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Safeguarding & Prevent Policy

Safeguarding

The OCM Group Limited is committed to taking every reasonable step to ensure the safety and welfare of apprentices and candidates within their remit. The OCM typically does not directly work with children or vulnerable adults, however we recognise that we have a duty of care to all whom we come into contact with, and that Safeguarding is everyone’s responsibility.  Safeguarding of Adults relates to the action taken to promote the welfare of adults and protect them from harm.

 

Safeguarding Policy Summary

The aim of the Safeguarding policy is to ensure that adults shall not receive or come to harm or be placed at risk of harm by any act of neglect, failure to act, inadequate staff training or management or for another reason within the control of The OCM. 

This policy is a statement of intent that demonstrates our commitment to Safeguard adults involved in learning or who come into contact with The OCM in any other capacity, from harm. The OCM aims to create and maintain a safe, healthy and supportive learning and working environment for our learners, staff, associates and visitors alike.  Training needs to be based on normal levels of respect, politeness and courtesy and staff are therefore to act with common-sense and care to ensure that all adults are protected from harm.

Policy Statement

The Safeguarding Policy applies to everyone working or learning through The OCM. It confers responsibilities on all directors, learners, staff, associates and visitors within apprenticeship. The OCM will work to protect and take action to protect all learners from harm; this is made clear through the induction process as learners and staff join.  All staff members and associates at The OCM who identify a concern through conversations, behaviour, appearance or actions will discuss these concerns to the designated Safeguarding Lead.

Definition of a vulnerable adult

It is important to understand what might constitute a vulnerable person in our context and recognise potential warning signs. Any person who is aged 18 years of age or over is defined as vulnerable if they are at risk of harm, abuse or manipulation (including radicalisation) as a result of either their social or personal situation. In addition, these might include but are not limited to:

  • Decreased performance
  • Withdrawal from programme, family or friends
  • Heightened emotional reactions
  • Low self-esteem/confidence
  • Signs of burnout
  • High levels of stress
  • Change of role /restructuring to take on additional responsibilities
  • Family loss/bereavement/divorce/ill health
  • Mental health/wellbeing changes
  • Inability to make decisions

Harm 

Harm can be caused in a number of ways and take different forms, including: 

  • Sexual – for example, trying to get someone to take part in sexual activity by using force, threats or bullying. Sexual activity requires both consents to be given and also an understanding of what is being consented to. ‘Grooming’ occurs when a person uses an emotional bond to gain the trust of a child or vulnerable adult in order to sexually abuse or exploit them, or to trade them (trafficking) 
  • Sexual harassment - unwanted behaviour of a sexual nature which: violates a person’s dignity, makes them feel intimidated, degraded or humiliated 
  • Radicalisation - the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups 
  • Neglect – for example, not caring for yourself or someone you are responsible for. This could include not washing regularly, not eating, or having unsafe living conditions 
  • Physical – for example, hitting another person or deliberately cutting yourself 
  • Psychological – for example, saying things which could hurt someone else, or which could make them feel vulnerable, alone or isolated. Making threats, trying to control another person, or humiliating someone can be psychological harm. Psychological harm can include bullying in person or online, including ‘revenge porn’.
  • Financial - for example, unreasonable or excessive borrowing or stealing money or other items. Also, trying to pressure someone else into giving you money or other items because they feel sorry for you. 

 

Responsibilities of The OCM for Safeguarding apprentices, candidates and staff 

 

The OCM will 

  • Maintain thorough knowledge of safeguarding matters
  • Ensure this policy and accompanying procedures and guidance are regularly reviewed for compliance with relevant legislation 
  • Provide points of contact for anyone needing to report a safeguarding concern 
  • Act on reported concerns as appropriate. This may include making a referral to an external agency
  • Monitor the effectiveness and implementation of this policy 
  • Promote a culture which promotes safeguarding, reducing the potential for harm to be caused or threatened 
  • Collate summaries of safeguarding concerns raised and outcomes, where known 
  • Introduce apprentices to their rights and responsibilities with regard to Safeguarding and Prevent through their enrolment
  • All apprentice and student-facing staff, including those at partners and subcontractors, undertake suitable training commensurate with their role in the organisation 
  • All apprentice and student facing staff will receive appropriate training as part of their induction
  • The Safeguarding Policy will be reviewed on an annual basis to ensure it covers any changes in legislation and remains suitable for the needs of the organisation 
  • The Designated Safeguarding Officer will meet with key Safeguarding staff on a regular basis to discuss Safeguarding and Prevent issues and processes, identify and address themes and standardise practice 
  • The effectiveness of the Safeguarding and Prevent policy in terms of learner awareness and understanding will be monitored through discussions, observations and review of Safeguarding

 

Categories of Potential Safeguarding Concerns 

Action may be needed to protect our learners from many types of different safeguarding concerns. A number of these are shown below although this is not an exhaustive list. There could be additional issues that pose a risk to our learners. 

 

Mental Health 

Mental health includes emotional, psychological, and social well-being. It affects how a person thinks, feels, and acts. It affects how they handle stress, relate to others, and make choices. Mental health issues such as depression and anxiety may leave the individual vulnerable to self-harm and suicidal thoughts as well as other safeguarding risks.

 

Sexual violence, harassment and abuse 

Sexual violence: the general term used to describe any kind of unwanted sexual act or activity, including rape, sexual assault, sexual abuse, and many others. Sexual harassment: unwanted behaviour of a sexual nature that makes someone feel distressed, intimidated or humiliated. It can take lots of different forms. It can include or be called sexualised bullying. 

Sexual abuse: forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Females can also be abusers as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education and all staff should be aware of it. This is also known as peer-on-peer abuse or child on child abuse).

 

Bullying (including cyberbullying)

Behaviour by an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally. 

 

Radicalisation or extremism

Radicalisation: The process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups 

Extremism: 

This is vocal or active opposition to fundamental British values, including:

  • Democracy 
  • The rule of law 
  • Individual liberty 
  • Mutual respect for and tolerance of those with different faiths and beliefs and for those without faith 

 

Also included in the definition of extremism are calls for the death of members of our armed forces, whether in this country or overseas. 

 

Antisemitism 

Antisemitism is a certain perception of Jews, which may be expressed as hatred toward Jews. Rhetorical and physical manifestations of antisemitism are directed toward Jewish or non-Jewish individuals and/or their property, toward Jewish community institutions and religious facilities 

 

Racism  

Racism is the belief that groups of humans possess different behavioural traits corresponding to physical appearance and can be divided based on the superiority of one race over another. It may also mean prejudice, discrimination, or antagonism directed against other people because they are of a different ethnicity.

 

Domestic Violence

Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse may involve, but is not limited to psychological, physical, sexual, financial and emotional impacts.

 

Faith Abuse 

Forms of child abuse linked to faith or belief. Examples of this include spirit possession, demons/the devil acting through children, the evil eye or djinns (known in some Islamic faith contexts) and dakini (in Hindu context) and ritual or multiple murders where the killing of children is believed to bring supernatural benefits, or the use of their body parts is believed to produce ‘magical’ remedies. 

 

Stalking 

Stalking can be defined as persistent and unwanted attention that makes someone feel pestered and harassed. It includes behaviour that happens two or more times, directed at or towards another person, which causes them to feel alarmed or distressed or to fear that violence might be used against you. Social media and the internet are often used for stalking and harassment, and ‘cyber-stalking’ or online threats can be just as intimidating. The effect of such behaviour is to curtail a victim's freedom, leaving them feeling that they constantly have to be careful, causing significant alarm, harassment or distress to the victim.

 

Forced Marriage 

A forced marriage is a marriage in which one or both spouses do not (or in the case of some adults with learning or physical disabilities, cannot) consent to the marriage and duress is involved. 

  

 

Trafficking 

The recruitment, transportation, transfer, harbouring or receipt of persons, by means of threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of position of vulnerability or of the giving or receiving of payments or benefits to achieve consent of a person having control over another person, for the purpose of exploitation.

 

Protecting adults online

The OCM has responsibility for helping people remain safe when using our IT systems. Specifically, we are responsible for: 

  • Putting in place appropriate filtering and monitoring systems, which are updated on a regular basis and keep apprentices safe from potentially harmful and inappropriate content and contact online while studying with us, including terrorist and extremist material 
  • Ensuring that our ICT systems are secure and protected against viruses and malware, and that such safety mechanisms are updated regularly. 
  • Conducting a full security check and monitoring our systems on a weekly basis with our IT provider. 
  • Putting into place systems and processes that block access to potentially dangerous sites and, where possible, preventing the downloading of potentially dangerous files 
  • Ensuring that any online safety incidents are logged and dealt with appropriately in line with this policy and the wider Safeguarding and Prevent Policies

 

 

The Prevent Duty

The threat to the UK from international terrorism is substantial. The terrorist threats that we now face is more diverse than ever before, dispersed across a wider geographical area and often in countries without effective governance. We therefore face an unpredictable situation. Whilst it remains rare for learners to become involved in extremist activity, any learner can be exposed to extremist influences or prejudiced views, including via the internet, from an early age. Early intervention is a preferable way of tackling extremism. 

The OCM must have due regard to the need to prevent people from being drawn into terrorism. This is referred to as ‘The Prevent Duty’. As part of OCM’s commitment to Safeguarding and the promotion of British values, we will ensure that all staff have the confidence to recognise the signs that a learner or colleague is at risk of radicalisation. 

The OCM recognises that its responsibility to the Prevent Duty is not limited to children, young people and vulnerable adults, or to those learning through Government funded programmes but that all learners and staff fall within the remit of this aspect of the Safeguarding & Prevent Policy.

Prevent definitions

Radicalisation 

The process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. 

Extremism 

This is vocal or active opposition to fundamental British values, including: 

  • Democracy 
  • The rule of law 
  • Individual liberty 
  • Mutual respect for and tolerance of those with different faiths and beliefs and for those without faith 

Also included in the definition of extremism are calls for the death of members of our armed forces, whether in this country or overseas.

Preventing Extremism

 The OCM will: 

  • Raise awareness to all apprentices and candidates of the threat from violent extremist groups and the risks, and The OCMs responsibility is to minimise this in their organisation 
  • Help apprentices to understand the positive contribution they can make to empower themselves to create communities that are more resilient to extremism, and protect the wellbeing of particular learners or groups who may be vulnerable to being drawn into violent extremist activity
  • Provide advice on managing risks and responding to incidents
  • Promote fundamental British values at every opportunity throughout programmes and other activities
  • Challenge segregation, promoting cohesion and building learner resilience with the aim of our apprentices, students and staff contributing actively to wider society 
  • Operate a clear and consistent anti-bullying approach that challenges harassment and discrimination and enables apprentices and staff to feel safe and supported 
  • Provide support, advice and guidance for apprentices, students and staff who may be at risk. This may include referral to the Police and local authority as part of the Government’s Prevent strategy and the process by which multi agency support is provided to individuals who are at risk of being drawn into terrorism
  • Ensure that staff, apprentices, students and employers are aware of their roles and responsibilities in preventing radicalisation and extremism 
  • The OCM will carry out an annual risk assessment in relation to the Prevent Duty with the aim of evaluating where and how learners or staff may be at risk of being drawn into terrorism. This will include reviewing policies regarding the delivery of learning, apprentice welfare, equality and diversity, and the safety and welfare of clients and staff 
  • The OCM will ensure that there is a shared understanding amongst staff and apprentices as to the risks posed within the training environment by extremist’s behaviour by raising awareness through training and information sharing 
  • Take steps to mitigate the risk posed to individuals vulnerable to extremism where it is identified
  • Prevent referrals will be made to the local authority/police with consideration to the risk of radicalisation or extremism. All such referrals will ultimately be made by the Safeguarding and Prevent Lead

 

Identifying Indicators of Radicalisation

 Potential signs of radicalisation include: 

  • An individual’s views become increasingly extreme regarding another section of society or government policy
  • An individual is observed downloading, viewing or sharing extremist propaganda from the web
  • An individual becoming withdrawn and focused on one ideology
  • An individual becoming increasingly intolerant of more moderate views
  • An individual may change their appearance, their health may suffer (including mental health) and they may become isolated from family, friends, peers or social groups
  • An individual expresses a desire/intent to take part in or support extremist activity 

 

External Speakers and Events

In order to comply with the Prevent Duty, The OCM will ensure that any external speaker’s views being expressed, or likely to be expressed, do not constitute extremist views that risk drawing people into terrorism or are shared by terrorist groups. 

It is the responsibility of the host to ensure that any external speaker’s content, planned to be delivered either verbally, by presentation or other materials are reviewed prior to the event to check that it is suitable and that it will not promote extremist views in any way. 

An external speaker booking form should be completed by the host and the Prevent Lead will then make the necessary checks prior to deciding whether the event can go ahead. Where a potential risk is identified the Prevent Lead will seek further information from the host to ensure a balance of The OCM’s legal duties in terms of both ensuring freedom of speech and also protecting apprentice, student and staff welfare.

Where the Prevent Lead is in any doubt that the risk cannot be fully mitigated The OCM will exercise caution and the event will not be allowed to proceed. We fully recognise the importance of academic freedom and the right to preserve freedom of speech for all our employees, learners and visiting speakers however we will balance this with our obligations towards the Prevent Duty.

 

Guidelines to follow when receiving a disclosure 

 

In order to ensure any disclosure is dealt with effectively, the 5 Rs should be considered. 

Recognise 

The ability to recognise behaviour that may indicate abuse is of fundamental importance. Signs and symptoms of abuse of young people or vulnerable adults may include direct disclosure. All relevant staff will be trained to understand signs of possible abuse and know how, where and to whom to report concerns. 

 

Respond 

An appropriate response is vital. No report or concern about possible abuse should ever be ignored and they should ensure:

  • They do not lead or probe with questions
  • Remain calm and demonstrate interest and concern while investigating
  • Tell the learner that you may need to disclose information to others to ensure any risk to them or others is minimised and do not agree to any off the record disclosures
  • Reassure them that they have done the correct thing in reporting their concerns and that it will be dealt with in a sensitive and appropriate way, ensuring any information is suitably restricted        
  • Record any disclosures on the Safeguarding Report Form 

 

Report 

All Safeguarding and Prevent concerns should be reported at the very first opportunity and within 2 hours where any delay increases the risk. Once concerns have been reported, responsibility for taking any further action resides with the Safeguarding & Prevent lead.

 

Record

DSL will ensure any disclosures, incidents or concerns and the subsequent investigation and assessment are accurately recorded, updated and monitored. The Information will be stored securely, confidentially and only made accessible to those who need access to support with the concern

 

Refer

The DSL will seek support from external agencies and refer as required

 

 

Safeguarding and Prevent Procedure

 

In the event of an emergency, including a threat to life, always call the emergency services on 999 Receiving, reporting and responding to Safeguarding and Prevent incidents by staff will follow the same procedure. Any suspicion, allegation or actual abuse of an apprentice by a member of The OCM staff or its subcontractors must be reported immediately and directly to the Safeguarding and Prevent designated lead. In their absence it should be reported to another member of the Executive Leadership Team, who will then lead with the investigation. 

 

Confidentiality and Information Sharing

Although an individual may insist information is kept confidential, concerns still need to be reported. The safety of the apprentice, student, staff or other person will always take precedence to any confidentiality concerns. All information received will always be dealt with sensitively and only shared further where there is a need to prevent and protect anyone from harm.

All members of staff are aware that whilst they have a duty to keep any information about learners confidential, they also have a professional responsibility to share information with other agencies in order to safeguard learners. All staff are aware that they cannot promise a learner to keep secrets which might compromise the learners’ safety or wellbeing.

A Safeguarding log will be maintained to record the summary of information from all concerns raised and will be monitored on an ongoing process

The General Data Protection Regulation (GDPR) and Data Protection Act provides further detail.

 

 

 

Complaints

The OCM has a Complaints Procedure available to learners, employers and members of staff as an additional method by which to report concerns.

All reported concerns will be taken seriously and considered within the relevant and appropriate process. Anything that constitutes an allegation against a member of staff will be dealt with by the DSL and a member of the executive team directly

 

Safer Recruitment

The OCM follow a safer recruitment process and comply with best practice in the recruitment and training of its staff and ensure that appropriate checks are carried out on new staff joining the organisation.

Safer recruitment means that all applicants will: 

  • complete an application form
  • provide two referees
  • provide evidence that they are eligible to work in the UK confirm identity checks and confirm qualifications
  • be checked through and registered with the Disclosure and Barring Service as appropriate to their role
  • All required staff, identified by their role, will receive an appropriate induction, including safeguarding and prevent training. All staff will have been provided with a copy of part one of the “Keeping Children Safe in Education”

 

Key contacts

Designated Safeguarding Team

  • Sam Webb
  • David Jamieson
  • Angela Bolam

Tel: 01869 338989 - line available 9am to 5pm Monday to Friday. Please ask to speak to the duty Designated Safeguarding Lead.

Email: [email protected]

 

Executive Leadership Team Members

Ed Parsloe, Chief Executive, The OCM

Tel: 01869 338989

Email: [email protected]

 

Charlotte Bruce-Foulds. MD OCM Apprenticeships

Tel: 01869 338989

Email: [email protected]

 

Emergencies and out of business hours contacts

If there is an immediate risk of harm or other emergency, you should call 999 and speak to the emergency services.

 For non-emergency calls you can contact the Police on 101 or for medical concerns the NHS on 111.

Anti-terrorist hotline: call 0800 789 321 – for concerns about possible terrorist activity, you can also make your report anonymously. https://www.gov.uk/report-terrorism

Samaritans: call 116123 – https://www.samaritans.org/how-we-can-help/contact-samaritan/ for support with many forms of emotional distress

Mind: call 020 8519 2122 - [email protected] - Advice and support around metal health or text 'shout' to 85258 a free, confidential, anonymous text support service.

NSPCC Helpline: call 0808 800 5000 – [email protected] advice for anyone who has concerns about the welfare of a child or young person Report online material promoting terrorism or extremism Report illegal or harmful information, pictures or videos you’ve found on the internet.

Policy Review 

All Safeguarding and Prevent concerns will be fully investigated and appropriate actions taken. The OCM will review this policy annually as a minimum in-line with any regulatory requirements.

 

Last review date: 01 September 2023

Next review date: 01 September 2024