Supply Staff Limited

Safeguarding of Vulnerable Children Policy

Policy Statement

Supply Staff Limited is committed to ensuring the safety and security of every child and young person with whom its employees, contractors and temporary workers come into contact and as such we have in place stringent safeguards to protect the children and young people with whom we work.  

This policy also covers the practices and reporting procedures for our employees, contractors and temporary workers should they suspect that any form of abuse or neglect is taking place.  

This policy is drawn from the guidance and requirements outlined in the following legislation and regulations:

  • Keeping Children Safe In Education 2023

  • The Rehabilitation of Offenders Act 1974

  • The Children Act 1989 and 2004

  • The Police Act 1997

  • The Protection of Children Act 1999

  • Criminal Justice and Court Services Act 2000

  • Care Standards Act 2000

  • Human Rights Act 2000

  • Education Act 2002

  • Education (Health Standards) Regulations 2003

  • Sexual Offences Act 2003

  • Children Act 2004

  • Childcare Act 2006

  • Further Education Regulations 2006

  • Safeguarding Vulnerable Groups Act 2006

  • Childcare (Disqualification) Regulations 2009

  • Equality Act 2010

  • The Health and Care Act 2022

  • The Children & Families Act 2014

  • The Education (Independent School Standards) Regulations 2014

The company’s aim is to provide a service that enables children to feel happy and secure and to allow parents, families and any other relevant parties to feel confident that the people providing the services are trustworthy, responsible and will do everything they can to keep children safe from harm by ensuring:

  • The status of all staff, contractors and temporary workers taking part in any regulated activity is checked against the DBS register;

  • We do not engage an employee, contractor or temporary worker to take part in regulated activity if they are on the children’s barred list;

  • That if we dismiss or remove an employee, contractor or temporary worker because they have harmed a child, or we would have done so if they had not left, we will inform social services and the DBS;

  • We obtain an Enhanced DBS Certificate for every employee and temporary worker taking part in a regulated activity and accept portability (i.e. DBS Certificates, provided either by the individual involved, where the applicant is registered with the DBS Update Service and has provided an original certificate. These are obtained by Supply Staff prior to the employee or temporary worker commencing any regulated activity and thereafter annually and/or the DBS Register will be checked for candidates who have paid to be registered on the DBS Registration Service. Candidates are not be allowed to participate in regulated activity without a valid DBS check;

  • Employees, contractors and temporary workers are trained to understand the different types of abuse, the indicators for each of these and the procedures to follow if they suspect such abuse is taking place;

  • We consistently update training for employees and temporary workers to reflect statutory guidance and good practice guidance including where and how to report any concerns relating to suspected abuse or neglect;

  • We assist Local Authorities in meeting their obligations under The Health and Care Act 2022 by reporting suspected risks or actual abuse or neglect where appropriate to the CQC, the Local Authority, and the Police if a criminal offence may have occurred within 24 hours of becoming aware of the situation;

  • That this policy is available in accessible formats to children themselves, parents, carers, social services and any other relevant statutory or voluntary organisation or individual engaged in regulated activity.

Supply Staff Limited has a zero-tolerance approach to dealing with child abuse and neglect.

Scope of the Policy

It is the duty of all employees, contractors and temporary workers to comply with this policy.  All employees, contractors and temporary workers are made fully aware of this policy and of their duties and responsibilities under the above legislation as part of the company’s induction programme.

This policy applies to all children regardless of sex; race (including colour, nationality, ethnic or national origin); religion or belief; age; disability; marital status and civil partnership; sexual orientation; gender reassignment; pregnancy and maternity.

Definitions

Safeguarding and promoting the welfare of children is defined within this policy as protecting children from maltreatment; preventing impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and acting to enable all children to have the best outcomes. 


CHILDREN

A child is a person under the age of 18

REGULATED ACTIVITY

An individual is engaged in regulated activity if they are providing any of the following activities as part of their role:

  • Healthcare

  • Personal care

  • Social work

  • Assistance with cash, bills or shopping

  • Assistance with the conduct of their own affairs

  • Conveying services

In addition, regulated activity also includes where an individual is providing “unsupervised” teaching, training, supervision, caring for or supervision of children where these activities are undertaken frequently.  Frequently is determined as:

  • Once a month or more

  • Three or more days in any 30-day period

  • Overnight between the hours of 2am and 6am  

RELEVANT CONDUCT

  • Relevant conduct is an action or inaction that has harmed or placed a child at risk of harm.  Relevant conduct in relation to children is conduct which:

  • Endangers a child or is likely to endanger a child

  • If repeated against or in relation to a child, would endanger a child or would be likely to endanger them

  • Involves sexual material relating to children (including possession of such material)

  • Involves sexually explicit images depicting violence against a person (including possession of such images), if it appears to DBS that the conduct is inappropriate

  • Is of a sexual nature involving a child, if it appears to DBS that the conduct is inappropriate.

Specific examples of relevant conduct include:

  • Psychological / emotional harm caused by an action or inaction that causes mental anguish;

  • Physical harm caused by any physical action or inaction that results in discomfort, pain or injury;

  • Sexual harm such as coercion or force to take part in sexual acts;

  • Neglect caused by failure to identify and / or meet care needs.

HARM

All forms of ill-treatment and impairment of, or an avoidable deterioration in physical or mental health  and impairment of physical, intellectual, emotional, social or behavioural development.
A person’s conduct endangers a child if they:

  • Harm a child;

  • Cause a child to be harmed;

  • Put a child at risk of harm;

  • Attempt to harm a child;

  • Incite another to hard a child.

HARM TEST

To satisfy the harm test there needs to be credible evidence of a risk of harm to children such as statements made by an individual regarding conduct/behaviour, etc.  For a case to be considered as a risk of harm, relevant conduct would not have occurred but there must be tangible evidence rather than a “feeling” that a person represents a risk to children. For example, a healthcare professional who confides to another worker that they are sexually attracted to children (but who had not engaged in ‘relevant conduct’) would satisfy the harm test.

POTENTIAL SOURCE OF RISK

Any individual who is believed to be responsible for, or implicated in, the abuse of a child or young person. This may include: 

  • Relatives and family members;

  • Professional staff including teachers;

  • Paid care workers;

  • Volunteers;

  • Neighbours;

  • Friends and associates;

  • People who deliberately exploit vulnerable people and strangers.

Responsibilities

It is the direct responsibility of the Recruitment and Compliance Manager to ensure the implementation of this policy on a day-to-day basis; however, all employees have a responsibility to accept their personal involvement in applying it and must be familiar with the policy and ensure that it is followed by both themselves and employees, contractors and temporary workers for whom they have a responsibility.

Disciplinary action may be taken against any employee who acts in breach of this policy. Disciplinary action may include summary dismissal in the case of a serious breach of this policy or repeated breaches. In other cases, it may include a warning, oral or written. Such action will be taken in accordance with the Company’s disciplinary procedure.

Breaches of this policy may also result in the employee responsible being held personally liable if legal action is taken in relation to safeguarding issues.

Procedures

SAFE RECRUITMENT PROCEDURE

When recruiting staff, contractors or temporary workers to take part in regulated activities involving children, Supply Staff ensures that the following:

  • Interviews are conducted by trained staff who have received guidance in relation to current legislation and best practice pertaining to the recruitment and placement of candidates who are to take part in regulated activity;

  • The candidate’s personal identity is verified by checking an original form of recent photographic identification;

  • Qualifications and training relevant to the role being recruited is verified by checking original certificates and validating these for authenticity with the awarding body;

  • A thorough biographical interview takes place to establish the candidate’s employment history and identify any gaps in employment;

  • A minimum of two written references is obtained covering a minimum of three years employment and verification will be sought for any gaps in candidate’s employment history of over three months duration;

  • All candidates are checked to confirm that they are not barred from participating in regulated activity with children or young people;

  • An enhanced DBS check is undertaken prior to commencement of regulated activity and/or the DBS Register is checked for candidates who have paid to be registered on the DBS Registration Service. Such candidates are also required to provide the original of their enhanced DBS check for validation. As a company, we accept portability of DBS certificates and the enhanced DBS check will be renewed or the register checked every year or if there has been a gap of more than three months between assignments. Candidates will not be allowed to participate in regulated activity without a valid enhanced DBS check;

  • Candidates are required to complete an application form which includes a declaration stating that there is no reason why they should be considered unsuitable to work with children or young people (including past convictions, cautions, bind-overs or pending cases) and that they have not been barred from carrying out regulated activity.

TYPES OF ABUSE

Abuse is the violation of an individual’s human rights and can take the form of a single act or repeated acts and includes maltreatment by inflicting harm or failing to prevent harm by an adult or another child.  The main types of abuse relating to children include:

  • Physical - This is when a child is hurt or injured by a child or an adult. Physical abuse includes hitting, shaking, throwing, kicking, punching and other ways of inflicting pain or injury such as poisoning, drowning or smothering. It also includes giving a child harmful drugs or alcohol.  Physical harm may also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness in a child.

  • Sexual - This is when a child is forced or enticed to take part in sexual activities by an adult (irrespective of whether the child is aware of what is happening). Sexual abuse can include physical contact kissing, touching, vaginal or anal intercourse and oral sex. Encouraging a child to look at or become involved in the production of pornographic images or watch sexual activity is also sexual abuse.  It also includes grooming a child in preparation for abuse.

  • Emotional / Psychological – Persistent emotional maltreatment as to cause severe adverse effects on the child’s emotional development.  This is when adults deny children love or affection, or constantly threaten or humiliate them. Sarcasm, degrading punishments and ignoring a child are also forms of emotional abuse and undermine a child's confidence and sense of self-worth.  It may also include not giving the child opportunities to express their views, deliberately silencing them or making fun of what they say or how they communicate and may feature age or developmentally inappropriate expectations being imposed (e.g. interactions that are beyond a child’s developmental capability, overprotection, limitation of exploration and learning, preventing participation in normal social interaction, bullying or cyber bullying, hearing or seeing ill treatment of another, causing fear, exploitation or corruption of children).

  • Neglect - This is when a child's basic need for love, food, clothing, warmth, safety, education and medical attention is not met by parents or carers.  It also includes failure to protect a child from physical or emotional harm and ensuring adequate supervision.    

  • Discrimination - Bullying, racism and other types of discrimination are forms of child abuse. Like other kinds of abuse they can harm a child physically and emotionally.

All staff, contractors and temporary workers are expected to look out for the common symptoms or indicators associated with the different types of abuse and neglect. 

METHODS FOR IDENTIFYING POTENTIAL ABUSE INCLUDE:

All staff, contractors and temporary workers are expected to look out for the common symptoms or indicators associated with abuse and neglect.  

There is no way to identify someone who will hurt children. People who pose a threat of sexual abuse to children can be skilled at making sure no one knows. There are warning signs however, so look out for someone who:

  • Pays an unusual amount of attention to a child or groups of children, and provides presents, money, or favours;

  • Seeks out vulnerable children, for example, deaf or disabled children and tries to spend time alone with a single child or group of children on a regular basis;

  • Takes a child or small group of children to places where the group doesn’t usually meet or have activities, such as at their home;

  • Is vague about where they have worked or when they were employed;

  • Avoids co-working or supervision of his or her work;

  • Encourages secretiveness about his or her activities with children;

  • Talks or behaves inappropriately towards children. 

Physical Abuse – the signs of this are often evident but can be hidden by both the victim and the abuser. Any unexplained injuries should always be fully investigated. Evidence to look out for includes:

  • Cuts, lacerations, puncture wounds, open wounds, bruises, welts, discoloration, black eyes, burns, bone fractures, broken bones, and skull fractures;

  • Untreated injuries in various stages of healing or not properly treated;

  • Poor skin condition or poor skin hygiene;

  • Dehydration and/or malnourished without illness-related cause;

  • Loss of weight;

  • Soiled clothing or bed;

  • Broken eyeglasses/frames, physical signs of being subjected to punishment, or signs of being restrained;

  • Inappropriate use of medication, overdosing or under-dosing;

  • A child telling you they have been hit, slapped, kicked, or mistreated. 

Sexual Abuse - very often the behaviour of a child, even if they are confused, will tell you that something is wrong.  Children can often make their feelings known to you if you take the time to listen, observe and take notice.  It is the capacity to believe that sexual abuse is possible, (without automatically seeing it everywhere), that will increase the potential to detect and respond to it when it happens.  Some of the physical signs to watch for are: 

  • Bruises around the breasts or genital area; 

  • Unexplained STDs;

  • Unexplained vaginal or anal bleeding; 

  • Difficulty in walking or standing;

  • Marked changes in behaviour;

  • Torn, stained, or bloody underclothing;

  • A child telling you they have been sexually assaulted or raped. 

If you suspect sexual abuse, do NOT wash the child or their clothing. Do NOT let time drift by while you think about your course of action. Call the Recruitment and Compliance Director at Supply Staff Limited immediately and they will refer the matter to the Local Authority Social Services Department and the Police as they are the experts and will have the skills, knowledge and equipment to respond appropriately and sensitively. 


Emotional / Psychological Abuse - this can have a profound impact on an individual’s mental health.  They can feel trapped, threatened, humiliated, used or a combination of all these. Most signs therefore relate to someone's mental state, and changes in behaviour such as:

  • Helplessness;

  • Hesitation to talk openly;

  • Implausible stories;

  • Confusion or disorientation;

  • Anger without apparent cause;

  • Sudden change in behaviour;

  • Emotionally upset or agitated;

  • Unusual behaviour (sucking, biting, or rocking);

  • Unexplained fear;

  • Denial of a situation;

  • Extremely withdrawn and non-communicative or non responsive;

  • A person telling you they are being verbally or emotionally abused. 

Neglect - this will often be manifested in the physical, social or health circumstances of the child.  Examples may include:

  • Dirt, faecal or urine smell, or other health and safety hazards in the child’s living environment;

  • Rashes, sores, or lice;

  • Inadequate clothing;

  • Malnourishment or dehydration; 

  • Untreated medical conditions;

  • Poor personal hygiene; 

  • Evidence of the withholding of medication or over-medication of the person; 

  • Evidence of a lack of assistance with eating and drinking;

  • Unsanitary and unclean conditions.

It should also be remembered that neglect can be intentional or passive (i.e. where the 'perpetrator' is doing his/her best but cannot provide the level of care and support that is needed). From the perspective of the 'victim' the impact is the same, and they experience abuse. Where abuse is intentional it is likely that the following signs will be apparent as the abuser may:

  • Try to prevent the child from speaking for themselves or seeing others without them being present;

  • Display attitudes of indifference or anger toward the child, or the obvious absence of care;

  • Blame the child (e.g. accusation that incontinence is a deliberate act);

  • Display aggressive behaviour (threats, insults, harassment) toward the child;

  • Have a previous history of abuse of others;

  • Display inappropriate affection toward the child;

  • Display flirtatious behaviour, or coyness, etc that might be possible indicators of inappropriate sexual relationships;

  • Create social isolation of the family, or isolation or restriction of activity of the child;

  • Create conflicting accounts of incidents by family, supporters, or the child;

  • Display inappropriate or unwarranted defensiveness.

REPORTING & RESPONSE TO SUSPECTED, ALLEGED OR CONFIRMED CASES OF ABUSE

The Recruitment and Compliance Manager is the designated contact with direct responsibility for handling any suspected or alleged incidences of abuse.  Any employee, contractor, temporary worker, parent, family member, carer or any other individual with concerns about possible abuse should report the matter to this member of our staff. Where it is suspected that such abuse may be caused by another staff member, then reporting the matter will be done in accordance with the company’s Whistleblowing Policy.

Any instance of suspected or alleged abuse should be reported immediately to the Recruitment and Compliance Manager, the employee, contractor or temporary worker must not attempt to investigate the abuse themselves. The company will take vigorous action against anyone trying to suppress a possible report of abuse.

Contact details for the Recruitment and Compliance Manager are:

Tel No: 020 3337 1912

Email: info@supplystaffltd.co.uk

Address: Supply Staff Limited, Old Station Road, Loughton, IG10 4PL

All incidences of child abuse or neglect will be reported immediately to the Local Authority Social Services Department, DBS and the Police. The company may also invoke its own disciplinary procedure and the abuser may be suspended pending investigation.

In all cases, the Recruitment and Compliance Manager is responsible for maintaining complete case records of the suspicions raised, or allegations made, including dates, times and persons involved, and details of the time, date and content of any report made to the Local Authority Social Services Department, DBS and Police. 

In addition, the company will undertake preventative action in the form of strategies to be implemented with the objective of halting further abuse and preventing a similar situation from arising elsewhere. Where such cases involve Supply Staff employees, contractors or temporary workers, a robust review of current practices and procedures will take place to determine what additional protective measures, if any, need to be incorporated into the standard processes and systems.  Incidents of alleged / confirmed abuse will be logged and reviewed on a quarterly basis to identify and eliminate any possible adverse trends and inform the company regarding training needs.

If the person against whom the allegation is made is an employee of Supply Staff Limited, then they will be informed of the allegation and their rights under the disciplinary procedure. If they are a contractor or temporary worker, they may be suspended pending investigation. If the person against whom the allegation is made is a 3rd party (e.g. parent, friend etc), then the Recruitment and Compliance Director will consult with the appropriate authorities.

The company expects its employees, contractors and temporary workers to take all possible steps to co-operate with investigations by any regulatory bodies such as HCPC, GMC, NMC etc.

PROCEDURE FOR MAKING A REFERRAL TO THE DBS

A “referral” to the DBS is information which does or could indicate that an individual has engaged in an activity that caused concern for the safeguarding of children.  As a “Personnel Supplier”, Supply Staff Limited has a statutory duty to refer any relevant information about such individuals to the DBS.  To meet DBS referral guidelines, we will make a referral when we (or the Hirer) withdraws permission for an individual to engage in regulated activity or would have done so had the arrangement not otherwise ended (e.g. we remove the individual from our candidate base, the assignment ends, the individual leaves, redundancy, retirement etc) because we think that the individual has engaged in relevant conduct, satisfied the harm test or received a caution or conviction for a relevant offence.  

Supply staff will follow this referral process:

  • Follow our own disciplinary procedure (which may also include consulting with a relevant governing body of professional association);

  • Consult with Local Authority Designated Officer or Health & Social Care Trust Designated Officer if appropriate;

  • Conduct an official investigation and gather the facts and evidence (e.g. witness statements);

  • Based on the facts, evidence and witness statements, establish if there may have been relevant conduct and withdraw permission for the individual to engage in the regulated activity;

  • Make a referral to the DBS using the DBS Referral Form (after consulting the DBS Referral Guidance);

  • Send the completed form and supporting evidence to the DBS;

  • Refer the same information by post to the relevant regulatory body;

  • Receive an acknowledgement from the DBS within 3 working days.  The DBS will then commence its own investigation and decision-making process;

  • If the DBS is “minded to bar” an individual, it will write to them seeking representations as to why they should not be barred.  The individual will receive all the evidence provided to the DBS and will have eight weeks in which to make a response to the DBS.  A final decision regarding the barring of that individual will then be made;

  • If the individual is not barred, they (and any legitimately interested parties) will be advised in writing;

  • If the individual is barred they will have the right to appeal to the Administrative Appeals Chamber of the Upper Tribunal.

The DBS contact details are:

Tel:  03000 200 190

Post:  PO Box 3961, Wootton Bassett, SN4 4HF

For further information go to: https://www.gov.uk/government/organisations/disclosure-and-barring-service

SAFEGUARDS

Supply Staff Limited requires its employees, contractors and temporary workers to follow all of its instructions, guidance, policies and procedures. Induction training will be provided to all employees, contractors and temporary workers engaged to undertake regulated activity with children including but not limited to:

  • Engagement with the local Safeguarding Children’s Board;

  • Training in relation to safeguarding and handling of reporting of alleged or suspected abuse;

  • Risk management to prevent abuse;

  • Actions to be taken in the event of alleged or suspected abuse;

  • The company’s complaints and escalation process;

  • The company’s whistleblowing policy;

  • Current legislation and best practice.

All employees, contractors and temporary workers will be appropriately supervised.

CONFIDENTIALITY & RECORD KEEPING

In most cases, confidentiality will mean that information relating to alleged or suspected abuse is only passed onto others with the consent of the child / their representative, however it should be recognised that in order to protect children it may be necessary to share information that might normally be regarded as confidential in order to investigate an alleged or suspected offence, particularly if the  Recruitment and Compliance Director judges that the individual / individuals are in serious danger.

All staff, contractors and temporary workers are required to abide by our Confidentiality Policy and will receive training in this area prior to commencing the job / their first assignment.

Confidential records will be managed as following:

  • They will be kept in a locked filing cabinet.

  • They will only be accessed by the Recruitment and Compliance Director & manager. 

  • Electronic / online records will be kept secure by password protected systems.

  • Confidential information will be destroyed in line with timescales, methods and standards required by current Data Protection legislation 

Review

This policy will be reviewed regularly and may be altered from time to time considering legislative changes or other prevailing circumstances.