It was consulted on in December 2015 and now the new guidance has been issued ready for implementation in September 2016. What will it mean practically for schools? Suzanne O’Connell considers the implications.
The Department for Education (DfE) has now published its response to the consultation on changes to Keeping Children Safe in Education as well as the new, statutory guidance itself. The new guidance came into effect on 5 September 2016 and the Government’s response document makes it clear that we can anticipate more changes to section 3 and section 4 at a later stage. It is very important that schools engage with the changes that have been made as soon as possible.
The statutory guidance included in Keeping Children Safe in Education May 2016 replaces that issued in July 2015. It is divided into four parts. All parts must be read and followed by governing bodies of maintained schools and proprietors of independent schools. However, Part one is targeted at all those working in schools and must be read by all staff.
This is the section that includes information for staff about what they should know, what they should look out for and what they should do if they have a safeguarding concern about a child, a staff member or safeguarding practices.
It clearly states that all staff should be familiar with:
the child protection policy
the staff behaviour policy or code of conduct
the role of the designated safeguarding lead.
Schools should schedule at least some training on the new guidance into their plans for the beginning of the year. It is most important that all staff are familiar with at least part one and that the senior leadership feel confident that the staff understand what their roles and responsibilities are. This is no tick-box activity, as the DfE points out.
The key theme is that safeguarding is not only the responsibility of the designated safeguarding lead (DSL) but every member of staff in the school. As such, everyone must not only be familiar with part one but understand it too. This does not just refer to teaching staff and schools are advised to “err on the side of caution” when deciding who should receive safeguarding training.
The DfE is keen to ensure that safeguarding is kept in the forefront of whole school discussions. With this in mind, it is now expected that staff should be updated on safeguarding and child protection at least annually. This could take place through email, e-bulletins and staff meetings and it is likely that the majority of schools already comply with this.
There is no formal requirement for schools to increase the frequency of training but instead it is left to the discretion of schools themselves. However, it remains that all staff should have training at induction and appropriate training should be given and updated as needed.
While building this into your CPD programme, it is worthwhile also reviewing the training of your DSL. They might benefit from training on the newly released guidance early in the school year, if they have not received it already. It is also worth reviewing their awareness of other safeguarding issues such as online safety and ensuring that they have some knowledge of all the areas specified on pages 12 and 13 of the guidance.
Review of policy
This is a good time to review your safeguarding policy. The DfE’s response to the consultation accepts that many schools may have a “child protection policy” rather than a “safeguarding policy” and if they do there is no need to duplicate. Whatever the title of the policy, staff should be able to contribute to it.
It is important that the wording of the policy reflects the fact that safeguarding is everyone’s responsibility while also outlining the roles of the DSL and other senior leadership, including governors, in the school.
Early detection of problems is an important part of the new guidance which states:
“All staff should be aware of the early help process, and understand their role in it. This includes identifying emerging problems, liaising with the designated safeguarding lead, sharing information with other professionals to support early identification and assessment and, in some cases, acting as the lead professional in undertaking an early help assessment.” P. 6
Make sure in your policy that there is reference to staff alerting the DSL sooner rather than later to any concerns they might have. Everyone has a responsibility both to act and follow up if there seems to be lack of action from other responsible people.
Anyone can make a referral at any time and not just the DSL. It is insufficient to sit back and say that you have told someone about it. Your policy should provide clear information about what actions staff should take if they have a concern and what they should do if a child in is immediate danger. Their understanding of this should be checked and explored.
Specific areas of safeguarding receive additional attention in the new guidance. Check your policy for information about confidentiality. This section has been moved from part two to part one, indicating the importance of staff being aware of what their responsibilities are. Whistleblowing should also have a prominent section and staff should understand what is meant by this and why it is necessary. A new NSPCC whistleblowing helpline is referred to in the guidance and this might usefully be included in your safeguarding policy too.
A new section has been included on online safety. Schools and colleges must have the appropriate monitoring and filtering systems in place. It is important to check with the IT co-ordinator and any other individual who has responsibilities for this that school practice is in line with the guidance. For schools who are anxious about what systems to use, the DfE cross reference to the UK Safer Internet Centre. In making decisions, they suggest that “measures taken are proportionate to the risks”.
Make sure that there is information in your policy about the duty to report Female Genital Mutilation to the police. It is made clear in the statutory guidance that it is the teacher who must make the report and Annex A includes more detailed information about how this should be done.
Review of roles
Although the new guidance is clear in the responsibilities that everyone holds, the DSL still remains a key individual responsible for co-ordinating safeguarding responsibilities and receiving and providing advice. The new guidance highlights the importance of having a deputy in place who is available in their absence. The cover arrangements are reviewed in the new guidance and you should check this against your own arrangements.
It is made clear that there must be someone available at all times to receive concerns and staff should know who this is. It is worthwhile at this stage reviewing the DSL’s job description against the guidance given, ensuring that training is sufficiently up-to-date for them to carry it out.
Safeguarding — a continued focus
While many aspects of school life are no longer open to the same level of scrutiny as they once were, safeguarding has never dropped from being a vital requirement. This renewed guidance and the emphasis on shared responsibility makes it even more important that staff are clear about what exactly it means for them.