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Safeguarding and child protection policy

About this policy

Waverley Training Services (WTS) whom operates within Commercial Services of Waverley Borough Council (WBC) has a statutory duty to safeguard children, young people and vulnerable adults receiving education and training, and to ensure that this document is kept up to date and in line with the latest guidance but not limited to the Department for Educations (DfE) Keeping Children Safe in Education KCSIE, Working Together to Safeguard Children and the Vulnerable Groups Act 2006.

WTS recognises the role it plays and its obligations, alongside other local services in the protection, welfare and wellbeing of children and it actively promotes the expected outcomes set out in government regulations.

The term ‘children’ as per the guidance from KCSIE refers to anyone under the age of 18 years old.

Aims and scope

The main aim of this policy is to ensure that safeguarding guidance is adhered to at all times and to which remains the ultimate responsibility of the Governors appointed, the responsibility is delegated to the Safeguarding Governor who leads on policy issues in relation to all safeguarding concerns at WTS.

WTS Safeguarding Governor: Sam Hutchison

The Governors are responsible for overseeing safeguarding and appointing a Designated Safeguarding Lead who will operationally, be at the forefront of safeguarding and child protection issues for WTS alongside the deputy.

All employees are to report to the Designated Safeguarding Lead (DSL) or Deputy Designated Safeguarding Lead (DDSL) any concerns regarding safeguarding of any of its Learners and/or concerns regarding its employees, visitors or other individuals such as volunteers or contractors.

Designated Safeguarding Lead: Krystel Rajewski

Deputy Designated Safeguarding Lead: Charmaine Winter

Our commitment

WTS is committed to ensuring the highest standards of safeguarding for all its employees, learners and visitors, this is to ensure that safeguarding is at the centre of everything we do. We recognise the following:

  • WTS shall ensure that all employees engaged in the provision of the service are subject to a valid enhanced disclosure check undertaken through the Disclosure and Barring Service (DBS).
  • To ensure that all employees, learners and visitors understand that safeguarding is everyone’s responsibility and recognise that everyone has a role to play in keeping children, young people and vulnerable adults safe and free from harm.
  • WTS has a duty to refer information about any person working with a learner who has harmed or poses a risk of harm to any service users.
  • WTS has ultimate responsibility for the management and control of the Regulated Activity provided under the Safeguarding Vulnerable Groups Act 2006, which underpins and is illustrated in documentation such as service level agreements (SLAs).
  • Record and check the details of all visitors to our premises.
  • To follow safer recruitment guidance and HR process.

Operational Safeguarding Group (OSG) and Strategic Safeguarding Group (SSG)

WTS are associated with the Operational Safeguarding Group (OSG) for WBC which disseminates information from the Strategic Safeguarding Group (SSG), with the overall objectives:

  • To promote the welfare of children, and adults, consistent with statutory guidance and best practice.
  • To share the best practice between services.
  • To implement learning from thematic reviews through service delivery.
  • To implement corporate and service-based policies and procedures including: the action to be taken where there are concerns about the safety or welfare of a child or of an adult.
  • To identify training needs across service delivery.
  • To challenge the effectiveness of what is done to safeguard and promote the welfare of children and of adults through service delivery.
  • To ensure effective record keeping and information sharing within service delivery.

Surrey Safeguarding Children Partnership (SSCP)

The SSCP coordinates local work to safeguard and promote the welfare of children and to ensure the effectiveness of what the member organisations do individually and together by developing interagency policies and procedures for safeguarding and promoting the welfare of children including:

  • The action to be taken where there are concerns about a child’s safety or welfare.
  • Training those working with children and/ or families in services effecting the safety and welfare of children.
  • Investigations of an allegation concerning persons working with children.

Monitoring arrangements

The implementation of the WTS safeguarding policy and processes will be monitored by the DSL at monthly safeguarding meetings held with the DDSL. Any concerns will be raised with the WBC Operational Safeguarding coordinator.

Safeguarding is discussed, monitored and reported in senior management meetings. A summary report will then be forwarded to the Governors meeting for further consideration.

We will seek to keep children, young people and vulnerable adults safe by:

  • Valuing, listening to, and respecting them.
  • Appointing a Designated Safeguarding Lead (DSL), a Deputy Safeguarding Lead (DDSL), and a lead Safeguarding Governor.
  • Adopting child protection and safeguarding best practice through our policies and procedures.
  • Developing and implementing an effective Acceptable ICT Use and Online Safety policy and related procedures.
  • Providing effective management for all its employees through supervision, support, training and quality assurance measures.
  • Recruiting safely, following WBC Safer Recruitment policy and ensuring all necessary pre-employment checks are made before employment is offered.
  • Recording and storing information professionally and securely.
  • Sharing information about safeguarding and relevant good practice with learners and employers.
  • Using our safeguarding procedures to share concerns and relevant information with agencies, young people, parents, families and carers appropriately.
  • Using our procedures to manage any safeguarding concerns and/ or allegations against employees appropriately.
  • Creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to support in dealing effectively with any bullying should it arise.
  • Ensuring that we have effective complaints and whistleblowing policies in place.
  • Ensuring that we provide a safe physical environment for our learners, by applying health and safety measures in accordance with the law and regulatory guidance.

Safeguarding and the Online Safety Act

The ‘staying safe’ outcome includes aims that children, young people and vulnerable adults are:

  • Safe from maltreatment.
  • Safe from accidental injury or death.
  • Safe from bullying and discrimination.
  • Safe from crime and anti-social behaviour in and out of education or training.
  • Secure, stable and cared for.

These aims equally apply to the digital world that children, young people and vulnerable adults will encounter whenever they use IT in its various forms. For example, there is a need to protect Learners from harm such as:

  • The use of the internet for grooming children, young people and vulnerable adults with the ultimate aim of sexual exploitation.
  • The use of IT as a platform for bullies, who may torment their victims via websites, online forums, text or email messages.
  • Exposure to inappropriate content when online, which can lead to their involvement in County Lines and/or anti-social behaviour.

It is the responsibility and duty of all employees to ensure every child, young person and vulnerable adult in their care is safe and the adopted principles apply to the ‘Virtual’ digital world as would apply to if they were attending the premises in person.

The KCSIE guidance have classified issues in regard to online safety into four categories:

  • Content: being exposed to illegal, inappropriate, or harmful content, for example: pornography, racism, misogyny, self-harm, suicide, antisemitism, radicalisation, extremism, misinformation, disinformation (including fake news) and conspiracy theories.
  • 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: online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying.
  • Commerce: risks such as online gambling, inappropriate advertising, phishing and or financial scams. If you feel your pupils, students or staff are at risk, please report it to the Anti-Phishing Working Group.

All Safeguarding concerns must be reported to the DSL or the DDSL in their absence. In the event that neither the DSL nor the DDSL is available, any concerns should be reported to a senior member of management.

The Online Safety Act 2023

The Online Safety Act 2023 is a new set of laws that protect children and adults online. It places a range of duties and responsibilities on social media companies and search services making them more responsible for their users’ safety when on their platforms. The Act will give internet providers new duties to implement systems and processes to reduce risks when their services are used for illegal activity, and to take down illegal content when it does appear.

Ofcom are now the independent regulator of online safety, and it has a broad range of powers to assess and enforce providers compliance within the framework. The Act has codes of practice and related criminal offences which will support in tackling the following but is not limited to:

  • Age-appropriate experiences for children online.
  • Providing adults with more control over the content they see.
  • The Act will tackle suicide and self-harm content.
  • It will tackle harmful algorithms.
  • The Act will protect women and girls.

Filtering and monitoring

The Council and Addcom regularly logs the use of its ICT equipment and systems. The Council may need to monitor, intercept and record the use of such systems, to ensure its use is not placing Council systems and/ or services including your PC, at risk or is otherwise inappropriately being used.

To ensure it complies with its own legal obligations the Council and Addcom may monitor and record.

  • Times, periods of patterns of internet use, websites accessed, connection lengths.
  • Frequency, times and patterns of use of email use, email addresses to which you have sent emails and the size of attachments.
  • Telephone calls primarily for the protection of employees.

At WTS there is user-based internet filtering, allowing an appropriate level of browsing permission for different age groups, following the guidance from the DfE’s KCSIE.

The following are examples of blocked categories: Discrimination, Explicit Violence, Extremists groups, Gambling, Dating, Weapons, and Pornography.

Websites and services are reviewed individually from permitted categories such as social media, entertainment, streaming media and instant messaging.

Use of WTS ICT equipment and systems to bypass such restrictions is strictly prohibited and could lead to disciplinary. In the event of accidental breach please seek immediate guidance and support from your Line Manager or the Data and Administration Manager.

Training

All employees are required to undertake the relevant safeguarding training annually or as appropriate when legislation or guidance is amended. WTS holds a single central register detailing Governors and employees safeguarding qualifications and training received, its validity and other appropriate information such as DBS (Disclosure and Barring Service) information including dates issued.

The DSL manages and oversees the content and delivery of the training, regularly reviewing the training records. In their absence, full responsibility will fall to the DDSL.

Any senior managers who support with the recruitment process will undertake a relevant safer recruitment qualification and read Section 4 of KCSIE. Confirmation of this will be retained on file.

Assistant Director and Governors will hold a relevant Safeguarding Governor qualification.

The Centre Manager holds:

  • Designated Safeguarding Lead L3.
  • Adults Safeguarding L3.
  • Safer Recruitment in Education.

The DSL and the DDSL hold the following qualifications:

  • Designated Safeguarding Lead L3.
  • Adults Safeguarding L3.
  • Safer Recruitment in Education.
  • Sexual Harassment for Managers & Supervisors.
  • Online Safety and Harms.

All other employees will hold a minimum of L2 Safeguarding qualification.

Allegations made against employees

We recognise that whilst employees at WTS are committed to the wellbeing and care of Learners, there exists a range of abuse perpetrated by employees that despite best efforts and interventions could still take place.

Any safeguarding concerns or allegations that may relate to an employee including a volunteer who works with Learners and/or who has behaved inappropriately and may pose a risk of harm to Learners will be follow the below process.

We follow the guidance KCSIE when it comes to raising concerns about an employee and any such concerns will be referred on to the DSL and/or DDSL.

Where there are concerns raised against the Teaching and Learning Manager, this must be referred on to the chair of governors. It will additionally need to be referred on to the LADO (Local Authority Designated Officer).

Low level concerns

There may be incidents which do not meet the safeguarding threshold for harm but still warrant the attention of addressing and reporting minor concerns about an employee, volunteer, or contractor.

  • It may include behaviour that which is inconsistent with the Code of Conduct, Behaviour policy including conduct outside of work and that which is not serious enough to warrant a formal referral to authorities.
  • It does not meet the threshold of harm or is not considered serious enough for a setting to refer to the LADO.

Low-level concerns may include:

  • Inadvertent or thoughtless behaviour.
  • Behaviour that might be considered inappropriate depending on the circumstances.
  • Behaviour which is intended to enable abuse.

Example behaviours may include:

  • Being over friendly with children.
  • Having favourites.
  • Adults 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.
  • Using inappropriate sexualised, intimidating, or offensive language.

All concerns should be reported to the DSL or the DDSL in their absence. Where there are circumstances where neither the DSL nor DDSL are available, the centre manager should be contacted.

Centre Manager: Adele O’Sullivan

External partners

All employers are responsible for ensuring that adequate measures are in place to safeguard Learners within the workplace. Employers can contact the DSL or DDSL to seek advice or guidance regarding any safeguarding concerns and/or if they would like to report a safeguarding or potential safeguarding issue.

All employers when entering into a contract with WTS will sign a Service Level Agreement (SLA) to ensure they understand the guidance placed on them as the employer, alongside WTS commitments to safeguarding and provide relevant contact information on how to report a concern.

Any Learner starting an Apprenticeship alongside their line manager will sign an Apprenticeship agreement to reiterate their commitment not only to the Apprenticeship but to statutory guidance such as safeguarding whilst on programme.

Data protection, information sharing and record keeping

Concerns of safeguarding could result in personal data being shared without consent of the data subject, the data protection regulations do not apply whereby a child, young person or vulnerable adult is at risk of immediate harm.

However, the individual will be informed that any disclosure made to the DSL or DDSL cannot be withheld if there is a risk of immediate harm, the individual will be kept up to date as to any action taken and with whom.

All personal information regarding an at-risk child, young person or vulnerable adult that identifies them, will be retained in line with WTS Data Protection (GDPR) and Privacy policy.

All written records will be kept on a secure cloud storage system which is accessible by authorised personnel only. All records will also be destroyed in line with our document retention guidance from the DfE and WBC.

WTS will ensure that access is available for those who need to know, but for all others will remain strictly confidential. For full information please see our Data Protection policy and procedures.

Monitoring and reporting

This policy will be reviewed annually and/ or when legislation or guidance is amended or introduced.

Version 3

Published date: September 2026

Review date: September 2027