POLICY
Safeguarding Policy
Document title: Safeguarding Policy
Document reference HR034
Version V8
Issue date 3rd August 2026.
Review date Adopts KCSIE 2026 with effect from 1 September 2026. Next full review by 31 August 2027, or earlier if legislation, statutory guidance or local procedures change
Document owner / approver HR / Centre Manager, approved by the Board of Directors
Applies to All staff, volunteers, contractors, learners and apprentices of Elevated Knowledge Ltd, at all sites and workplaces
Designated Safeguarding Lead (DSL) Louise Pollitt — louisepollitt@elevatedknowledge.co.uk
Deputy Safeguarding Officer Kieron McCormick -kieron@elevatedknowledge.co.uk
Safeguarding team
SAFEGUARDING — WHO TO CONTACT If you have a concern, do not delay. If in doubt — report it.
Designated Safeguarding Lead (DSL) Louise Pollitt — louisepollitt@elevatedknowledge.co.uk
Deputy Safeguarding Officer Kieron McCormick- kieron@elevatedknowledge.co.uk
Safeguarding phone line (office hours) 0161 475 5840, ext 2
Safeguarding email safeguarding@elevatedknowledge.co.uk (confidential mailbox, monitored by the Designated Safeguarding Lead and the Deputy Safeguarding Officer)
Stockport MASSH (Multi-Agency Safeguarding and Support Hub) 0161 217 6028 — www.stockport.gov.uk/contacting-the-massh
Out of hours / emergency If a learner is in immediate danger, call the Police on 999. Stockport out-of-hours social care team: via the MASSH contact route.
1. Purpose
Elevated Knowledge Ltd is committed to safeguarding and promoting the welfare of all learners, and expects all learners, staff, volunteers and partners to share this commitment. The purpose of this policy is to set out how we meet that commitment: the management systems and arrangements in place to create and maintain a safe learning environment; how staff recognise the signs that a learner may be at risk (safeguarding alerts); the procedure for reporting a concern; what happens once a concern is reported (referral and investigation); and how staff are trained, supported and kept up to date. It identifies the named Designated Safeguarding Lead and the actions every member of staff must take to protect learners and young people from harm.
2. Scope
This policy applies to all activities and functions of Elevated Knowledge Ltd, at the training centre, in the workplace, on placement and online. It covers all learners and apprentices, including those under 18 and adults at risk (in line with the Care Act 2014), and applies to all staff (teaching and non-teaching), directors, volunteers, contractors and visitors. Safeguarding goes beyond basic learner protection procedures and is an integral part of everything we do; this policy complements and supports our related policies listed in Section 16.
3. Policy statement and ethos
We aim to create and maintain a safe learning environment where all learners and adults at risk feel safe, secure and valued, and know they will be listened to and taken seriously. Learners have access to appropriate opportunities to develop the skills they need to stay safe and healthy, develop their self-esteem and understand the responsibilities of adult and working life. All learners know that there are adults in the training centre whom they can approach in confidence if they are in difficulty or feeling worried, and that their concerns will be taken seriously and treated with respect. Early help is central to our approach: the earlier we identify a concern or a change in a learner, the better the outcome. Safeguarding and mental health first aiders are available in the centre every day.
4. Legislation and national guidance
This policy reflects and should be read alongside the following legislation and statutory guidance:
• Keeping Children Safe in Education 2026 (statutory guidance, in force from 1 September 2026) — all staff must read and understand Part 1 in full. The condensed version of Part 1 (previously Annex A) has been withdrawn, so every member of staff reads the full Part 1, including those who do not work directly with learners.
• Working Together to Safeguard Children 2026 — the statutory multi-agency framework, which replaced the 2023 edition in March 2026. It introduces the integrated Family Help model (bringing targeted early help and section 17 support into a single offer), strengthens information sharing and anti-discriminatory practice, and revises serious incident notification, rapid review and child safeguarding practice review arrangements.
• Crime and Policing Act 2026 — removes the “supervision exemption” from regulated activity, so that anyone who teaches, trains, instructs, cares for or supervises learners under 18 frequently is in regulated activity whether or not they are supervised (see Section 11).
• Children Act 1989 and Children Act 2004.
• Education Act 2002 (Section 175 duty to safeguard and promote welfare).
• Safeguarding Vulnerable Groups Act 2006 and the Disclosure and Barring Service (DBS) regime.
• Care Act 2014 — safeguarding adults at risk.
• Counter-Terrorism and Security Act 2015 and the Prevent duty guidance 2023.
• Female Genital Mutilation Act 2003 (Section 5B mandatory reporting duty, as inserted by the Serious Crime Act 2015).
• Information Sharing: advice for practitioners (DfE), UK GDPR and the Data Protection Act 2018.
• Stockport Safeguarding Children Partnership (SSCP) local procedures and thresholds, and the Greater Manchester safeguarding procedures.
• Generative artificial intelligence (AI) in education (DfE) and the DfE filtering and monitoring standards — see Section 13.5.
In line with Working Together to Safeguard Children 2026, safeguarding and promoting the welfare of children is defined as: protecting children from maltreatment; preventing the impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.
As an independent training provider, Elevated Knowledge Ltd is not a school or college for the purposes of KCSIE. We nevertheless adopt and apply KCSIE 2026 in full as a matter of policy, and in line with our funding and contractual obligations, for every learner under the age of 18. Learners aged 18 and over are safeguarded to the same standard under the Care Act 2014 and our adults-at-risk arrangements, and any reference in this policy to a “child” or “learner under 18” should be read accordingly.
5. Roles and responsibilities
5.1 The Designated Safeguarding Lead (DSL)
The named Designated Safeguarding Lead for Elevated Knowledge Ltd is Louise Pollitt (louisepollitt@elevatedknowledge.co.uk), a senior member of the Operations Board with lead responsibility for safeguarding. In her absence Kieron McCormick (KieronMcCormick@elevatedknowledge.co.uk) acts in her place. The DSL will:
• Act as the first point of contact for all safeguarding matters and be available to staff during delivery hours. Robust cover arrangements are in place for any period when the DSL is unavailable through sickness, leave or other circumstances; those arrangements are clear, reliable and known to all staff, and the confidential safeguarding mailbox is monitored by both the DSL and the Deputy Safeguarding Officer so that concerns are acted on without delay.
• Make referrals to the Stockport MASSH, the police and other agencies, and support staff to make effective referrals; keep copies of all referrals and related records securely.
• Attend formal DSL training at least every two years and keep knowledge and skills up to date through regular (at least annual) updates, including local SSCP training.
• Ensure all staff and volunteers receive safeguarding information from the point of induction, understand the reporting and recording procedures, and know what to do if they have a concern.
• Manage and keep secure the safeguarding records, maintain the single central record of concerns, and transfer a learner’s safeguarding file (separately from the main file) to any new establishment, retaining a copy.
• Share safeguarding information promptly and securely when a learner moves to another provider, school, college or employer, including any information indicating that the learner may pose a risk to themselves or to others, and speak directly to the receiving Designated Safeguarding Lead where there are significant concerns.
• Liaise with the HR Manager on safeguarding issues, champion safeguarding across the organisation, and ensure this policy is reviewed at least annually or sooner where changes warrant.
5.2 The HR / Centre Manager
• Ensures the policies and procedures adopted to safeguard learners are fully implemented and followed by all staff, and that safer recruitment and selection is practised (Section 10).
• Ensures sufficient time and resources are available for the DSL to discharge her responsibilities, including attending meetings, contributing to assessments, supporting colleagues and delivering training.
• Ensures all staff receive appropriate safeguarding training, updated at least every two years, that every member of staff reads Part 1 of KCSIE in full each year and confirms in writing that they have done so, and that staff feel safe to raise concerns about poor or unsafe practice.
5.3 The Board of Directors
• Ensures a senior member of the Operations Board is designated to take lead responsibility for safeguarding (the DSL, Louise Pollitt).
• Reviews and approves this policy at least annually and ensures compliance with SSCP local safeguarding procedures.
• Ensures safer recruitment practices, procedures for managing allegations against staff, and appropriate insurance cover are in place.
5.4 All staff, volunteers and visitors
Every adult working in or visiting Elevated Knowledge Ltd has a responsibility to report any concern about the welfare or safety of a learner, however small, using the procedure in Section 7. Staff must read and understand Part 1 of KCSIE 2026 in full each year — the condensed Annex A version has been withdrawn — and confirm in writing that they have done so. Staff must follow the staff Code of Conduct (Section 14) and must never promise a learner confidentiality.
6. Examples of safeguarding alerts
Because of their day-to-day contact, staff are particularly well placed to observe the outward signs of abuse, changes in behaviour, or failure to develop. The following categories and indicators are examples of safeguarding alerts that must be reported. This list is not exhaustive — any concern, however small, should be reported to the DSL. If it does not feel right, report it.
Category of concern Examples of alerts / possible indicators
Physical abuse Unexplained or frequent injuries, bruising, burns or bite marks; injuries inconsistent with the explanation given; flinching; reluctance to change clothing.
Emotional abuse Excessive fear of making mistakes, withdrawal, low self-esteem, self-deprecation, sudden speech disorders, extreme attention-seeking or passivity; persistent verbal abuse, criticism, humiliation or blaming by an adult or peer.
Sexual abuse and harmful sexual behaviour Sexual knowledge or behaviour inappropriate to age, pain or discomfort, sexually explicit language or images, fear of specific people, inappropriate relationships (including with adults in positions of trust). Harmful sexual behaviour sits on a continuum from developmentally expected, through inappropriate and problematic, to abusive behaviour and sexual violence.
Neglect Persistent hunger, poor hygiene or dress, untreated medical conditions, constant tiredness, repeated lateness or non-attendance.
Medical conditions and unmet health needs A learner repeatedly attending without essential medication, or a medical condition or allergy left unmanaged. Managing a medical condition is not in itself a safeguarding matter, but it may be an indicator of neglect or of wider abuse.
Child-on-child abuse Bullying (including cyber-bullying and prejudice-based bullying), physical abuse, sexual violence and sexual harassment, harmful sexual behaviour, initiation or hazing rituals, upskirting, and the making or sharing of nudes and semi-nudes — including digitally altered or AI-generated images (“deepfakes”).
Harmful sexual behaviour, sexual harassment and misogyny Sexualised comments, jokes or name-calling; unwanted physical contact; sexual harassment online, in the centre or in the workplace; misogynistic language, attitudes or content shared between learners. Misogyny can escalate and is closely linked to harmful sexual behaviour.
Exploitation, trafficking and modern slavery Child criminal exploitation (including county lines), child sexual exploitation, financial exploitation, unexplained gifts, money or phones, older “friends”, secretive behaviour, going missing, travel to unfamiliar areas. Exploitation may be organised by a network or gang of which the learner appears to be a willing part; apparent consent does not change the fact that it is abuse, and it may amount to modern slavery.
Radicalisation and extremism Expression of extremist views, sudden ideological change, accessing extremist material, isolation from friends and family, use of hateful language (Prevent duty).
Serious violence Carrying a weapon, threatening to use or using a weapon; assault; unexplained injuries alongside disrupted training, absence, changes in friendship groups, unexplained money or a history of offending. Those who commit violence are often victims themselves.
Domestic abuse and forced marriage Learner witnessing or experiencing domestic abuse; fear of a planned marriage; restrictions on freedom; so-called honour-based abuse.
Child-to-parent or caregiver abuse A learner using violence, threats, coercion or controlling behaviour towards a parent, carer or sibling.
Female Genital Mutilation (FGM) Knowledge or disclosure that FGM has been carried out or is planned; extended travel to countries where FGM is practised; discomfort or pain.
Mental health, self-harm and suicide risk Changes in mood or behaviour, sleep difficulties, withdrawal from social situations, loss of interest in things the learner usually enjoys, expressions of hopelessness, physical signs of harm or neglect. Self-harm and suicidal ideation are safeguarding concerns in their own right and must be reported to the DSL the same working day.
Online safety Excessive secrecy about online activity, online grooming, cyber-bullying, viewing harmful content, online radicalisation, and risks arising from generative AI — including AI-generated or digitally altered sexual images, AI chatbots, AI-generated misinformation and AI-assisted grooming or fraud.
Substance misuse, crime and unsafe environments Signs of drug or alcohol misuse, involvement in crime, homelessness or unsuitable housing, unsafe activities in the local area or workplace.
Absence from, or missing from, education Persistent, unexplained or unusual absence, late arrival or a learner missing from education. Being absent from education, as well as missing from it, can be a warning sign of abuse, exploitation, serious violence or mental ill health.
Low-level concerns and welfare changes Any change in behaviour, appearance, attendance or performance that does not feel right — including concerns about the conduct of adults that do not meet the harm threshold.
Indications of abuse concerning learners with special educational needs or disabilities must be reported exactly as they would be for any other learner. Additional barriers can exist to recognising abuse in learners with SEND: behaviour, mood or injury may be wrongly attributed to the disability; the learner may not recognise that what is happening to them is abuse; the learner may depend on adults for personal or intimate care; communication barriers may make disclosure harder; and the learner may be more isolated from peers. Staff should be alert to these barriers and report any concern to the DSL.
7. Reporting procedure
If a learner is in immediate danger, call 999 first. Otherwise, any member of staff, volunteer or visitor who has a concern about a learner, or who receives a disclosure, must follow these steps:
1. Listen and reassure. Take the learner seriously. Do not promise confidentiality — explain at the outset that you must share what they tell you with the Safeguarding Lead. Keep questions to the minimum needed to understand what is being alleged and never ask leading questions, as these can contaminate evidence for any subsequent investigation.
2. Do not investigate. Do not question the learner or any other person further, examine injuries, or contact parents/carers or the alleged person. Investigation is the job of the statutory authorities.
3. Report the same day. Speak to the Designated Safeguarding Lead, Louise Pollitt (louisepollitt@elevatedknowledge.co.uk, 0161 475 5840 ext 2), or in her absence the Deputy Safeguarding Officer, Kieron McCormick, or email safeguarding@elevatedknowledge.co.uk. Concerns must be reported the same working day.
4. Record. Record the facts on the Incident Report Form (Appendix A), including dates, times, what was said or observed (in the learner’s own words where possible) and any explanation given. Sign and date the record and pass it to the DSL. Records are stored securely, separately from the learner’s main file.
5. Agree next steps. Agree with the DSL what action will be taken, by whom and when it will be reviewed. If you believe your concern has not been acted upon, you may contact the Stockport MASSH directly (0161 217 6028) — anyone can make a referral.
8. Investigation and referral process
Once a concern is reported, the following process applies so that everyone understands what will happen:
1. Triage by the DSL. The DSL (or deputy) reviews the concern with the member of staff, checks existing records and considers whether emergency medical treatment is needed. Where appropriate and safe to do so, the DSL may clarify basic facts — for example, asking a parent/carer how an injury happened — but will not conduct an investigation.
2. Decision. In the light of the information available, the DSL decides whether to: make an immediate referral to the Stockport MASSH (and/or the police); seek advice from the MASSH where there is uncertainty; request Family Help or other targeted support and monitor the learner against further risk; or take no further action with reasons recorded. The DSL also considers whether to inform parents or carers, where doing so would not place the learner at additional risk, and records that decision. For suspected sexual abuse, the case is referred immediately without discussion with the learner’s family.
3. Referral. Referrals to the MASSH are made by telephone as a matter of urgency, followed immediately by the written pro-forma by email. The MASSH coordinates the multi-agency response and the statutory investigation (under s.47 or s.17 of the Children Act 1989) is carried out by children’s social care and/or the police — not by Elevated Knowledge Ltd. We give every co-operation to social workers, police and medical staff, including for any arrangements they wish to make for the learner.
4. Informing parents/carers. Our approach is one of transparency and honesty. In most cases parents/carers will be informed when concerns are raised and when a referral is to be made and given the opportunity to address the concerns — unless doing so would place the learner at increased risk, in which case the DSL will act on the advice of the MASSH. Parents are never approached first where forced marriage, FGM or sexual abuse is suspected.
5. Feedback and follow-up. The DSL keeps a written record of every report, referral and outcome (including the date, time and the name and position of the person the matter was reported to), tracks the referral until an outcome is confirmed, escalates where the response is not adequate, and updates the member of staff who raised the concern so far as is appropriate.
6. External meetings. Staff may be asked to attend child protection conferences or core group meetings. Reports are prepared in advance and cover the learner’s physical, emotional and intellectual development and wellbeing, and relevant family issues. We notify the relevant team if a learner subject to a child protection plan is to be excluded or has an unexplained absence of more than two days.
7. Reviews. Where a child dies or is seriously harmed and abuse or neglect is known or suspected, the safeguarding partners will undertake a Child Safeguarding Practice Review (which replaced Serious Case Reviews). Elevated Knowledge Ltd will provide any information or management report required and will fully implement resulting learning, reviewing policy, practice and procedures as required.
9. Allegations and concerns about staff
Any suspicion, allegation or apparent abuse of a learner by a member of staff, a contractor working on site or a volunteer must be reported immediately to the DSL and the Chief Executive. If the allegation concerns the DSL, it must be reported directly to the Chief Executive; if it concerns the Chief Executive, to the Chair of the Board. We follow the procedures of the Stockport Safeguarding Children Partnership. The need for a referral to the Local Authority Designated Officer (LADO) is considered at the point the concern is first raised, rather than once an internal view has been formed, and a referral is made within one working day where the allegation meets the harm threshold. Allegations concerning agency staff, contractors, trainee assessors, associate tutors and volunteers are handled in the same way as allegations about employees: we remain responsible for establishing the facts and managing the safeguarding process, even where the individual’s employer or agency leads on any disciplinary action. Steps will be taken to ensure the safety of the learner; the matter will be dealt with quickly and fairly, protecting the learner while supporting the person against whom the allegation is made. An allegation may result in suspension pending investigation and the application of the disciplinary procedure where appropriate, and referral to the DBS where a person is removed from regulated activity. Low-level concerns about the conduct of adults are also recorded and reviewed by the DSL so patterns can be identified early. Staff who are concerned about poor or unsafe safeguarding practice can also use the Whistleblowing Policy (Section 14) and may contact the NSPCC whistleblowing advice line.
10. Communication, training and CPD for staff
10.1 Communication
• This policy is stored as a controlled document in the quality management system and on the staff HR system (Breathe); any amendment is communicated to all staff by email, and to employers by email and via the OneFile e-portfolio system.
• Safeguarding is a standing agenda item at all Elevated Knowledge meetings, and our commitment to safeguarding is promoted in brochures, on the website and intranet, and displayed in public areas of the centre.
• Learners receive a summary of this policy (position statement) in their induction pack; safeguarding, Prevent and British values are covered at induction and reinforced through periodic online courses, tutorials and placement review visits. All learners are told who the Safeguarding Officers are and how to contact them from the start of training.
• All employers receive a summary of the policy and confirm their understanding and agreement through the Commitment Statement; visiting staff reinforce safeguarding through the review system.
10.2 Training and CPD
• All new staff and volunteers receive safeguarding training at induction, covering this policy, the signs and symptoms of abuse, how to manage a disclosure, and when and how to record a concern.
• All staff and volunteers in regular contact with learners complete at least Level 1 safeguarding training, refreshed at least every two years, plus Prevent training. All staff read Part 1 of KCSIE 2026 in full each year — the condensed Annex A version has been withdrawn — and confirm in writing that they have done so.
• Before 1 September 2026 all staff receive a briefing on the changes introduced by KCSIE 2026 and Working Together to Safeguard Children 2026, covering the Family Help model, harmful sexual behaviour and misogyny, serious violence, modern slavery and the National Referral Mechanism, mental health, AI-related online risks, the updated indicators of abuse, and the safer recruitment changes made by the Crime and Policing Act 2026.
• The DSL and staff with particular safeguarding responsibilities receive enhanced training (Level 2 and above) through the Stockport Safeguarding Children Partnership training offer or other appropriate providers (for example, the NSPCC), refreshed at least every two years with annual updates.
• All safeguarding training is logged on each staff member’s CPD record (IQA-CPD) and monitored through the staff risk profiling tool (IQA-RPT); gaps identified are actioned through the Action and Improvement Plan (IQA-AAIP).
11. Safer recruitment, DBS and insurance
Our recruitment and selection processes adhere to Part 3 of KCSIE 2026 and Working Together to Safeguard Children 2026, including appropriate use of references, online searches on shortlisted candidates and pre-employment checks. All staff who work directly with learners undergo an enhanced DBS check with a children’s barred list check before starting, renewed every five years (or sooner where there is reason). Following the Crime and Policing Act 2026, the “supervision exemption” has been removed: anyone who teaches, trains, instructs, cares for or supervises learners under 18 frequently — three or more days in any 30-day period, or overnight — is engaged in regulated activity whether or not they are supervised, and must hold an enhanced DBS check with barred list check. This applies to volunteers, including those already in post, and where a certificate has not been returned before the individual starts, they are appropriately supervised and all other checks, including a separate children’s barred list check, are completed first. Where an individual is not in regulated activity we consider whether another level of check (enhanced without barred list, or basic) is appropriate. We refer to the DBS any person, including a volunteer, who is removed from regulated activity because they have harmed or pose a risk of harm to a learner. Systems are in place to ensure learners are not working with unsuitable people; placement employers are given good-practice guidance on learner protection, and where a workplace supervisor will supervise a learner under 18 for more than three days in a 30-day period that supervision is regulated activity and the appropriate check is arranged. Work-experience and workplace placements are checked so they do not infringe age or other legal restrictions applying to young persons; risks are assessed and controlled and parents/carers informed. Suitable and sufficient insurance cover is maintained throughout each learner’s apprenticeship.
12. Attendance, records and information sharing
12.1 Attendance, and learners absent or missing from education
Attendance is recorded via the Timenet biometric clocking system and registers are monitored daily by tutors and the Centre Manager, so any unexplained or persistent absence is detected at the earliest stage. Attendance reports are shared with employers and internal staff; learners and parents report absences via the answerphone. We pursue and address all unauthorised absences, implement the statutory requirements for reporting learners missing education, and inform the DSL whenever an exclusion is being discussed so any safeguarding issues are considered. Being absent from education, as well as being missing from education, can be a warning sign of a range of safeguarding concerns — including neglect, sexual abuse, child sexual or criminal exploitation, serious violence and mental ill health — so unexplained or persistent absence is reported to the DSL as a safeguarding matter and not treated solely as an attendance issue.
12.2 Records
We keep up-to-date information on learners including where and with whom the learner is living, attainment, attendance, referrals to and support from other agencies, and any other significant event in a learner’s life. Safeguarding records are kept securely in a locked cabinet or secure system, separate from files to which parents have access, and every concern is followed up.
12.3 Confidentiality and information sharing
Information about a learner is disclosed by the Director or DSL to other members of staff on a need-to-know basis only. All staff understand that they have a professional responsibility to share information with other agencies in order to safeguard learners, in line with UK GDPR, the Data Protection Act 2018 and the DfE information-sharing advice — fear of sharing information must never stand in the way of safeguarding a learner. Staff must be clear with learners that they cannot promise to keep secrets. Photographs and images of learners are personal data: consent is obtained before images are taken or published, images must not identify a learner (use a full name or a photograph, never both), personal devices are not used to store images of learners, and all requests for images of looked-after learners are referred to the responsible social worker. When a learner transfers to another provider, school or college, the DSL sends the safeguarding file securely and separately from the main file, retaining a copy, and shares any information indicating that the learner may pose a risk to themselves or to others. Where there are significant concerns, the DSL speaks directly to the receiving DSL as well as transferring the file. Information shared is necessary and proportionate: irrelevant material is not shared, but relevant context is never withheld.
13. Specific safeguarding issues
13.1 Early help and Family Help
The earlier we pick up on any sign of abuse or change in a learner, the better. Working Together to Safeguard Children 2026 brings targeted early help and section 17 support together into a single Family Help offer, delivered by multi-disciplinary teams under a coordinated plan with a named lead practitioner. All staff should be aware of the criteria for a referral to Family Help, and for a referral for assessment under section 47 of the Children Act 1989, and should raise any concern with the DSL, who leads on referrals and participates in multi-agency working. Staff are alert to the need for additional support for learners who are more vulnerable — for example those with SEND, young carers, learners who are care-experienced or in kinship, foster or residential care, learners who are pregnant or are parents themselves, learners showing early signs of abusive, violent or harmful behaviour towards others, learners repeatedly removed from sessions or on a reduced timetable, and those showing early signs of being drawn into anti-social or criminal behaviour. Where a learner is repeatedly removed from a session or sent home, this is recorded centrally so that patterns can be identified and used to support a referral.
13.2 Preventing radicalisation (Prevent duty)
We comply with the Prevent duty guidance 2023 under the Counter-Terrorism and Security Act 2015. A Prevent policy and risk assessment are maintained and monitored regularly, staff and learners are trained in Prevent, and concerns that a learner may be being drawn into terrorism or extremism are reported to the DSL, who will refer to Channel or the police as appropriate. British values are actively promoted through induction and delivery.
13.3 Forced marriage and honour-based abuse
We are sensitive to differing family patterns and lifestyles across racial, ethnic and cultural groups; however, abuse cannot be condoned for religious or cultural reasons. Forced marriage is a form of abuse and a crime. If forced marriage or honour-based abuse is suspected, parents/carers will not be approached or informed of a referral — the DSL will refer directly to the MASSH and, where appropriate, the Forced Marriage Unit.
13.4 Female Genital Mutilation (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. Under Section 5B of the Female Genital Mutilation Act 2003, teachers and tutors must personally report to the police (101) any case where they discover — through disclosure by the victim or visual evidence — that FGM appears to have been carried out on a girl under 18. Unless there is good reason not to, the tutor should also discuss the case with the DSL and involve children’s social care as appropriate. For at-risk or suspected cases (no disclosure or visual evidence), and for women aged 18 or over, staff follow the standard reporting procedure in Section 7. Failure to report discovered cases may result in disciplinary sanctions.
13.5 Online safety
Learner IT usage is governed by the Internet Safety Policy, which covers use of any equipment, personal or otherwise, together with appropriate filtering and monitoring in line with KCSIE 2026 and the DfE filtering and monitoring standards. Online risks are considered under the four areas of content, contact, conduct and commerce, and expressly include risks arising from generative AI — among them AI-generated or digitally altered sexual images, AI chatbots, AI-generated misinformation, and AI-assisted grooming or fraud; staff and learners are directed to the DfE guidance on generative artificial intelligence in education. Making or sharing nudes and semi-nudes, whether or not the learner appears to have consented, is a safeguarding concern and requires a response proportionate to the learner’s age and to any element of coercion or vulnerability. Other online safety concerns — grooming, cyber-bullying, sexual harassment and online radicalisation — are safeguarding alerts and must be reported under Section 7. A named senior manager, supported by the DSL and our IT provider, is responsible for filtering and monitoring: the systems are checked at least once every academic year, at every site and on all internet-connected devices, and a written record of each check and of any action taken is retained for audit. Learner use of mobile phones is governed by the centre rules issued at induction; phones are not used during taught sessions or practical workshop activity, both for safeguarding and for health and safety reasons.
13.6 Harmful sexual behaviour, sexual harassment and misogyny
We take a zero-tolerance approach to sexual harassment, sexual violence and harmful sexual behaviour, and to the misogyny, sexism and other prejudice that can normalise them. Harmful sexual behaviour sits on a continuum, from behaviour that is developmentally expected, through inappropriate and problematic behaviour, to abusive behaviour and sexual violence. Staff do not dismiss such behaviour as banter, as “having a laugh” or as part of workshop culture, and the absence of reports is not taken as evidence that it is not happening. All incidents — including sexualised comments, jokes and name-calling, unwanted physical contact, upskirting, and the making or sharing of nudes and semi-nudes, including AI-generated or digitally altered images — are reported to the DSL under Section 7 and recorded, so that patterns involving individuals or groups can be identified. The DSL considers the needs of the learner who has been harmed and of the learner who has caused harm, carries out a risk assessment, arranges support and, where appropriate, refers to the MASSH or the police. Preventative education on healthy relationships, consent, respect and online conduct is delivered through induction, tutorials and review visits.
13.7 Serious violence
Staff are alert to the indicators that a learner may be at risk of involvement in serious violence: increased or unexplained absence, disengagement from training, changes in friendship groups or relationships with older individuals, a marked decline in performance, unexplained gifts or money, unexplained injuries or signs of assault, and a history of offending. Any concern that a learner is carrying a weapon, has threatened to use one or has used one must be reported to the DSL immediately; where there is an immediate risk to any person, staff call 999 first. The DSL assesses the risk, takes appropriate action and refers to the police and the MASSH as necessary. Learners who commit violence are frequently victims themselves, so early support is offered alongside any statutory or disciplinary response.
13.8 Mental health and emotional wellbeing
We take a whole-centre approach to mental health and emotional wellbeing. Staff are not mental health professionals and do not attempt to diagnose, but they are well placed to notice change and must report any concern to the DSL the same working day. Self-harm, suicidal ideation and risk of suicide are safeguarding concerns in their own right. Potential warning signs include changes in behaviour or mood, sleep difficulties, withdrawal from social situations, loss of interest in things the learner usually enjoys, and physical signs of harm or neglect. Where mental ill health is thought to be a result of abuse, neglect or exploitation, the reporting procedure in Section 7 applies in full. Where a learner is believed to be in immediate danger, staff call 999 or arrange for the learner to be taken to A&E; where the situation is urgent but not an emergency, NHS 111 is used. The DSL considers what support to arrange and, for learners under 18, whether to involve parents or carers, and records the decision and the reasons for it. Mental health first aiders are available in the centre every day.
13.9 Modern slavery, exploitation and the National Referral Mechanism
Child criminal exploitation and child sexual exploitation may be organised or facilitated by a network or gang of which the learner appears to be a willing part; apparent consent does not change the fact that it is abuse. Both may amount to modern slavery or human trafficking. Where a learner is identified as a potential victim, the DSL makes a referral through the National Referral Mechanism in addition to referring to the MASSH and, where a crime is suspected, the police. Staff report any indicator — unexplained money, gifts or phones, older associates, going missing, travel to unfamiliar areas, unexplained injuries, secretive behaviour or apparent debt — under Section 7.
13.10 Learners questioning their gender
KCSIE 2026 incorporates statutory guidance for schools and colleges on responding to children who are questioning their gender. The Board has adopted the following position for learners under 18. It is not for the centre to initiate any action; the guidance applies where a learner, or their parent or carer, raises a request to socially transition. Parents and carers are involved as a matter of priority and their views carry significant weight, other than in the rare circumstances where involving them would place the learner at risk of harm, in which case the DSL decides what action to take. Requests are considered individually, taking account of the learner’s best interests, the impact on other learners, and safety; a written record of the request, the discussion and the decision is kept. Toilets, changing and washing facilities are provided on the basis of biological sex; where a learner does not wish to use the facilities for their sex, the centre considers whether an alternative — for example a self-contained single-use facility — can be provided without compromising the safety, privacy or dignity of other learners. Staff apply the Equality Act 2010 and our Equality and Diversity Policy throughout and treat every learner with respect. Any learner who is distressed or at risk is supported through the safeguarding procedures in this policy in the usual way.
13.11 Out-of-hours arrangements
Safeguarding Officers are available on the dedicated line during office hours (0161 475 5840, ext 2) and via safeguarding@elevatedknowledge.co.uk. Outside office hours, concerns should be raised with the Stockport MASSH (0161 217 6028 / www.stockport.gov.uk/contacting-the-massh) or, in an emergency, the police on 999.
14. Staff code of conduct (summary) and whistleblowing
All staff follow the Safeguarding Code of Conduct. In summary, staff must not: spend excessive time alone with learners away from others (if privacy is needed, the door remains open and colleagues are made aware); make unnecessary physical contact; transport a learner alone in a car except with the full knowledge and consent of parents/guardians; meet learners outside the work environment; start their own investigation or question anyone once a concern has been raised; engage in or tolerate sexually provocative conversation or inappropriate language; do things of a personal nature for learners that they can do themselves; trivialise or exaggerate abuse issues; promise confidentiality; or show favouritism or threaten any form of physical punishment. Staff must: respect learners’ rights to privacy; declare any pre-existing relationships with learners; be aware of the reporting procedures and the Safeguarding Officers’ contact details; make others aware if they become the subject of inappropriate affection or attention; and report any concern about the actions or behaviour of another member of staff. Staff who have concerns about malpractice, unsafe practice or misconduct may raise them through the Whistleblowing / Confidential Reporting Policy — first with their line manager, then the Director, then the Chair of the Board — and will not suffer any form of retribution for raising a genuine concern in good faith. If in doubt — raise it.
15. Monitoring and review
The DSL monitors all safeguarding concerns, referrals and outcomes, and reports to the Board of Directors, which reviews safeguarding at each meeting and formally reviews this policy at least annually. A summary of monitoring information is included in the annual report where this does not breach confidentiality. Training completion, DBS renewal and policy acknowledgement are tracked through the HR system and CPD records, and audit findings are actioned through the Action and Improvement Plan (IQA-AAIP) in line with ISO 9001:2015 (Clauses 9.1 and 9.3). This version adopts Keeping Children Safe in Education 2026 with effect from 1 September 2026 and reflects Working Together to Safeguard Children 2026. It will be reviewed by 31 August 2027, or sooner if legislation, statutory guidance or local procedures change. Confirmation that every member of staff has read Part 1 of KCSIE in full, and the record of the annual filtering and monitoring check, are reported to the Board each autumn term.
16. Related documents
• Health and Safety Policy
• Whistleblowing / Confidential Reporting Policy
• Bullying and Harassment Policy
• Safe Recruitment Policy
• Prevent Policy and Prevent Risk Assessment
• Internet Safety Policy
• Data Protection Policy
• Complaints Policy and Grievance Procedure
17. Version history
Version Date Summary of changes Reviewed / approved by
V6 19 August 2025 Updated for KCSIE September 2025. HR / Centre Manager
V7 24 July 2026 Full review and restructure into controlled policy format. DSL named with contact details throughout (Louise Pollitt). Legislation and guidance updated: Working Together to Safeguard Children 2023, KCSIE 2025 (KCSIE 2026 noted for adoption 1 Sept 2026), Prevent duty guidance 2023, Children Acts 1989/2004, Safeguarding Vulnerable Groups Act 2006, UK GDPR/DPA 2018. Obsolete references removed (Every Child Matters, Common Assessment Framework, Serious Case Reviews replaced by Child Safeguarding Practice Reviews, ACPC/SSCB replaced by Stockport Safeguarding Children Partnership). Added: purpose and scope; examples of safeguarding alerts with indicators; consolidated reporting procedure; investigation and referral process; monitoring and review section. DRAFT watermark removed. Board of Directors
V8 3rd August 2026 Updated to adopt Keeping Children Safe in Education 2026 (in force 1 September 2026) and Working Together to Safeguard Children 2026 (which replaced the 2023 edition). Key changes: all staff to read Part 1 of KCSIE in full, the condensed Annex A version having been withdrawn; robust, known DSL cover arrangements and a confidential shared safeguarding mailbox; early help replaced by the integrated Family Help model, with an expanded list of learners who may need additional support; updated indicators of abuse (modern slavery, child-to-parent or caregiver abuse, verbal abuse, medical conditions, serious violence, absence from education); “making or sharing nudes and semi-nudes” terminology, including AI-generated and digitally altered images; new sections on harmful sexual behaviour, sexual harassment and misogyny, serious violence, mental health and emotional wellbeing (with self-harm and suicidal ideation named as safeguarding concerns in their own right), modern slavery and the National Referral Mechanism, and learners questioning their gender; online safety updated for generative AI and the four Cs, with an annual, recorded check of filtering and monitoring by a named senior manager; earlier consideration of LADO referral and parity of treatment for agency, contract and trainee staff; strengthened transfer of safeguarding files and direct DSL-to-DSL contact; safer recruitment updated for the Crime and Policing Act 2026, which removes the supervision exemption so that volunteers and workplace supervisors in frequent contact with under-18s require an enhanced DBS check with barred list check. DSL/Senior management team
Appendix A — Safeguarding Incident Report Form
Complete this form for any safeguarding concern, disclosure or incident and pass it to the Designated Safeguarding Lead (Louise Pollitt) the same working day. Record facts, not opinions, using the learner’s own words where possible. Do not investigate.
Date of report: Date/time of incident or concern:
Learner name: Section / Company:
Referred by (name and role):
Incident / concern being reported (facts only, learner’s own words where possible):
Reported to (name, role, date and time):
Outcome / action taken (completed by the DSL):
Agreed with Elevated Knowledge Ltd — name and date: Review date:
For print friendy version of this document or for safeguarding form please click the links below: