work-based learning provider has a statutory requirement under the provisions of the Counter Terrorism and Security Act (CTSA) 2015, to comply effectively with the requirements of the Prevent Statutory Duty.
Section 26(1) of the Counter Terrorism and Security Act June 2015 (CTSA) imposes a statutory duty on “specified authorities”, when exercising their functions, “to have due regard to the need to prevent people from being drawn into terrorism”.
The CTSA goes on to say “There is an important role for further education institutions, including sixth form colleges and independent training providers, in helping prevent people being drawn into terrorism, which includes not just violent extremism but also non-violent extremism, which can create an atmosphere conducive to terrorism and can popularise views which terrorists exploit. It is a condition of funding that all further education and independent training providers must comply with relevant legislation and any statutory responsibilities associated with the delivery of education and safeguarding of learners”.
The fundamental aims of Prevent, as part of the revised 2018 Contest Strategy (www.gov.uk/government/publications/counter-terrorism-stratety-contest) are, “to safeguard vulnerable people to stop them becoming terrorists or supporting terrorism”.
Prevent aims to safeguard vulnerable individuals (children and adults) who may be at risk of potentially becoming involved in terrorist activities. It aims to support institutions such as schools, colleges, universities, and further education establishments where this may happen.
CONTEST is the Government’s Counter-Terrorism Strategy 2018. The aim of CONTEST is ‘to reduce the risk to the UK and its citizens and interests overseas from terrorism, so that people can go about their lives freely and with confidence’. The updated and strengthened strategy reflects the findings of a fundamental review of all aspects of counter-terrorism, to ensure we have the best response to the heightened threat in coming years from all forms of terrorism.
The counter-terrorism strategy will continue to be organised within the tried and tested strategic framework of the four P work strands, each comprising several key objectives:
CONTEST has four strands, often known as the four Ps. The aims of the four Ps are:
Radicalisation is defined as the act or process of making a person more radical or favouring of extreme or fundamental changes in political, economic, and social conditions, institutions, or ways of thinking. TTA recognise that safeguarding against radicalisation is no different from safeguarding against any other vulnerability.
Extremism is defined as holding the extreme political or religious views. As defined in the Government’s Counter Extremism Strategy 2015, Extremism is ‘the vocal or active opposition to our shared values. These include democracy and the rule of law, mutual respect and tolerance of other faiths and beliefs.’
TTA staff, associates, partners, subcontractors, and volunteers are expected to uphold and promote the fundamental principles of British Values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of those with different faiths and beliefs.
This includes not discriminating against those with protected characteristics as defined in the Equality Act 2010:
Age Disability
Gender reassignment Marriage and Civil Partnership Pregnancy and maternity Race
Religion and belief Sex
Sexual orientation
The Safeguarding Vulnerable Groups Act 2006 legislation brings together the legislative framework of measures to protect children and vulnerable adults from harm. These measures include:
The term safeguarding embraces both child and vulnerable adult protection and preventative approaches to keep our apprentices, learners on other TTA programmes and staff safe.
An action that endangers or causes serious violence to a person/people, causes serious damage to property, or seriously interferes or disrupts an electronic system. The use of threat must be designed to influence the Government or to intimidate the public and is made for the purpose of advancing a political, religious, or ideological cause.
Channel is an early intervention multi-agency process designed to safeguard vulnerable people from being drawn into violent extremist or terrorist behaviour. Channel is designed to work with individuals of any age who are at risk of being exploited by extremist or terrorist ideologues. The Process is shaped around the circumstances of each person and can provide support for any form of radicalisation or personal vulnerabilities. Channel is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. The programme uses a multi-agency approach to protect vulnerable people by:
Sections 36 to 41 of the Counter-Terrorism and Security Act 2015 set out the duty on local authorities and partners of local panels to provide support for people vulnerable to being drawn into any form of terrorism.
The main aims of this policy are to ensure that staff are fully engaged in being vigilant about raising awareness; and they ensure that we work alongside other professional bodies and agencies to ensure that our apprentices, learners, and staff are safe from harm.
The objectives of this policy are:
It is recognised that apprentices/learners or staff with low aspirations are more vulnerable to radicalisation. TTA strive to ensure that all learning programmes promote respect, tolerance and diversity and apprentices and staff are encouraged to share their views and recognise that they are entitled to have their own different beliefs.
Apprentices/learners and staff are briefed during their induction process about how to stay safe when using the Internet and social media. They are advised to seek help if they are concerned or upset about anything they read or see on the internet or social media. There are specific policies in place that address the safe use of IT and social media.
TTA staff, associates, partners, subcontractors, and volunteers will undertake appropriate training to ensure that they are clear about their role and responsibilities including their statutory safeguarding duties. Training events and resources are available, some mandatory, to ensure that staff are made aware of the threats, vulnerabilities, and risks in relation to radicalisation and how they can identify these at an early stage.
Promote to all staff, associates, partners, subcontractors and volunteers the importance of:
The welfare of children, young people and vulnerable adults is everyone’s responsibility. TTA does not investigate individual child protection or adult cases or referrals. TTA is not the statutory authority for the conduct of enquiries into specific cases; therefore, TTA staff and associates need to follow the TTA safeguarding procedures to ensure that all allegations or suspicions of abuse or significant harm to a child, young person or vulnerable adult is dealt with swiftly.
It will be the responsibility of the Designated Safeguarding & Prevent Lead to make the decision and then report the case to the relevant statutory agency. TTA will share all relevant information with the respective statutory agency (Police or Social Services). In the absence of the Designated Safeguarding Lead, a Deputy Safeguarding Lead in consultation with a director, may make the decision and report a concern/case to the relevant statutory agency.
Specific roles and responsibilities concerning Safeguarding are detailed below:
The nominated Safeguarding & Prevent Lead (who is a member of the Board of Directors) will take leadership responsibility for the organisation’s safeguarding and Prevent arrangements.
Be responsible for creating and driving a positive culture and ethos where safeguarding is an important part of everyday life
Undertake regular and appropriate training for their role as a member of the Safeguarding & Prevent Team
Review the Prevent & Safeguarding Policy and Procedures and their effectiveness, and update on an annual basis as appropriate
Have designated safeguarding staff in place which includes the nominated Designated Prevent & Safeguarding Lead, Deputy Safeguarding & Prevent Leads, Prevent & Safeguarding Officers, and a Safer Recruitment Officer
Share and disseminate information, knowledge, and good practice across the business, and lead by example
Meet on a regular basis to review all matters in relation to Prevent and safeguarding, including minute discussions and disseminate the minutes to other teams
Report Prevent and safeguarding concerns and matters to the Board
Undertake regular and appropriate training for the role
Consult as appropriate, and make the decision to, then report any serious matters to the relevant statutory agency, sharing relevant information with the respective statutory agency (Police or Social Services).
Have access to safeguarding files which are otherwise restricted
There are nominated deputies who are trained and competent to fulfil the role and responsibilities of the Designated Prevent & Safeguarding Lead in the absence of the Designated Prevent & Safeguarding Lead
All Operational Delivery Managers are trained Safeguarding Officers – they will:
Be responsible and accountable for the embedding of safeguarding across their area(s) of operational delivery
Be responsible and accountable for all aspects of Prevent & Safeguarding and ensure that their staff understand their responsibilities to promote welfare amongst their learners
Take an organisational approach and ensure that safeguarding is embedded into apprenticeship, learner and staff practice and experience
Set clear objectives for L&D coaches to support and empower their learners to keep themselves safe
Target L&D coaches to carefully assess risks and put in place and that risk reduction measures are implemented for all work tasks and activities
Undertake regular and appropriate training for the role
Safeguarding Officers will liaise with the Designated Prevent & Safeguarding Lead/Deputies on all safeguarding issues that come to their attention
Work with the Quality & Compliance Manager to ensure safeguarding is included in self-assessment activities and the SAR
Undertake regular and appropriate training for the role
Be up to date with all legislative and compliance requirements
Review TTA’s Recruitment and Selection Policy, Procedures, documents, and forms annually or where legislative changes require an earlier review
Ensure all staff involved in recruitment, selection and interview processes are suitably trained and undertake Safer Recruitment training
Understand the role of the Disclosure and Barring Service and comply with its vetting and barring requirements
Request sight of original DBS disclosures for all candidates attending interview for learner facing roles; and recorded on the Single Central Register
Ensure DBS disclosures for all TTA staff are updated every three years
Instruct operational delivery managers to carry out a risk assessment with any new member of the operational delivery team where a Disclosure is not readily available
Facilitate Prevent and safeguarding training for all staff and associates including refresher training; sharing all training initiatives and training opportunities with partner/subcontractor organisations
Are responsible and accountable for ensuring that apprentices and all learners attending TTA programmes work within a safe, secure and healthy environment, and where there is the slightest concern, this is immediately reported
Play a part in ensuring that this policy and associated procedures and documents are implemented effectively and consistently across all delivery
Liaise with the Safer Recruitment Officer (who is the HR Manager) to ensure that staff and the delivery team have appropriate instruction, training, and development to enable them to fulfil their Prevent and safeguarding responsibilities and to work safely
L&D coaches include Prevent and Safeguarding in Schemes of Work, Lesson Plans, Observations and the learner journey for training and delivery staff
IQA team will talk to apprentices/learners at observations and assessments to check their awareness of this policy, and where they are not, report this to the respective operational delivery manager and the Prevent & Safeguarding team
IQA team will monitor the performance of the training and delivery team by various tools and methods for example participate in One-to-One process, OTLA, Observations of Assessment and IQA field visits to ensure policy requirements and Company standards are being met/adhered to and good practice shared
Ensure that any incident of suspected or alleged abuse is reported appropriately and timely to the Designated Prevent & Safeguarding Lead/Deputy Prevent & Safeguarding Lead(s) or a designated Safeguarding Officer
Lead by example and abide by the TTA Code of Conduct
Must attend Prevent and safeguarding training including refresher training – this may be an event, online seminar or on-line – when requested and in a timely manner
Be alert and take responsibility for ensuring you know how to identify signs of abuse and risk to apprentices and how to report it
Immediately refer concerns to your immediate manager, who will ensure the matter is sensitively investigated in the first instance; and who will inform the Designated Prevent & Safeguarding Lead/deputy in the absence of the Designated Prevent & Safeguarding Lead Be prepared to listen to and take seriously the concerns of apprentices and learners on other TTA programmes, staff, colleagues, or carers
Write down details clearly word for word – the learner’s words not your interpretation
Ensure all paperwork is treated confidentially and provided to the Designated Prevent & Safeguarding Lead/deputy who will maintain all documentation in a secure environment Abide by the TTA Code of Conduct
Always set a good example to learners by your own exemplary behaviour.
As a provider of 16-18 Apprenticeship programmes, TTA Learning & Development Coaches, tutors, IQAs, specialists, staff and associates will regularly encounter young people.
TTA may also provide training programmes in prisons and YOI’s, where some L&D coaches, tutors, IQAs, specialists and staff will encounter adults and young people detained in custody.
Although our main adult training programmes are with employed adults who would not normally fall into any of the above categories, we should be aware that a proportion of our learners may experience challenges such as language difficulties – where the learner’s first language may not be English; and may be the subject of potential discrimination and racial abuse; or have a poor understanding of their rights and responsibilities at work. Also, some of our apprentices/learners encounter adults as part of their daily work in care homes and hospitals. These adults may have mental health difficulties or a disability that puts them into the legal definition of ‘vulnerable’.
TTA seeks to protect children, young people, and vulnerable adults against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right, Neo Nazi, White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.
The TTA Safeguarding & Prevent Team will work with managers, specialists, and staff to support them in the assessment of levels of risk within the organisation and at learner sites and centres; to put actions in place and discuss risk with employers, partners, and subcontractors as appropriate, where it is considered that learners may be at risk of radicalisation.
Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action. For this reason, the appropriate interventions in any case may not have any specific connection to the threat of radicalisation, for example, they may address mental health, learning difficulties, relationship, or drug/alcohol issues.
Exploitation is the deliberate maltreatment, manipulation or abuse of power and control over another person. It is taking advantage of another person or situation usually, but not always, for personal gain. Exploitation comes in many forms, including:
Recognising signs of harm or abuse – You might become aware that an individual is at risk of harm when:
Child sexual exploitation (CSE) is a type of sexual abuse. Young people may be given gifts like alcohol, cigarettes, accommodation, or drugs in return for sexual activity. CSE offenders may:
The Home Office recently published County Lines Guidance on Criminal Exploitation of children and vulnerable adults; September 2018. This guidance is primarily aimed at staff who work with children, young people and potentially vulnerable adults, including professionals working in education, health, housing, benefits, law enforcement (police) and related partner organisations.
The UK Government defines county lines as a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of “deal line”. They are likely to exploit children and vulnerable adults to move and store the drugs and money and they will often use coercion, intimidation, violence (including sexual violence) and weapons.
A forced marriage is where one or both people do not (or in cases of people with learning disabilities or reduced capacity, cannot) consent to the marriage as they are pressurised, or abuse is used, to force them to do so. It is recognised in the UK as a form of domestic or child abuse and a serious abuse of human rights. The pressure put on people to marry against their will may be:
The government is committed to ensuring that professionals who are made aware of a forced marriage victim have the training and guidance they need to provide effective advice and support. The Forced Marriage Unit publish free on-line publications including multi-agency practice guidelines: handling cases of forced marriage, which provides step-by-step advice for frontline workers, including health professionals, educational staff, police, children’s social care, adult social services and local authority housing and multi-agency statutory guidance for dealing with forced marriage, which provides guidance for all persons and bodies who exercise public functions in relation to safeguarding and promoting the welfare of children and vulnerable adults.
Female Genital Mutilation (FGM) is illegal in England and Wales under the FGM Act 2003. It is a form of child abuse and violence against women. FGM comprises all procedures involving partial or total removal of the external female genitalia for non-medical reasons. The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended
by the Serious Crime Act 2015). The legislation requires regulated health and social care professionals and teachers in England and Wales to make a report to the police where, in the course of their professional duties, they are either:
The Anti-social Behaviour, Crime and Policing Act 2014 made it a criminal offence in England, Wales, and Scotland to force someone to marry. (It is a criminal offence in Northern Ireland under separate legislation). This includes:
TTA has links to Prevent Teams including Northumbria and other Police authorities; as well as links with Dept of Education, Government agencies, local authorities, and Safeguarding Boards to keep up to date on the latest advice and guidance in relation to keeping individuals safe from other vulnerabilities and forms of exploitation.
Our staff and associates are supported and given guidance and training to help them recognise warning signs and be aware of learners who may be considered vulnerable and therefore susceptible to being exploited. This may include experts or members of the Prevent team talking to the staff and provision of training and awareness sessions.
The Designated Safeguarding Lead, Deputies and Safeguarding Officers know where to go for further advice and guidance, as necessary.
Where there are risk factors suspected or present, then this must be immediately reported to the respective Operational Manager who is a Safeguarding Officer, as well as keeping the Designated Safeguarding Lead (or deputy) informed and updated.
TTA will work in partnership with appropriate agencies in the best interests of the learner and we will cooperate with any enquiries that take place because of a risk factor being investigated.
All TTA staff and associates working within our organisation have a duty to report any potential safeguarding concerns about an individual’s behaviour towards a colleague, apprentice, or learner on another TTA programme, immediately.
Safer recruitment practice includes scrutinising applicants, verifying identity and academic and/or vocational qualifications, obtaining professional and character references, checking previous employment history, and ensuring that a candidate has the health and physical capacity for the job.
All recruitment materials will include reference to TTA’s commitment to safeguarding and promoting the wellbeing of our apprentices and learners on other TTA programmes.
All TTA staff involved in the recruitment, selection and appointment of staff are expected to abide by TTA recruitment requirements and practices without exception; and to lead by example.
When selecting and recruiting staff the TTA Recruitment Policy will be adhered to by all those involved in the interview process; this includes.
TTA recognise the stressful and traumatic nature of child and vulnerable adult protection work. We will support staff by providing an opportunity to talk through their anxieties with their Operational Manager Safeguarding Officer and/or the Designated Safeguarding Lead/deputy safeguarding lead; and to seek further support as appropriate.
All operational directors and managers have a duty to ensure that each partner or subcontractor is made aware of TTA’s requirements in relation to Prevent and Safeguarding without exception. Operational managers responsible for areas of provision – specifically apprenticeships, Adult Education Budget, Traineeships – are also responsible for ensuring that a robust due diligence process is carried out with every potential partner/subcontractor to scrutinise and assure ourselves that we do not inadvertently engage with any partner/subcontractor who may have links with extremist groups, or companies/businesses that may have any link with extremist groups. TTA operate in line with Government/ESFA Apprenticeship funding rules for training providers – contracting and subcontracting –responsibilities of providers and their subcontractors, including those organisations that are not registered on the Register for Apprenticeship Training Providers (RoATP). TTA have in place a robust due diligence and on-boarding procedure for all potential/prospective partner/subcontractor organisations. TTA will also ensure that all parties are aware of current Government legislation, guidelines, and papers to ensure that its own policies, procedures, and documentation are kept up to date and meet those protocols as published from time to time.
All operational directors and managers working with partners and subcontractor organisations must ensure the following:
This Prevent & Safeguarding Policy will be reviewed on an annual basis or earlier if required due to changes in legislation or best practice.
For and on behalf of TTA Limited