This policy describes the Bright World response to dealing with students who are suspected of, or are suffering abuse or neglect, or who are at risk of suffering harm from abuse or neglect. The document details child protection roles, responsibilities of staff, the procedures for identifying and managing child protection concerns and issues, and for mitigating risks to the safety and welfare of students.

1. Policy:

1.1 This policy is linked to Bright World Safeguarding policy and describes the child protection roles, responsibilities of staff, the procedures for identifying and managing child protection concerns and issues, and for mitigating risks to the safety and welfare of students.

1.2 The aim of the policy is to set out the processes and provisions in place to ensure all possible steps are taken to:
• Provide a safe environment for our students while under the guardianship of the company
• Effectively and efficiently identify and manage cases where students are at risk or have unmet safeguarding needs
• Promote the importance of safeguarding and child protection across all areas of the business
• Regularly evaluate our processes and management of safeguarding incidents with a view to continuous improvement of our safeguarding and child protection policies

1.3 This policy focuses on the measures in place for students of any age who are under the care of Bright World Guardianships.

1.4 In line with our mission statement, this policy supports Bright World’s duty to safeguard and promote the welfare of students. The mission statement is made with reference to Statutory Guidance for Schools and Colleges on Safeguarding Children and Safer Recruitment in Education, Department for Education, July 2015: Keeping Children Safe in Education (2019); National Guidance for Child Protection in Scotland, 2014; Social Services and Well-being (Wales) Act 2014; and Working Together to Safeguard Children (2018). Bright World policies and processes are in line with the requirements of the Association of Education and Guardianship of International Students (AEGIS), National Minimum Boarding Standards and sector specific accredited training experts. The company refers to various expert sources advice on child abuse and safeguarding, for example NSPCC website, Barnardo’s and the Local Safeguarding and Children’s Board when developing policies and managing incidents.

1.5 The company is aware of how to access local agency contacts. This includes referrals to Multi Agency Safeguarding Hubs (MASH) and Local Safeguarding Partnerships (LSP) across the country, how to access locally agreed inter-agency procedures, guidance and contact with LSP members. In addition, the company is aware of the non-emergency reporting procedures via the Local Authority’s Children’s Services relevant to the area or MASH (via the relevant contact telephone numbers on the internet), or by telephoning 101 to report a non-emergency. For emergency situations, the company is aware of the need to contact the relevant police force for the area by dialling 999.

1.6 Bright World contacts for Safeguarding and Child Protection issues and concerns are:
Designated Safeguarding Leads for the Company are:
Lana Foster, Managing Director who can be contacted on 01273 835745 or lana@brightworld.co.uk
James Foster, Commercial Director who can be contacted on 01273835745 or james@brightworld.co.uk

Deputy Safeguarding Lead is Jenny Rumble, Director of Safeguarding & Operations who can be contacted on 01273 835745 or jen@brightworld.co.uk

1.7 This policy applies to all full time, part time, contracted, agency and volunteer staff including those who do not have cause to come into direct or regular contact with students in order to carry out their daily duties. This policy also applies to those who provide homestay accommodation for our students and third party contractors.

2. Child Protection Principles

2.1 The company mission statement is “Bright World is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment.” The following principles underpin our provisions and practices in relation to safeguarding and child protection:

• Bright World will provide a safe and secure environment for all students
• Host families and transfer companies provide a safe and secure environment for all students
• All students feel safe, secure and protected from harm
• All students know who to turn to for help, advice or support, can access services confidentially, quickly and easily and have access to 24-hour support
• The Managing Directors of the company have overall responsibility and accountability for the safeguarding and welfare of the students
• All staff share in the responsibility to protect students from harm, remain vigilant in identifying safeguarding and child protection issues and to follow policies and procedures relating to safeguarding and child protection
• Students and staff have effective means by which they can raise child protection concerns or report issues, and are enabled to frequently raise their view on the care they are receiving for example visits from their ‘Buddy’, Host Family Care Plans and Exeat Phone Calls
• Staff have at least one reliable means to contact all students quickly and directly
• Staff are aware of the medical or learning needs of individual students via the Student Record in IBOS
• In cases where the whereabouts of a student under Bright World Guardianships is not known or the student is believed to be at risk of harm, procedures to locate the student by the safest and quickest means possible, or secure the safety of the student will be invoked immediately by following the Absent or Missing Student policy
• The company has procedures in place that enable child protection concerns and incidents to be dealt with promptly and effectively and in line with relevant legislation

2.2 Bright World Guardianships is committed to the protection of all children in its care. Bright World Guardianships’ Mission is to keep our students safe while they are here and to improve the quality of our service and standards as we grow. We are committed to safeguarding student welfare and undertake rigorous checks on all who work with us and we expect all staff and volunteers to share this commitment. We have a clear Child Protection strategy. We operate in line with UNCRC Global Code of Ethics for Tourism.

2.3 The safety and welfare of children, or Child Protection, means protecting children from physical, emotional or sexual abuse or neglect where there is an identified risk. Safeguarding is the minimisation of the risk to children from all forms of child abuse including for example:
• child sexual exploitation
• radicalisation and extremism
• female genital mutilation
• physical, emotional, sexual abuse or neglect
• domestic abuse
• online abuse
• bullying and cyber bullying
• child trafficking
• grooming

2.4 We aim to ensure that the students in our care experience at all times a caring and secure environment in which they feel safe, respected and valued. In pursuit of this aim, Bright World Guardianships undertakes the following:

1. To train Head Office staff to a minimum of Level 3 Child Protection training with Local Co-ordinators being trained to a minimum of Level 2. Head Office staff maintain the responsibility of responding to CP concerns raised by students, other guardianship personnel, host families and transfer companies.

2. To ensure Head Office staff record any allegations/concerns in an incident in IBOS and refer them to the DSL or Deputy DSL. Where appropriate concerns will be reported to the relevant Children’s Services Duty team or Multi Agency Safeguarding Hub (MASH) in the local area.

3. To ensure that a Bright World On Duty Manager is available for advice and guidance if staff are not sure whether a referral to Children’s Services is required. The On Duty Manager is able to contact Lana Foster and James Foster for advice in relation to referrals.

4. To ensure that all guardianship personnel receive CP Awareness Training and to make them and the students in our care aware of the need to report allegations and suspicions of child abuse to Head Office. In cases where the strategic leads are unavailable, staff must make direct contact where appropriate with the local Children’s Services or MASH On Duty Team, as delay could put a child/Young Person at further risk of harm. Contact with the local Children’s Services (Scotland/Wales) or MASH is made via the telephone numbers available on the Local Authority website.

5. To promote an environment of trust, openness and clear communication between students, school and Bright World Guardianship staff and our Host Families, so that student welfare, safety and pastoral care is recognised as the top priority

6. To respond to any reported allegation or suspicion of child abuse in accordance with the Bright World guidelines and those set out in the Child Protection Procedures of the Association for the Education and Guardianship of International Students (AEGIS)

7. To ensure that all guardianship personnel and personnel offering outsourced services who come into direct contact with students in our care, are recruited using safer recruitment practices and are formally screened through the completion of an Enhanced DBS check

8. To maintain links with the appropriate Agencies who have a statutory responsibility to deal with child welfare and child protection concerns. If you have any reason to believe that a child in your care is suffering from any form of abuse or neglect then please report it immediately in confidence to Lana Foster by telephone at the office or out of hours via mobile telephone.

3 Child Protection Procedures

3.1 This document is designed to set out clearly for employees of Bright World Guardianships Ltd the procedures you should follow if a child under our guardianship discloses a worry or concern to you, or if you have cause to be concerned about anything you have seen or heard, in relation to that student or other staff member.

3.2 All staff members are aware of their role to play in safeguarding children and identifying concerns early to allow us to provide early help, and prevent concerns from escalating. This includes for example school staff, host families, Local Coordinators and Transfer Companies who are acknowledged as being part of the wider safeguarding system within the company. When dealing with child protection or safeguarding concerns, Bright World works in partnership with the students, school, parents, agent and statutory authorities including the police, Social Services and health services.

3.3 All staff members are aware of the systems within the company which support safeguarding and child protection including the policy, staff behaviour policy and the designated safeguarding lead. All staff members receive appropriate child protection training which is regularly updated.

3.4 All members of staff should be aware of the signs of the four main categories of abuse – physical, emotional, sexual abuse and neglect. This will mean that staff are able to identify cases of children who may be in need of help or protection. Staff members should maintain an open mind as child abuse can happen anywhere, and should always act in the interests of the child. The signs and symptoms of abuse (for example cyber-bullying, grooming or CSE) are detailed on the NSPCC website and are available on each area’s Local Safeguarding Partnerships (LSP) website.

3.5 A cause for concern or disclosure could be any of the following, all of which should be taken seriously:
1. that someone has touched them inappropriately, sexually and/or in a way to make them feel uncomfortable
2. that someone has physically abused them, i.e. hit them or they have unexplained/unusual injuries
3. that someone has verbally abused them, shouted, been constantly critical of them
4. that they are being bullied
5. that they are not being fed properly either at school in their host family
6. that they are not able to wash sufficiently at the host family
7. that they saw or heard something that troubled them at the host family, on a computer, on TV or around the house.
8. The incident could have occurred in a host family, taxi, at a friend’s house or at school. Children may also disclose something to you that has happened to them at home in their country of origin. Whatever the matter, please follow the guidelines in this manual and report the matter to our Director of Safeguarding & Operations, Jenny Rumble, or in her absence, Lana Foster, James Foster and Charlotte Hamson.

4. Indicators of child abuse and response to individual concerns

4.1 There are potential indicators of the four main types of abuse which staff should be aware of and these include:
• Children going missing particularly on repeat occasions
• Problems with drugs or alcohol which may be seen in the student appearing not to be looking after themselves
• Mental health problems such as depression and eating disorders which may be seen in significant weight loss or weight gain
• Self harm and/or suicidal thoughts
• Child is unusually quiet, withdrawn or isolating themselves
• Behavioural problems including anti-social behaviour and criminal behaviour

4.2 Staff must deal with any concern or follow up of a disclosure or suspicion that a child is being abused and this must be done immediately. Initial enquiries are often dealt with locally via the school or Local Coordinator with later decisions and communications being made centrally at Head Office.

4.3 As equally important as following up suspected child abuse information immediately, as you are the person the child has chosen to trust and disclose the problem to, you must remain in touch with them on any feedback or follow up that is needed. Any problem you report, however, minor, will be discussed by Lana Foster and James Foster and/or Jenny Rumble, in consultation if necessary with Safeguarding Associates For Excellence (SAFE), Children’s Services, MASH or other external agency as appropriate.

A Bright World Guardianships student discloses something to a Local Coordinator or a Head Office staff member:

• Reassure the child and listen carefully – it is important that they know you believe them
• Do not say you will not say anything to anyone – in fact you have a duty to disclose this to another person so do not promise confidentiality
• Make sure you take detailed notes, write everything down
• Ask open questions if appropriate, do not lead the conversation to find out what has happened. Use words such as tell me, explain or describe, and allow the student to speak
• Avoid words such as what, why, how when – these will be asked by the relevant agency if appropriate.

  • Ensure that you notify the police by calling 999 if you believe that the young person is at immediate or serious risk of harm
    • Contact Jenny Rumble and Lana Foster at Head Office as soon as practicable on 01273 835745 and/or by launching a 360 Email just to them initially if you are Head Office staff. If the disclosure is made to a Local Coordinator, they should send a written report of the disclosure to jen@brightworld.co.uk, lana@brightworld.co.uk & james@brightworld.co.uk. If the disclosure is made out of hours, please use the emergency phone number (01273 836060)


The child is safe and away from the person they are disclosing about:

You must report what you have found out both in writing and verbally to Jenny Rumble and Lana Foster, once you have ensured that the child is safe. If the disclosure is out of hours, please use the emergency phone number (01273 836060). In writing you should email them, or if you are a member of Head Office staff, log the Problem in the Problem section of the Incident record and launch the email to them.

4.4 In the unlikely event that the student is in immediate danger for example in a host family, at school or at any other place, we must remove the student from the situation or ensure immediate help is sent to them. The reasons for their departure should remain confidential to all parties. Jenny Rumble and Lana Foster will review the situation and if appropriate the relevant statutory agencies will be informed.

4.5 As important as recording information from the student is the recording of information disclosed to you, for example by the host family or transfer company. All information provided should be recorded by the Bright World staff member in the Incident Record in iBOS and original records of any other information should be retained.

4.6 Bright World is committed to dealing with any allegation made against people working, looking after or living with children, to enable the allegation to be dealt with fairly, effectively and in a timely fashion. This is supported by the Bright World policy and procedure on ‘Managing Incidents’.

4.7 There are various sources of an allegation or information of potential child abuse which staff need to be aware of. Allegations or information relating to a child potentially being abused may arise in a number of ways:
• From a teacher/house parent, Bright World Transfer Company or from a Bright World host family
• From a student concerning his/her friend
• From a staff member about another member of staff or in a voluntary activity, or within his/her family or private life
• As an anonymous phone call
• Information contained within a written report from a Local Coordinator or other member of staff

4.8 On receipt of an allegation or information staff are required to treat the matter seriously, not make assumptions or offer alternative explanations. The following guidance must be followed:

• Please stay calm and listen carefully to the information that is being given to you.
• Remember that at this time it is ‘ALLEGED’. You are simply responsible for collecting and reporting the information that you are given. Please avoid adding your judgement or personal opinions
• Record all information in an accurate written record which is put into the relevant Incident record on iBOS. This should include the time, date, and place of the allegation
• Record the words that the child actually said to you – avoid translating the meaning of what you think the child said to you into your own language
• Please do not do anything that might impede any investigative actions. Information should be recorded and reported in a timely manner and restricted to those who need to know the details.

4.9 The matter should be reported to the designated safeguarding lead, Lana Foster or Deputy DSL, Jenny Rumble, as soon as possible, after ensuring the child is safe and notifying any relevant authorities if there is immediate or serious risk of harm. In Lana’s & Jenny’s absence, James Foster or Charlotte Hamson should be contacted. Please remember to include all of the written documentation and any notes that you have taken by completing the incident Problem and Log. If you do not have access to the system then use outlook and transfer the information later.

4.10 Please do not disclose any further information from this point until the next course of action has been decided by the designated safeguarding lead, Lana Foster.

5 Recording the disclosure of cause for concern

5.1 This section is informed by the principles contained within the Crown Prosecution Service guidance ‘Achieving Best Evidence’ March 2011. The report outlines guidance concerning early discussions with a child. There is a good recording practice pro-forma, available here, to review during a disclosure.

5.2 Where you suspect that a child is or has suffered abuse or neglect, avoid talking to the child in the presence of the suspected abuser.

5.3 Listen to the child rather than questioning them directly.

5.4 Never stop a child who is freely recalling events.

5.5 Use the ‘Tell, Explain, Describe’ model to confirm whether or not a child has been, is being or is at risk of abuse and who the suspected abuser is. The fine details of the alleged abuse should not be explored at this stage. This will be done by accredited professionals during the witness interview.

5.6 Make a contemporaneous note of the discussion, recording the timing, setting and people present as well as what was said (using the exact words used by the child). Retain your notes as these may be required in the future.

6. Receipt of a suspected report of child abuse by the Designated Safeguarding Lead

6.1 An emergency strategy meeting will be held to discuss the incident, assess the alleged threat and risk to the child, implement an action plan and continue to review the situation until a successful resolution has been achieved.

6.2 The incident will be recorded (with timed and dated entries) within a Student Record, on an ‘Incident’ template which will be assessed for disclosure to a statutory agency if this is in the interests of child protection.

6.3 For matters that are not deemed necessary for reporting to a statutory agency, the appropriate parties will be updated, for example the student, parents or school. For matters where advice is required, the local area’s Children’s Services or MASH will be contacted for expert guidance. Bright World will always take the advice provided to them by a statutory agency as they will be in possession of more facts and information, leading them to make an informed decision about the correct course of action to take.

6.4 The Designated Safeguarding Lead (DSL) within the company is the person who is responsible for receiving concerns about the safety and welfare of children and young people.

6.5 The DSL:
• Will be the first point of contact for all staff and volunteers for advice and guidance to employers, voluntary organisations and community groups on issues relating to child protection
• Has a higher level of safeguarding training and knowledge than the rest of the staff and should have completed Working Together to Safeguard Children and Young People
• Ensures that staff hold a current certificate for child protection training which is updated as per the required period of time
• Ensures that all staff child protection training is recorded in a central log which is audited regularly to identify training needs and any recording gaps
• Is responsible for updating the Safeguarding Policy annually and complete the Section 11 audit tool every 2 years
• Ensures that the company complies with the safe recruitment procedures for new staff members and their induction
• Makes formal referrals to the local area’s Children’s Services, MASH, police force or LSP
• Ensures that concerns are logged and stored securely with complete records of all child protection concerns, issues and incidents
• Has joint responsibility with the Managing Directors or board of trustees to ensure that the safeguarding policy and related policies and procedures are followed and regularly revised
• Is responsible for promoting a safe environment for children and young people
• Knows the contact details of relevant statutory agencies for example Children’s Services, Local Safeguarding Partnership and the local area’s police force
• Ensuring that this policy is made available to students and to their parents/guardians

6.6 The Local Authority Designated Officer will be contacted by the DSL where there is sufficient information to suggest that a child has, is being or is at risk of abuse. The LADO will be contacted for further advice from the relevant statutory authority, or where appropriate an immediate referral will be made to the relevant area’s Children’s Services or MASH.

6.7 The Local Authority Designated Officer (LADO) for each local area can be contacted via the relevant LSP. Contact details are available via the internet for each LSP with the name and telephone number for each LADO/point of contact for a LADO referral.

In West Sussex the MASH details are as follows:
MASH: Monday to Friday between 9am-5pm: 01403 229900
At all other times, including nights, weekends and bank holidays, contact the ‘out of hours’ emergency team: 0330 222 6664
Email: MASH@westsussex.gcsx.gov.uk

If a report of a child being abused, having been abused or being a risk of abuse is made and the child is in a different LSP area, then the contact details for the MASH or LADO in that area should be located via internet search.

6.8 For urgent cases, the police will be notified immediately via telephone number 999.

REVIEWED BY HEAD OFFICE ON 17/01/2020

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