Safeguarding standards for children's contracted services

Providers must have up-to-date safeguarding policies and procedures.

1.1 Safeguarding policy

To safeguard children and young people providers must ensure their safeguarding policy clearly sets out safeguarding expectation for all members of the organisation including:  staff, volunteers, proprietor, children and their families. The policy must also set out clearly how the following will be identified and managed in line with current DSCP procedures:

• child sexual exploitation
• child-on-child abuse (including harassment and violence)
• children with disabilities or complex needs
• bullying
• online safety - children exposed to abuse through the digital media
• radicalisation and violent extremism
• self-harm and suicidal ideas
• child criminal exploitation
• harmful sexual behaviour

Additional information about key safeguarding areas can also be found in Keeping Children Safe in Education (Annex B) and the NSPCC website - types of abuse.

Providers must include information on reporting concerns about children in the policy, including:

• information on potential indicators of abuse or neglect and how to recognise and respond to concerns details of the named Designated Safeguarding Lead and Deputy Safeguarding Lead(s)

• how individual staff and volunteers who are concerned that a child has been harmed or may be at risk of harm, report this immediately to the Designated Safeguarding Lead (or Deputy) who will consider whether any actions need to be taken, including a referral to the Family Support and Advice Line or information sharing with the relevant locality team (if the child / young person is already open to children's services). In the case a child is in immediate danger, staff understand the requirement to phone the police.

Please refer to the DSCP guidelines on safeguarding referrals.

The policy should include information on recording, storing and sharing of information, explaining:

• how safeguarding and child protection concerns are recorded, stored and shared
• effective information sharing for intervention and safeguarding. Please refer to the DSCP guidelines on information sharing and information sharing advice for safeguarding practitioners

The policy must detail how you will ensure effective inter-agency working around safeguarding including compliance with:

• Child Safeguarding Practice Review processes
• Child Death Review processes

Providers will have a policy or section within their safeguarding policy on online safety that includes:

• use of personal/organisations IT system and/or mobile phones
• taking, storing and destructing photographs and videos of children
• expectations regarding an individual’s behaviour, conduct and interaction when using all social media. This includes contact with parents and children who use the providers services
• appropriate lines of intervention, response and protection following any internet safety incident
• how to ensure the leadership team and relevant staff:
  • are aware of and understand the system for online safety is in place
  • manage them effectively
  • understand how to escalate concerns when identified
• for schools, colleges or educational providers; how to review the effectiveness of filtering and monitoring system, to limit children’s exposure of online risk from your IT system

Refer to the DSCP online safety guidance and support for parents to keep children safe online government guidance.

1.2. Safer recruitment policy

Providers must ensure their safeguarding policy:

• is in line with the DSCP guidance on safer recruitment practices and the latest Keeping Children Safe in Education (KCSiE) statutory guidance
• details the recruitment process for paid staff, volunteers and agency staff, which should include as a minimum:
  • planning
  • advertising
  • scrutinising
  • shortlisting
  • references
  • interviews
  • DBS (including online search) and other suitability checks
• how the governments criteria for DBS checks and risk assessments for convictions or concerns is complied with
• outlines expectations that staff responsible for recruitment undertake safer recruitment training
• explains that at least one member of interview panels must undertake safer recruitment training. See the DSCP training offer
• requires all staff/volunteers working in regulated activity to be DBS checked. See Disclosure and Barring Service guidance for further information and definition of regulated activity
• covers expectations regarding induction and supervision
• references staff records (see section 2)

To manage a positive DBS disclosure (stating a criminal conviction or caution), providers will ensure:

• your policy includes the process of dealing with convictions, relevant ‘soft’ information and third-party information
• a risk assessment is undertaken on all convictions, concerns, soft information and third-party information and a record kept. The provider will share the risk assessment with the commissioner and contract officer as appropriate

1.3. Managing allegations policy

Providers must ensure they have clear internal procedures and policies for managing allegations against staff and volunteers and that this is known by and operated by everyone in your organisation, either as part of your safeguarding policy or as a standalone policy.

The policies and procedures should:

• be aligned with DSCP managing allegations procedures
•  name at least 2 members of the organisation’s senior leadership team who have completed Managing Allegations training within the last 3 years
• include the name and contact details of the designated senior manager to whom an allegation or concern should be reported and deputy in their absence
• describe the process if the designated senior manager or deputy is the subject of the allegation or concern
• contain procedures covering:
  • managing confidentiality
  • the provision of support
  • responding to allegations or concerns
  • disciplinary process
  • record keeping
  • monitoring progress
  • the identification and implementation of lessons learned 
• include a process for the prompt, appropriate management and recording of any low-level concerns relating to members of the Provider's staff, volunteers, or subcontractors
• include a named officer who will report all allegations to the Local Authority Safeguarding Officer (LADO) as appropriate and continue to liaise as appropriate, in accordance with the DSCP procedures
• include relevant LADO contact information, for Dorset, contact details of LADO is as noted in this link: Allegations Against Staff - BCP Safeguarding Children Partnership and the Dorset Safeguarding Children Partnership

Where there are any convictions, concerns or relevant information on DBS checks, providers must ensure there is evidence of safer recruitment processes being adhered too. Providers can contact the LADO should they have concerns that: safeguarding concerns and allegations regarding an individual working with children may not have been previously reported; or to confirm that they have been and the outcome of the LADO contact. Providers should contact the LADO service by phone or email in the first instance for advice and guidance, as it may be that a referral is not required. New Dorset Council LADO Referral Form - Dorset Safeguarding Children Partnership

Our standard contract requires providers to immediately notify Dorset Council’s commissioning and/or referring teams when they become aware of any allegations, concerns or safeguarding information which in provider’s view, deems their staff/ volunteers may be unsuitable to work with children or young people.

The requirement to have a managing allegation policy includes providers working alone for example self-employed or sole-traders. Information on how to report concerns pertaining to yourself should be promoted prominently to children, young people and their parents/cares. For example, stating the contact details of the LADO.

1.4. Whistleblowing policy

Providers recognise the importance of raising concerns at work in the public interest or ‘whistleblowing’ and must have clear guidance for ‘whistleblowing’. See the DSCP guidance on whistleblowing.

1.5. Code of conduct

Providers should have an effectively implemented code of conduct which covers staff behaviour policy. The list isn’t exhaustive, but it should include:

• acceptable use of technologies (including the use of mobile devices)
• how to respond to low level of concern
• staff/children relationships
• communications including the use of social media

2.1 Providers must complete and update records of all staff, trustees, governors, volunteers and agency staff. Education providers know this as a single central record (SCR) and must follow requirements in KCSiE. A template SCR can be found in Dorset’s safeguarding standards resources.

2.2 Providers must evidence any checks (including DBS) in their staff records. The record must be completed immediately when any changes occur and reviewed annually.  If this is held centrally i.e. head office, providers must be able to provide assurance that this information is available on request.

2.3 Providers must ensure any staff/volunteers requiring DBS checks have valid and up-to-date certificates that are renewed as required.  Dorset Council recommends DBS checks are updated at least every three years. To evidence this, the last check must be recorded in the staff record or SCR. If you are inspected by a regulatory body such as Ofsted or CQC, you will follow their requirements on DBS checks renewal.

2.4 The record should include names, addresses, dates of birth of all:

• staff
• trustees
• governors
• volunteers
• agency workers
• contractors who work regularly in the organisation and third-party staff (for example sports coaches)

Where background checks are completed by another organisation, the organisation should record confirmation that the appropriate background and safeguarding checks have been undertaken

2.5 The record should include:

• identity checks (address and photographic identity) that have been carried out and by whom
• what was checked, for example a passport, utility bill, driving licence etc
• where qualifications are required, an indication they have been checked (for example certificates)
• Right to Work' in the United Kingdom checks
• Enhanced DBS checks (including Children’s Barred List) for staff/volunteers working in regulated activity.  See gov.uk guidance for information and definition of regulated activity 
• the date that individuals were DBS checked
• confirmation that two satisfactory references have been seen and verified in line with safe recruitment practice
• confirmation that a risk assessment is conducted and added to the record for any long-term staff with only one reference
• prohibited from teaching checks (where applicable)

Providers will ensure:

• that a safeguarding training needs analysis is undertaken of relevant staff and volunteers which is reviewed annually. You should consider including board members (or equivalent), who have a lead role in ensuring the organisation is fulfilling its responsibilities for safeguarding children effectively. This training should be in line with recommendations from the safeguarding children partnership in the providers’ area. For Dorset, this safeguarding training requirement applies: Training Pathway - BCP Safeguarding Children Partnership and the Dorset Safeguarding Children Partnership
• all relevant new staff undergo safeguarding and child protection training (including online safety) at induction
• your safeguarding lead and deputy undertakes the training for staff working in specialist roles: including designated and named professionals as described on the training section of the DSCP website or other recognised equivalent as recommended by the safeguarding partnership in the providers’ area
• at least one person (including the Chair) of any recruitment panel has undertaken safer recruitment training as described on the training section of the DSCP website or other recognised equivalent as recommended by the safeguarding children partnership in the providers’ area
• all safeguarding training should be updated at regular intervals; best practice is every three years for staff and volunteers working with children. Safeguarding leads and deputies, update this training every two years. All providers should follow training requirements within Working Together to Safeguard Children. Providers in education settings must follow training requirements in line with the latest KCSiE.

Providers must complete Dorset Council’s safeguarding self-audit when requested. Where identified, they must implement action plans resulting from the audit.

All policies listed in this document:

• should be reviewed regularly. Your safeguarding policy should be reviewed annually or as changes occur in your practice or within legislation and regulations
• must be made available and published to all relevant staff and volunteers working with children and their families and implemented through relevant training. We would recommend that updated policies are made available on your website (if you have one)
• the staff record must be made available for inspection
• must be provided to the council on request