Safeguarding and Child Protection Policy and Procedure

Policy Statement

This policy summarises Bright World’s safeguarding arrangements and current working practices for protecting children and young people who may be at risk of abuse or neglect whilst engaging with Bright World Education and Bright World Guardianships.

The policy sets out Bright World’s safeguarding principles, responsibilities and procedures throughout every stage of our involvement with a child, from an initial enquiry and school placement through to guardianship, host family accommodation, travel arrangements and ongoing welfare support. It also details our safeguarding measures, safer recruitment procedures, response to safeguarding concerns, online safety, information sharing and confidentiality.

Bright World recognises its moral and statutory responsibility to safeguard and promote the welfare of all children. We recognise that safeguarding is everyone’s responsibility and that all staff, volunteers, Local Coordinators, host families, contractors and any other individuals acting on behalf of Bright World have a role in identifying concerns, acting promptly and promoting children’s welfare.

We are committed to providing an environment in which children feel safe, secure, respected and valued. We encourage children to speak openly if they are worried and are committed to listening carefully, taking concerns seriously and responding appropriately.
Safeguarding underpins every service we provide. Whether we are advising families on school choices, arranging guardianship, selecting host families, organising travel or supporting students throughout their education, the welfare of the child will always be our first priority.

Aims of this Policy

The purpose of this policy is to provide staff, volunteers, Local Coordinators, host families and contractors with the framework they need to safeguard children effectively throughout every stage of Bright World’s services.

The policy also informs parents, legal guardians, agents, schools and partner organisations how Bright World safeguards children whilst they are engaged with our school placement or guardianship services.

This policy is based upon the latest versions of:
• Keeping Children Safe in Education (KCSIE)
• Working Together to Safeguard Children
• National Minimum Standards for Boarding Schools
• AEGIS Standards
• Relevant Local Safeguarding Partnership procedures
• Other statutory guidance and recognised safeguarding best practice.

The Bright World Mission Statement and Main Aims

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To keep every child safe whilst delivering outstanding educational support, guardianship and pastoral care.
Everything we do is underpinned by safeguarding. We are committed to protecting children, promoting their welfare and ensuring that every decision we make places the child’s best interests at its centre.

Safeguarding is the responsibility of every person working with Bright World, including:
• full-time and part-time staff;
• Local Coordinators;
• volunteers;
• contractors;
• host families;
• taxi companies and drivers;
• consultants; and
• anyone acting on behalf of Bright World.

This responsibility applies whether or not the individual works directly with children on a daily basis.

Bright World believes safeguarding begins long before a student arrives in the UK. It starts from the very first enquiry, continues throughout the admissions and placement process, remains central during guardianship, host family placements and travel arrangements, and continues until our involvement with the student has ended.

Where there is a child protection concern Bright World Guardianships will ensure the child’s wishes and feelings are taken into account when determining what action to take and what services to provide.

We provide clear information for students on the Bright World App. We check that students understand the information and are comfortable about how they can raise a concern. We explain how concerns will be treated seriously, and that students can safely express their views and give feedback.

All staff, host families and volunteers should recognise that children may not feel ready to disclose abuse or may not recognise that what they are experiencing is harmful. Children may also be prevented from speaking because of fear, embarrassment, coercion, loyalty, disability, language barriers, cultural expectations or previous experiences.

This must never prevent staff from maintaining professional curiosity or discussing concerns with the Designated Safeguarding Lead (DSL). We are committed to ensuring that unconscious bias does not influence safeguarding decisions, particularly when working with children from affluent backgrounds. Staff and host families must remain alert to all forms of neglect, including affluent neglect.

Staff and host families should be aware that safeguarding concerns may overlap and that children may experience multiple safeguarding risks at the same time. Children may also experience barriers to disclosure because of fear, embarrassment, loyalty, coercion, cultural factors, disability, communication needs or because they do not recognise behaviour as harmful. This includes risks arising from children’s use of online platforms, social media, gaming environments and emerging technologies, including artificial intelligence tools.

It is important that staff and host families determine how best to build trusted relationships with children and young people which facilitate communication

Child Protection from part of safeguarding and refers to the action taken to protect individual children who are suffering, or are likely to suffer, significant harm.

• Child-on-child abuse, including sexual harassment and sexual violence
• Child sexual exploitation
• Child criminal exploitation, including county lines
• Modern slavery and trafficking
• Radicalisation and extremism
• Serious violence
• Female genital mutilation (FGM)
• Forced marriage and honour-based abuse
• Domestic abuse
• Physical, emotional and sexual abuse
• Neglect, including affluent neglect
• Online abuse, including risks associated with social media, gaming, artificial intelligence, generative AI and other emerging technologies
• Bullying and cyberbullying
• Mental health concerns
• Self-harm and suicidal ideation
• Misogyny and harmful attitudes linked to gender

We aim to:

	ensure that Bright World Guardianships students have a safe and child-centred environment which promotes and prioritises their safety and wellbeing, recognising that children with special educational needs and disabilities, medical conditions and other additional needs may face additional safeguarding challenges or barriers to reporting concerns.
	promote an environment of trust, openness and clear communication between students, school and Bright World staff and our host families so that student welfare, safety and pastoral care is recognised as the top priority;
	support children’s development by protecting them from specific safeguarding issues and all forms of child abuse
	create a culture of safe recruitment, adopt procedures that help deter, reject or identify people who might abuse children and create an environment where staff remain vigilant
	ensure that we follow our Safer Recruitment policy and procedure and that all Bright World Guardianships staff, host families and volunteers understand their safeguarding responsibilities, including identifying safeguarding concerns and reporting child protection concerns appropriately.
	Staff, host families and volunteers will receive appropriate safeguarding training and regular updates covering emerging safeguarding risks, online safety, information sharing, child-on-child abuse, sexual harassment and violence, exploitation, mental health and other areas identified through national guidance and local safeguarding priorities.
	ensure that taxi companies we use follow our safeguarding requirements and Code of Conduct, and that appropriate safer recruitment checks, including DBS checks where applicable, are completed and verified for drivers transporting students.
	ensure that appropriate action is taken in the event of incidents or concerns of abuse being reported to Bright World staff and that support is provided to individuals who raise or disclose the concern
	ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
	We maintain links with the appropriate agencies who have a statutory responsibility to deal with child welfare and child protection concerns.

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If you have any reason to believe that a child connected with Bright World is suffering, or is at risk of suffering, abuse, neglect or exploitation, you must report your concerns immediately to Robbie Piper (DSL) or, in his absence, Lana Foster, Su Warren or James Foster (Deputy DSLs), using the contact details contained within this policy.

This policy will be reviewed annually or sooner where there are changes to legislation, statutory guidance, safeguarding practice, organisational arrangements or following any safeguarding incident or significant learning.

Bright World Guardianships Contacts

Bright World recognises that safeguarding children is the responsibility of everybody and the owners and directors of the company have appropriate safeguarding training and oversight of company practices.

Name	Title	Email	Number
Robbie Piper	DSL, Mental Health and Prevent Lead	robbie@brightworld.co.uk	Direct: 01273 836068
Lana Foster	DSL	lana@brightworld.co.uk	Direct: 01273 836789
Su Warren	Deputy DSL	su@brightworld.co.uk	Direct: 01273 836780
James Foster	Deputy DSL	james@brightworld.co.uk	Direct: 01273 836788

Concerns in relation to the Managing Directors should be addressed to the Guardianship & Safeguarding Manager, Robbie Piper. Concerns in relation to the Senior Guardianship & Safeguarding Manager, Robbie Piper, should be addressed to Lana or James Foster. Concerns about any of the above can be directed to Crimestoppers which will remain confidential.

Guidance we refer to and advise our staff and host families to read

Statutory Guidance for Schools and Colleges on Safeguarding Children and Safer Recruitment in Education

Department for Education

Keeping Children Safe in Education

Working Together to Safeguard Children

National Guidance for Child Protection in Scotland

Social Services and Well-being (Wales) Act

What to do if you are worried that a child is being abused

Bright World Guardianships’ policies and processes are in line with the requirements of the

* Association for the Education and Guardianship of International Students
* National Minimum Boarding Standards

Bright World Guardianships refers to various expert sources advice on child abuse and safeguarding, for example National Society for the Prevention of Cruelty to Children (NSPCC) website, Barnardo’s and the Local Safeguarding Partnerships (LSP) when developing policies and managing incidents.

* NSPCC safeguarding guidance and resources

Safeguarding During School Placement Services

Bright World recognises that safeguarding begins long before a student arrives at school or enters a guardianship arrangement. Our responsibility to safeguard children starts from the first enquiry and continues throughout the school placement process, admissions, arrival in the UK and, where applicable, throughout our guardianship service.

All staff involved in Bright World Education’s school placement service share responsibility for safeguarding children and must remain vigilant to signs of abuse, neglect, exploitation or other welfare concerns. Safeguarding should form part of every decision made during the admissions and placement process.

Initial Enquiries

The first contact with a prospective family may identify safeguarding concerns or vulnerabilities.
During initial enquiries staff will:
• establish who holds legal parental responsibility for the child;
• verify, where appropriate, who has authority to make decisions on the child’s behalf;
• remain alert to unusual family circumstances, coercive or controlling behaviour, inconsistencies in information or any concerns regarding the child’s welfare;
• ensure discussions are appropriate to the child’s age, maturity and understanding;
• maintain professional curiosity where information appears inconsistent or incomplete;
• seek advice from the Designated Safeguarding Lead (DSL) if any safeguarding concerns arise.

Meetings with Families

Meetings with prospective students and families should always take place in a safe, professional environment.
Bright World staff will:
• conduct meetings in suitable offices or professional settings wherever possible;
• ensure children are not normally left alone with one member of staff;
• use meeting rooms that provide appropriate visibility or follow office procedures designed to protect both children and staff;
• follow visitor sign-in procedures where applicable;
• maintain appropriate professional boundaries throughout all meetings.

Where meetings are held online, staff should use approved business platforms and ensure meetings remain professional and appropriately recorded where necessary.

Student Interviews and Assessments

Admissions interviews and educational discussions should always be conducted with the welfare of the child in mind.
Staff will:
• ensure discussions relate only to admissions, education, wellbeing and pastoral support;
• ask only appropriate and relevant questions;
• avoid intrusive questioning unrelated to the admissions process;
• treat children with dignity and respect;
• ensure another member of staff or parent is nearby where appropriate.

Identity Verification and Documentation

Bright World receives personal documentation including passports, birth certificates, visas, school reports and other sensitive information.

Staff will:
• process documentation in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and Bright World’s Data Protection Policy;
• store documents securely;
• use secure methods when transferring documentation to schools and partner organisations;
• verify identities wherever appropriate;
• remain alert to inconsistencies, suspected identity fraud or altered documentation;
• immediately report concerns to the DSL.

School Recommendations

Safeguarding is central to every school recommendation made by Bright World.
When advising families, staff will:
• recommend schools that best meet the child’s academic, pastoral, medical and wellbeing needs;
• provide balanced, honest and impartial advice;
• never recommend a school solely because of commission arrangements or commercial relationships;
• consider the safeguarding, pastoral and boarding arrangements offered by prospective schools;
• declare and appropriately manage any conflicts of interest.

Admissions and Applications

Bright World will ensure that the admissions process is conducted honestly, transparently and in the child’s best interests.
Staff will:
• provide accurate information to schools;
• ensure information supplied on behalf of applicants is truthful and complete to the best of our knowledge;
• never knowingly conceal safeguarding concerns relevant to a school’s ability to safeguard the child;
• never coach students or families to provide misleading or inaccurate information;
• seek advice from the DSL where safeguarding information may need to be shared with a prospective school.

Communication with Children and Families

Bright World expects all staff to maintain professional boundaries at all times.
Staff will:
• use Bright World email addresses and approved business communication systems wherever possible;
• avoid communicating with children through personal social media accounts;
• avoid excessive or unnecessary direct messaging with children;
• copy parents or legal guardians into communications where appropriate;
• maintain professional language and behaviour at all times;
• keep appropriate records of significant communications relating to student welfare.

Travel and Arrival Arrangements

Where Bright World assists with travel planning, safeguarding considerations will form part of every arrangement.
Staff will:
• verify travel arrangements before arrival;
• confirm who will be meeting the child at each stage of their journey;
• ensure suitable guardianship arrangements are in place where required;
• communicate relevant arrival information to schools where appropriate;
• remain alert to unexpected changes that could affect a child’s safety.

Pre-Arrival Welfare Information

Before a student arrives at school, Bright World will encourage parents to provide information necessary to safeguard and support the child.
This may include:
• medical conditions;
• allergies;
• disabilities or Special Educational Needs and Disabilities (SEND);
• mental health concerns;
• medication requirements;
• dietary requirements;
• previous safeguarding concerns where relevant;
• any additional information necessary to enable the receiving school to safeguard the child appropriately.

Where appropriate and lawful to do so, this information will be shared with the receiving school, with parental knowledge or consent unless doing so would place the child at increased risk of harm.

Responding to Safeguarding Concerns Before Enrolment

Safeguarding concerns may arise before a student has formally joined a school or commenced guardianship.
Where any member of staff becomes aware of:
• suspected abuse or neglect;
• exploitation or trafficking;
• child criminal exploitation;
• child sexual exploitation;
• radicalisation;
• self-harm or suicidal ideation;
• online abuse;
• domestic abuse;
• forced marriage;
• honour-based abuse; or
• any other safeguarding concern,
they must immediately inform the Designated Safeguarding Lead (DSL) or Deputy DSL.

Staff must never promise absolute confidentiality to a child. Children should be reassured that information will only be shared with those who need to know in order to keep them safe.

Bright World will work collaboratively with parents, schools, local safeguarding partners and statutory agencies whenever appropriate to safeguard the welfare of the child.

Professional Boundaries

All Bright World staff involved in school placement services must maintain clear professional boundaries.
Staff must not:
• communicate with students using personal social media accounts;
• arrange private meetings away from professional settings;
• give personal gifts or accept inappropriate gifts;
• transport students unless authorised by Bright World;
• share personal contact details except where authorised for business purposes;
• develop relationships with students that could compromise professional judgement or safeguarding.
Any concern regarding professional boundaries must be reported immediately to the DSL.

Recording Safeguarding Concerns

Any safeguarding concern identified during the school placement process must be recorded promptly, accurately and objectively.
Records should include:
• the nature of the concern;
• the information received;
• any action taken;
• advice sought;
• decisions made;
• the rationale for those decisions; and
• any information shared with schools or statutory agencies.

Safeguarding records relating to school placement enquiries will be retained in accordance with Bright World’s safeguarding and data retention procedures, including where the student does not ultimately proceed with a school placement or guardianship service.

Safeguarding throughout the student recruitment and admissions process

Supporting Procedures and Safeguarding Responsibilities

Safeguarding is embedded throughout every aspect of Bright World’s work. The procedures below apply to all members of staff, Directors, Local Coordinators, host families, volunteers, contractors and any individual acting on behalf of Bright World.
All individuals are expected to read, understand and comply with this policy alongside the organisation’s related safeguarding procedures.

Safeguarding responsibilities begin from the first contact with a prospective student and continue until Bright World’s involvement with that child has ended.

Recognising Safeguarding Concerns

Everyone working for or representing Bright World must remain alert to indicators that a child may be experiencing abuse, neglect or exploitation.
Concerns may arise from:
• direct disclosures by a child;
• observations of a child’s behaviour, appearance or emotional wellbeing;
• information received from parents, schools, agents or third parties;
• concerns identified during school placement interviews or admissions;
• welfare visits;
• host family observations;
• travel arrangements;
• online communication;
• social media activity where concerns become known;
• repeated changes in behaviour or presentation.

No single indicator necessarily confirms abuse. However, staff should remain professionally curious and consider the wider context when assessing concerns.
Where there is uncertainty, advice should always be sought from the Designated Safeguarding Lead (DSL).

Responding to a Disclosure

If a child discloses abuse or neglect, staff must respond calmly, sensitively and without judgement.
Staff should:
• listen carefully;
• allow the child to speak freely;
• remain calm and reassuring;
• acknowledge that the child has done the right thing by speaking;
• avoid expressing shock or disbelief;
• explain that the information cannot be kept confidential if someone is at risk;
• make a written record as soon as possible using the child’s own words wherever possible;
• report the concern immediately to the DSL.
Staff must not:
• promise confidentiality;
• ask leading questions;
• investigate the allegation themselves;
• attempt to interview alleged perpetrators;
• delay reporting concerns.
The welfare of the child must always take precedence over organisational or reputational considerations.

Reporting Safeguarding Concerns

Every safeguarding concern, however minor it may initially appear, should be reported promptly.
Concerns should be reported immediately to:
• the Designated Safeguarding Lead (DSL); or
• in their absence, one of the Deputy Designated Safeguarding Leads.
Where a child is believed to be at immediate risk of significant harm, emergency services should be contacted without delay, followed by immediate notification to the DSL.
No member of staff will ever be criticised for reporting a genuine safeguarding concern made in good faith.

Information Sharing

Effective safeguarding depends upon timely and appropriate information sharing.
Bright World will share safeguarding information only where it is lawful, proportionate and necessary to protect a child.
Information may be shared with:
• schools;
• local authority children’s services;
• police;
• health professionals;
• Local Safeguarding Partnerships;
• UK Visas and Immigration where appropriate;
• other agencies with statutory safeguarding responsibilities.
Consent should normally be sought before sharing information unless doing so would place a child at greater risk or would prejudice a safeguarding investigation.
The safety of the child will always take precedence.

Professional Curiosity

Bright World expects all staff to exercise professional curiosity throughout their work.
Professional curiosity means:
• noticing when something does not feel right;
• respectfully exploring inconsistencies;
• asking appropriate questions;
• avoiding assumptions;
• considering whether there may be an underlying safeguarding issue.
Professional curiosity is particularly important where:
• explanations appear inconsistent;
• children appear withdrawn, fearful or unusually anxious;
• information changes repeatedly;
• adults appear controlling or reluctant to allow children to speak;
• there are repeated unexplained changes to travel, accommodation or care arrangements.
Staff should always discuss concerns with the DSL rather than dismissing them.

Working with Schools

Bright World works closely with schools to promote children’s welfare.
Where safeguarding concerns arise, Bright World will work collaboratively with designated safeguarding leads, pastoral teams, boarding staff and other appropriate professionals.
Information shared with schools should be:
• factual;
• accurate;
• relevant;
• proportionate;
• recorded appropriately.
Bright World recognises that safeguarding is most effective where organisations work together openly and professionally.

Working with Parents and Legal Guardians

Parents and legal guardians are important safeguarding partners.
Bright World aims to maintain open and honest communication whilst recognising that there may be circumstances where safeguarding concerns cannot immediately be shared if doing so would place a child or another individual at increased risk.
Where appropriate, parents will be informed of concerns and involved in safeguarding planning.
Where statutory agencies advise that information should not be shared, Bright World will follow that advice.

Escalating Concerns

If a member of staff believes that appropriate action has not been taken following a safeguarding referral, they have a responsibility to escalate their concerns.
Escalation may include:
• raising concerns again with the DSL;
• consulting a Deputy DSL;
• contacting children’s social care;
• contacting the police where appropriate;
• following Local Safeguarding Partnership escalation procedures.
Bright World supports staff who raise safeguarding concerns in good faith.

Confidentiality

Safeguarding information is confidential and must only be shared with those who have a legitimate need to know.
Safeguarding records must never be discussed casually or disclosed for reasons unrelated to protecting the child.
All safeguarding documentation will be stored securely in accordance with Bright World’s Data Protection Policy and information retention procedures.
Confidentiality should never prevent appropriate safeguarding action being taken where a child may be at risk.

Child-Centred Practice

Bright World places children at the centre of safeguarding decision-making.
Every child has the right to:
• be listened to;
• feel safe;
• be treated with dignity and respect;
• receive appropriate support;
• have their wishes and feelings considered according to their age and understanding.
Where decisions are made that differ from a child’s expressed wishes, the reasons for those decisions should be clearly recorded.
Throughout every safeguarding process the best interests of the child will remain Bright World’s primary consideration.

Child Protection Principles

The following principles underpin our provisions and practices in relation to safeguarding and child protection:

	Bright World Guardianships will provide a safe and secure environment for all students;
	Host families and taxi companies provide a safe and secure environment for all students;
	All students feel safe, secure and protected from harm;
	All students are supported through a child-centred approach that recognises their individual circumstances, needs, vulnerabilities and barriers to reporting concerns.
	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;
	Students are provided with accessible information about how to raise concerns, including concerns relating to abuse, harassment, exploitation, online harm or inappropriate behaviour by others.		The owners of the company, Lana and James Foster, have overall responsibility and accountability for the safeguarding and welfare of the students;
	Bright World Guardianships ensures appropriate Designated Safeguarding Lead (DSL) and Deputy DSL cover arrangements are maintained at all times. Where the DSL is unavailable, a trained deputy will take responsibility for safeguarding matters and staff and host families will have access to a clear method of contacting safeguarding leads.
	All staff, host families and volunteers 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;
	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 and these are shared with the host family on a need to know basis;
	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.

Supporting procedures and documents

This policy is to be read in conjunction with the following policies and documents:

• Anti-bullying and (including cyber-bullying) policy

• Anti-Radicalisation Policy

• Online safety policy (including guidance on artificial intelligence, generative AI and emerging technologies)

• Honour Based’ Violence – Female Genital Mutilation (FGM), Breast Ironing and Forced Marriage Policy

• Emergency procedure

• Low Level Concerns Policy

• Absent or Missing student Policy

• Safer Recruitment Policy for Host Families

• Safer Recruitment Policy for staff

• Staff Code of Conduct

• Host Family Code of Conduct

• Whistleblowing Policy

• Welfare, Health and Safety Policy

• Complaints Policy and Procedure

Definitions

|_. Term |_. Meaning | | Safeguarding and promoting the welfare of children | is defined as:
• protecting children from maltreatment;
• preventing impairment of children’s mental and physical health or development;
• ensuring that children grow up in circumstances consistent with the provision of safe and effective care;
• taking action to enable all children to have the best outcomes. | | Child Protection | Is part of safeguarding and promoting welfare. It refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm. | | Designated Safeguarding Lead (DSL) | This is the person identified as taking the lead in safeguarding matters in an organisation. This person (and any deputy) will be trained to a higher level. | | Prevent | Prevent is the name given to part of the government’s strategy to prevent terrorism by reducing the possibility of radicalisation.| | Local Safeguarding Partnership (LSP) | Formerly Local Safeguarding Children Board (LSCB) and consisting of the local authority, the clinical commissioning group within the local authority and the chief office of police within the local authority. | | LADO | The role of the Local Authority Designated Officer (LADO) is to coordinate all allegations and concerns made against a person who works with children. | | Children| ‘Children’ includes everyone under the age of 18. | | MASH | Multi-agency Safeguarding Hub – MASH is the front door service, a team made up of social workers, police officers and health and education staff who aim to protect vulnerable children and young people.| | CAMHS | Child and adolescent mental health services – part of the NHS who help with Mental Health illness. | | Family Help | The targeted early help level of support provided to children and families where additional support is needed beyond universal services and community-based early help. | Modern Slavery| Includes trafficking, exploitation, forced labour and other situations where individuals are controlled, coerced or exploited. Children can be particularly vulnerable to exploitation and may not recognise themselves as victims.

Child-on-Child Abuse (Peer-on-Peer Abuse), Including Sexual Violence and Sexual Harassment

Bright World recognises that children can abuse other children. Such abuse can occur both inside and outside school, online and offline, and may occur between friends, siblings, peers or within wider social groups.

Child-on-child abuse will never be dismissed as “banter”, “part of growing up”, “horseplay”, “boys being boys” or “just a disagreement”. All concerns will be taken seriously, investigated appropriately by the relevant safeguarding professionals and responded to in a child-centred manner.

Bright World recognises that harmful sexual behaviour exists on a continuum, ranging from inappropriate sexualised behaviour and sexual harassment through to sexual violence. All concerns, including those that may initially appear minor, will be taken seriously and assessed to determine the appropriate safeguarding response.

Children who abuse other children may themselves have experienced abuse or trauma. Whilst this does not diminish the seriousness of their behaviour, it should be considered when determining appropriate safeguarding responses and support.

Bright World also recognises that the absence of reports does not mean abuse is not occurring. Staff, host families and Local Coordinators should remain vigilant and report any concerns to the Designated Safeguarding Lead (DSL).
Bright World adopts a zero-tolerance approach to all forms of child-on-child abuse.

Forms of Child-on-Child Abuse

Child-on-child abuse may include, but is not limited to:
• bullying, including cyberbullying and prejudice-based bullying;
• physical abuse;
• emotional abuse;
• sexual harassment;
• sexual violence;
• harmful sexual behaviour;
• upskirting;
• initiation or hazing-type violence;
• coercive or controlling behaviour;
• image-based abuse, including the sharing of nude or semi-nude images without consent;
• abuse involving artificial intelligence, manipulated or deepfake images;
• online intimidation, coercion or blackmail;
• exploitation;
• discriminatory behaviour relating to race, religion, disability, sex, gender reassignment or sexual orientation.

Abuse may consist of a single incident or a pattern of behaviour.

Staff should understand that consent must be freely given and that children may be unable to give consent where there is pressure, coercion, intimidation, manipulation or an imbalance of power. A child’s apparent agreement does not necessarily mean that behaviour is acceptable or safe.

Preventing Child-on-Child Abuse

Bright World seeks to minimise the risk of child-on-child abuse by:
• providing regular safeguarding training for staff, Local Coordinators and host families;
• educating students through inductions, handbooks and safeguarding information available on the Bright World App;
• providing students with clear guidance on how to raise concerns, including through the Bright World App reporting form;
• fostering open communication so students feel comfortable speaking to trusted adults, including school staff, parents, host families, guardians and Bright World’s safeguarding team;
• maintaining effective communication with schools and other safeguarding partners;
• promoting respectful relationships, equality, inclusion and responsible online behaviour.

Bright World’s Role

Although schools have primary responsibility for managing incidents occurring within their setting, Bright World has an important safeguarding role whenever concerns involve one of our students.
Bright World will:
• listen carefully to the child raising the concern;
• reassure the child that they have done the right thing;
• explain that concerns cannot remain confidential where safeguarding issues exist;
• make an accurate written record using the child’s own words wherever possible;
• report concerns immediately to the DSL or Deputy DSL;
• work collaboratively with the school’s Designated Safeguarding Lead and pastoral staff;
• support the student throughout the safeguarding process;
• communicate appropriately with parents or carers where this is safe and in line with safeguarding advice;
• maintain accurate safeguarding records.
Where incidents occur within host family accommodation or during activities organised by Bright World, appropriate safeguarding action will be taken immediately.

Sexual Harassment and Sexual Violence

Sexual harassment and sexual violence are never acceptable and should never be tolerated or dismissed.
Examples include:
• unwanted sexual comments;
• sexualised jokes;
• unwanted touching;
• sexual assault;
• coercion into sexual activity;
• sharing intimate images without consent;
• online sexual abuse;
• sexual intimidation or threats.

Bright World recognises that victims may not report concerns immediately due to embarrassment, fear of not being believed, loyalty to others or concerns about the consequences.
Staff, host families and Local Coordinators should create an environment in which children feel safe to report concerns and are confident they will be listened to and taken seriously.

Online Child-on-Child Abuse

Online abuse can occur without face-to-face contact and may have significant safeguarding implications.
Examples include:
• cyberbullying;
• threatening or abusive messages;
• sharing of nudes and semi nudes
• image manipulation using artificial intelligence or deepfake technology;
• impersonation;
• online coercion or blackmail;
• sexual harassment through social media or messaging platforms;
• exclusion from online groups.
Where concerns involve the making or sharing of nude or semi-nude images, staff must not view, copy, save or forward images unless there is a clear safeguarding reason to do so and this is managed in accordance with current statutory guidance and under the direction of the DSL.
Staff should remain aware that online abuse can continue outside school hours and across international borders.

Responding to Concerns

Where a concern is identified, staff, Local Coordinators and host families should:
• remain calm;
• listen carefully and reassure the child;
• avoid asking leading questions;
• never promise confidentiality;
• make an accurate written record;
• report the concern immediately to the DSL or Deputy DSL.
Staff and host families must never investigate allegations themselves or attempt to mediate between children where abuse may have occurred.
Where there is an immediate risk of harm, the DSL, or any individual if necessary, should contact the Police or Children’s Social Care without delay.
The DSL will:
• assess the concern and determine the appropriate safeguarding response;
• liaise with the student’s school DSL where appropriate;
• seek advice from Children’s Social Care or other safeguarding agencies where thresholds are unclear;
• consider whether an Early Help assessment or referral is appropriate;
• refer concerns to Children’s Social Care or the Police where necessary;
• share information with parents or carers unless doing so would place the child at increased risk of harm or prejudice a criminal investigation.
If the DSL or Deputy DSL is unavailable, this must not delay appropriate safeguarding action. Any individual may make a referral directly to Children’s Social Care or the Police if a child is believed to be at risk of harm.

Risk Assessment

Where there has been a report of sexual violence between children, the DSL will undertake an immediate risk and needs assessment. Reports of sexual harassment will also be considered for risk assessment on a case-by-case basis.
The assessment will consider:
• the needs, wishes and protection of the child who has experienced harm;
• the nature and seriousness of the behaviour, including any evidence of coercion, intimidation or exploitation;
• the child alleged to have caused the harm;
• any risks posed to other children, host families or staff;
• whether any immediate safeguarding measures are required.
Risk assessments will be recorded, reviewed regularly and updated as circumstances change.

Supporting Children

Bright World recognises that safeguarding support may be required for:
• the child who has experienced abuse;
• the child whose behaviour has caused harm;
• witnesses;
• friends or other children affected by the incident.
Support may include regular welfare contact, liaison with schools, parents, host families, mental health services, statutory safeguarding agencies and signposting to specialist support organisations.
Bright World will always seek to minimise disruption to the child’s education whilst ensuring appropriate safeguarding measures remain in place.

Management of Reports

Following assessment, the DSL will determine the most appropriate response, which may include:
• managing the matter internally through safeguarding measures and education;
• liaison with the student’s school;
• Early Help support;
• referral to Children’s Social Care;
• referral to the Police where a criminal offence may have occurred.
Bright World will work collaboratively with all relevant agencies to ensure children receive appropriate protection and support.

Record Keeping

All incidents of child-on-child abuse, suspected abuse or harmful behaviour involving Bright World students must be recorded.
Records should include:
• the concern raised;
• actions taken;
• referrals made;
• advice received;
• communications with schools and parents;
• safeguarding decisions and risk assessments;
• ongoing safeguarding arrangements;
• final outcomes where known.
Records will be retained securely in accordance with Bright World’s safeguarding, confidentiality and data retention procedures.

Creating a Safe Culture

Bright World is committed to promoting respectful relationships, equality, inclusion and positive behaviour throughout all aspects of its work.
Students are encouraged to:
• report concerns about themselves or others;
• respect personal boundaries;
• behave responsibly online;
• understand the importance of consent;
• support one another appropriately by reporting concerns to trusted adults.
Every child has the right to feel safe, respected and protected from abuse. Bright World will always place the welfare and best interests of the child at the centre of its response to any incident of child-on-child abuse.

Allegations Against Adults Working with Children

Bright World is committed to creating and maintaining a culture of openness, transparency and accountability in which all safeguarding concerns involving adults are taken seriously and managed fairly, consistently and without delay.
This section applies to all adults working on behalf of Bright World, including:
• Directors;
• employees;
• Local Coordinators;
• host families and members of their household;
• volunteers;
• contractors;
• consultants;
• taxi drivers engaged by Bright World;
• agency staff; and
• any other individual acting on behalf of the organisation.
Bright World manages allegations in accordance with the principles set out in Keeping Children Safe in Education (Part Four) and relevant statutory safeguarding guidance.
Bright World recognises that safeguarding children includes ensuring that unsuitable adults are prevented from working with children and that concerns about adults are responded to promptly and appropriately.

What is an Allegation?

An allegation may arise where it is believed that an adult working with children has:
• behaved in a way that has harmed, or may have harmed, a child;
• possibly committed a criminal offence against or relating to a child;
• behaved towards a child or children in a way that indicates they may pose a risk of harm to children;
• behaved, or may have behaved, in a way that indicates they may not be suitable to work with children, including behaviour that presents a transferable risk.
Allegations may relate to behaviour inside or outside work, including online activity.

Immediate Response

Any allegation must be treated seriously.
The person receiving the allegation should:
• remain calm;
• listen carefully;
• avoid asking leading questions;
• reassure the individual reporting the concern;
• explain that the information cannot remain confidential where safeguarding concerns exist;
• make an accurate written record using the person’s own words wherever possible;
• report the matter immediately to the DSL.
Staff, host families and Local Coordinators must never investigate allegations themselves.
Where the allegation concerns the DSL, the concern should be reported immediately to Lana Foster or another Director.
Where the allegation concerns a Director, it should be reported to another Director, who will seek advice from the Local Authority Designated Officer (LADO) as appropriate.

Referral to the Local Authority Designated Officer (LADO)

Bright World will seek advice from the appropriate LADO whenever an allegation may meet the statutory harm threshold.
The LADO will advise on:
• whether the allegation meets the threshold;
• whether further investigation is required;
• whether Police or Children’s Social Care involvement is necessary;
• what information can appropriately be shared;
• any immediate safeguarding measures required.
Bright World will follow all advice provided by the LADO and other statutory agencies.

Suspension and Risk Management

Suspension is not an automatic response to an allegation.
Where appropriate, Bright World will undertake a risk assessment to determine the most suitable course of action whilst safeguarding enquiries are undertaken.
This may include:
• temporary redeployment;
• additional supervision;
• restriction of duties;
• temporary removal from regulated activity;
• suspension where advised by the LADO or other statutory agencies.
The welfare of children will always be the overriding consideration.

Confidentiality

Allegations will be handled confidentially and information will only be shared with those who need to know.
Bright World recognises that both the child and the adult concerned are entitled to be treated fairly throughout the process.
Information should not be shared more widely than necessary, and staff should avoid speculation or discussion outside those directly involved.

DBS Referrals

Where Bright World removes an individual from regulated activity, or would have done so had they not left, because they have harmed or posed a risk of harm to a child, the organisation will make a referral to the Disclosure and Barring Service (DBS) in accordance with its legal duties.

Historical Allegations

Historical allegations of abuse will be taken seriously and referred to the Police where appropriate. Bright World will work with the relevant safeguarding agencies to ensure that historical concerns are managed in accordance with current statutory guidance.

Support

Bright World recognises that allegations can be distressing for everyone involved.
Appropriate support will be offered to:
• the child or young person;
• parents or legal guardians where appropriate;
• the member of staff, volunteer or host family concerned;
• colleagues affected by the allegation.
Support arrangements will always be consistent with safeguarding requirements and any advice received from statutory agencies.

Allegations that do not meet the threshold (Low level concerns)

Bright World Guardianships has a Low Level Concerns policy and a Low Level Concerns List that outlines the processes we will follow to deal with concerns (including allegations) which do not meet the harm threshold set out above. We also have a staff code of conduct that explains professional boundaries.

Bright World recognises that not all concerns about adults working with children will meet the threshold for referral to the Local Authority Designated Officer (LADO). However, concerns that do not meet this threshold should never be ignored or dismissed.
Bright World has a Low-Level Concerns Policy and associated procedures which set out how concerns about the behaviour of adults working with or on behalf of Bright World will be identified, recorded, considered and managed.

A low-level concern is any concern, no matter how small, that an adult working with children may have acted in a way that:
• is inconsistent with Bright World’s Code of Conduct or expected professional standards;
• does not meet the threshold for an allegation requiring LADO involvement; or
• causes a sense of unease or a “nagging doubt” regarding an individual’s suitability to work with children.

The term “low-level” does not mean that the concern is insignificant. Early identification and appropriate management of concerns helps to maintain professional standards, prevent misunderstandings, identify patterns of behaviour and safeguard children.
Low-level concerns may relate to behaviour inside or outside of work where that behaviour may affect an individual’s suitability to work with children.

Examples of behaviour that may amount to a low-level concern include, but are not limited to:
• being overly familiar with children;
• showing favouritism towards particular students;
• using inappropriate language or humour;
• unnecessary physical contact;
• failing to maintain appropriate professional boundaries;
• communicating with students through unauthorised personal messaging or social media accounts;
• taking photographs of children using personal devices without appropriate approval;
• giving personal gifts to students without authorisation;
• transporting students without following Bright World’s procedures;
• failing to follow safeguarding procedures;
• behaviour that demonstrates poor judgement and could place a child or adult at risk.

This list is not exhaustive.

Bright World recognises that behaviour may exist on a wide spectrum. Some behaviours may be inadvertent, thoughtless or arise from poor judgement, whilst others may indicate a developing pattern of behaviour that requires further safeguarding action.
All staff, Directors, Local Coordinators, host families, volunteers, contractors and anyone working on behalf of Bright World have a responsibility to report concerns about the behaviour of adults where there is uncertainty about whether professional standards have been met.

Reporting and Managing Low-Level Concerns

All low-level concerns should be reported promptly to the Designated Safeguarding Lead (DSL), or an appropriate Director where the concern relates to the DSL.

Staff and host families should not assume that a concern is too minor to report or that someone else will raise it.

Bright World will:
• listen carefully to the concern;
• record the information factually and objectively;
• consider whether the concern indicates a wider safeguarding issue;
• assess whether there is a pattern of concerning behaviour;
• determine whether additional advice, training, supervision or support is required;
• consider whether the concern meets the threshold for referral to the LADO.
Where further information becomes available, previously recorded low-level concerns may be reviewed alongside new information to determine whether further safeguarding action is required.
Low-level concerns will be managed fairly, proportionately and confidentially. The purpose of managing such concerns is to maintain high safeguarding standards, support safer working practices and protect both children and adults from inappropriate situations or misunderstandings.

Recording Low-Level Concerns

All low-level concerns will be recorded securely in accordance with Bright World’s safeguarding procedures, Data Protection Policy and records retention requirements.
Records will be:
• factual;
• objective;
• clear;
• confidential;
• stored securely.

Records should include:
• the nature of the concern;
• when the concern was raised;
• who raised the concern;
• the person the concern relates to;
• any relevant background information;
• actions taken;
• advice received;
• decisions reached;
• the reasons for those decisions.

Records will be retained to enable appropriate review, identify patterns of behaviour and support effective safeguarding decision-making.

Safeguarding Culture and Professional Expectations

Bright World is committed to creating a safeguarding culture where concerns can be raised openly and without fear of unfair criticism.
All individuals working on behalf of Bright World are expected to:
• maintain professional boundaries;
• demonstrate appropriate behaviour at all times;
• challenge unsafe or inappropriate practice;
• report concerns promptly;
• contribute to a culture of openness, accountability and continuous improvement.
Reporting low-level concerns supports safer working practices by allowing concerns to be addressed at an early stage and reducing the risk of inappropriate behaviour escalating.
Bright World will always act proportionately, fairly and in the best interests of children, while ensuring that adults involved in safeguarding processes are treated with dignity and respect.

Learning Lessons

Bright World Guardianships recognises that safeguarding concerns and allegations provide opportunities to learn, reflect and strengthen safeguarding practice.

Throughout the process of managing an allegation against an adult working with or on behalf of Bright World, and following the conclusion of any case, the Designated Safeguarding Lead (DSL), relevant managers and, where involved, the Local Authority Designated Officer (LADO), will review the circumstances of the case to identify whether any improvements can be made to prevent similar concerns arising in the future.

This review may include consideration of:
• the effectiveness of safeguarding procedures;
• the timeliness and quality of decision-making;
• communication between those involved;
• information sharing arrangements;
• any action taken to manage risk, including whether temporary removal from duties, suspension or other protective measures were appropriate;
• whether additional training, guidance or supervision is required.

Where an individual is reinstated following an allegation, Bright World will consider whether any additional support, monitoring or safeguarding arrangements are required to ensure safe practice and protect all parties.

Where an allegation is concluded to be unfounded, false, malicious or unsubstantiated, the DSL and relevant managers (and the LADO where involved) will consider whether any learning can be identified and whether improvements to procedures, training or safeguarding arrangements are required.

Learning identified through safeguarding reviews will be used to strengthen Bright World’s safeguarding culture and improve the protection of children and young people.

Self-Reporting

Bright World Guardianships is committed to fostering a safeguarding culture based on honesty, openness, accountability and continuous learning.

Everyone working on behalf of Bright World has a professional responsibility to report safeguarding concerns, including concerns about themselves where these may affect their suitability to work with children.

Bright World recognises that individuals may find themselves in situations which could be misinterpreted, appear compromising to others, or where, on reflection, they feel their behaviour may have fallen below the standards expected within the relevant Code of Conduct.

Self-reporting is encouraged because it supports transparency, accountability and safer working practices. Early reporting enables appropriate support, effective risk management and, where necessary, protective action to be taken.
Self-reporting promotes safeguarding and safer practice by:

• enabling individuals to seek support with potentially difficult situations and address concerns at the earliest opportunity;
• demonstrating awareness of expected professional standards and reflection on personal actions and how they may be perceived;
• helping to identify and manage potential risks before they escalate; and,
• contributing to a culture where everyone working on behalf of Bright World aspires to the highest standards of conduct and behaviour.

Expectations for Self-Reporting

All employees, Directors, Local Coordinators, host families, volunteers, contractors and any individual acting on behalf of Bright World must inform the Designated Safeguarding Lead (DSL), or an appropriate Director, without delay if they:
• are arrested, charged or convicted of any criminal offence;
• become subject to a police investigation;
• become subject to child protection enquiries;
• become the subject of safeguarding allegations;
• receive a caution, reprimand or warning where relevant;
• become aware of circumstances that may affect their suitability to work with children;
• experience significant personal circumstances that could impact upon their judgement, wellbeing or ability to safeguard children safely.

This applies to circumstances occurring both inside and outside of work where they may affect an individual’s suitability to work with children.

Failure to disclose relevant information may itself be considered a safeguarding concern and may result in further action being taken.
Managing Self-Reports

Where an individual self-reports a concern, Bright World will respond fairly, proportionately and in accordance with safeguarding procedures.

The person reporting the concern will normally be given the opportunity to provide a full account of the circumstances. The DSL will consider the information provided, assess any safeguarding implications and determine whether any further action, advice, support, monitoring or referral is required.

Bright World recognises that individuals who self-report demonstrate awareness of safeguarding responsibilities and a willingness to maintain safe professional practice. Self-reporting will be managed sensitively while ensuring that the welfare of children remains the overriding priority.

How to receive a disclosure from a child or young person

See our “Good Recording Practice Guide”: here

Sharing Safeguarding Information

Effective safeguarding depends upon the timely, lawful and proportionate sharing of information.

Bright World Guardianships recognises that no single organisation can safeguard children in isolation. Appropriate information sharing with those who need to know is essential to identify risks, respond to concerns and protect the welfare of children.

There will be occasions when safeguarding information needs to be shared with other parties in order to safeguard a child. Information may be shared with Bright World staff, Local Coordinators, host families, the Designated Safeguarding Lead (DSL) of the school attended by the student, children’s social care, safeguarding partners, statutory agencies, and other organisations or practitioners where required.

Information will only be shared with those who have a legitimate safeguarding need to know and will always be handled in accordance with Bright World’s Data Protection Policy and applicable data protection legislation.

Principles of Information Sharing

When sharing safeguarding information, Bright World will ensure that information is:
• necessary;
• proportionate;
• relevant;
• accurate;
• timely; and,
• shared securely.

Decisions about sharing information will always consider the safety and welfare of the child. The DSL will record the reasons for significant information-sharing decisions, including where information is not shared.

All staff, host families, Local Coordinators and volunteers must understand that they have a professional responsibility to share information where this is necessary to safeguard or promote the welfare of a child.

Data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Data (Use and Access) Act 2025, does not prevent the lawful sharing of information where doing so is necessary to protect a child from harm.

Confidentiality and Disclosures

Staff, host families and volunteers must never promise a child that information shared with them will be kept secret if that information may place the child or another person at risk.

Children should be reassured that information will only be shared with people who need to know in order to help keep them safe.
Safeguarding information is personal and confidential. The DSL and DDSL will only share information about a child with Bright World staff, host families, school DSLs, agencies or other professionals on a need-to-know basis and where there is a safeguarding purpose.

Sharing Information Without Consent

Bright World will normally seek appropriate consent before sharing personal information.
However, consent will not be required where:
• a child may be at risk of significant harm;
• seeking consent may increase the risk to the child;
• seeking consent may compromise a police or safeguarding investigation; or,
• there is another lawful basis for sharing information.

Where information is shared without consent, the DSL will record the reasons for this decision.

The DSL will normally seek parent or carer consent before making a referral to Children’s Social Care unless doing so may place the child at greater risk of harm, compromise an investigation or delay necessary safeguarding action.

Working with Schools and Other Agencies

Bright World works closely with schools and safeguarding partners to support children’s safety and wellbeing.
Where appropriate, safeguarding information may be shared with:
• school Designated Safeguarding Leads;
• pastoral and boarding teams;
• children’s social care;
• police;
• Local Authority Designated Officers (LADO);
• healthcare professionals;
• Local Safeguarding Partnerships; and,
• other relevant safeguarding professionals.

Information shared will always be limited to what is necessary to safeguard or support the child.

Bright World will be proactive in sharing information at an early stage where concerns are emerging, where risks are increasing, or where a child is already known to children’s social care.

Recording Information Sharing Decisions

Where safeguarding information is shared, Bright World will record, where appropriate:
• what information was shared;
• who it was shared with;
• why it was shared;
• when it was shared;
• the reasons for the decision; and,
• any follow-up action required.

Accurate recording supports accountability, transparency and effective safeguarding practice.

The Role of the Bright World DSL and DDSL

The DSL will take lead responsibility for safeguarding and child protection (including online safety). This is explicit in the role holder’s job description. This person has the appropriate status and authority within the guardianship organisation to carry out the duties of the post.

Bright World Guardianships will ensure that appropriate safeguarding cover is available whenever the DSL is unavailable. Staff, host families and partner schools will always have access to a trained DSL or DDSL for safeguarding advice and decision-making. Appropriate arrangements, including shared safeguarding communication systems where necessary, will be maintained to ensure continuity.

The DSL is responsible for promoting a strong safeguarding culture across Bright World Education and Bright World Guardianships and ensuring that safeguarding arrangements remain effective across both services.

The designated safeguarding lead, Robbie Piper, is expected to:

	refer cases of suspected abuse to the local authority children’s social care as required;
	support staff and host families who make referrals to local authority children’s social care;
	refer cases to the Channel programme where there is a radicalisation concern as required – Robbie Piper is also the Prevent Lead
	refer cases where a crime may have been committed to the Police as required.
	act as a point of contact with the three safeguarding partners;
	liaise with fellow DSL Lana and DDSLs Su Warren and James Foster to inform them of issues;
	liaise with staff and host families on matters of safety and safeguarding (including online and digital safety) and when deciding whether to make a referral by liaising with relevant agencies;
	act as a source of support, advice and expertise for all staff and host families;
	understand the importance of information sharing, both within Bright World Guardianships, and with safeguarding partners, the DSL for the school the student attends, other agencies, organisations and practitioners;
	ensure that information sharing decisions are timely, proportionate, accurately recorded and made in accordance with statutory guidance;
	encourage a culture of listening to students and taking account of their wishes and feelings, among all staff, host families and volunteers and in any measures Bright World Guardianships may put in place to protect them;
	understand the difficulties that students may have in approaching staff and host families about their circumstances and consider how to build trusted relationships which facilitate communication;
	ensure the Bright World Guardianships Safeguarding and Child Protection Policy is known, understood and used appropriately;
	ensure this Safeguarding and Child Protection Policy is reviewed annually (as a minimum), with procedures and implementation updated where required;
	ensure the child protection policy is available for all relevant parties in manuals and on the Bright World website.

The DSL will also:

	provide safeguarding advice and guidance to Local Coordinators, volunteers, contractors and host families;
	maintain oversight of safeguarding concerns arising from school placements, host family arrangements, welfare visits and student support;
	ensure safeguarding concerns are assessed appropriately and that referrals, where required, are made promptly;
	liaise with school Designated Safeguarding Leads regarding safeguarding concerns involving Bright World students;
	oversee safeguarding plans and ensure appropriate follow-up action is taken;
	identify safeguarding themes and learning opportunities through regular review of concerns and records;
	ensure safeguarding training requirements are monitored across the organisation.

Record keeping

Bright World Guardianships will keep full records of any safeguarding concern reported to them. All concerns, discussions and decisions made, and the reasons for those decisions, will be recorded in writing. Safeguarding records will be stored securely and separately to the general student files. These will be stored confidentially by the DSL as a password protected file. Only the DSL and DDSL will have access to these files.

Safeguarding records will be managed in accordance with Bright World’s Data Protection Policy, records retention procedures and applicable data protection legislation.

Records will be factual, objective, timely and clearly distinguish between fact, professional opinion and third-party information where appropriate. These will include all concerns about a student even if there is no need to make an immediate referral and record the rationale for decisions made and action taken.

In summary, records should include:
• a clear and comprehensive summary of the concern;
• details of how the concern was followed up and resolved;
• a note of any action taken, decisions reached and the outcome.

Where appropriate, safeguarding records will also include:
• the views and wishes of the child;
• advice received from external agencies;
• decisions regarding information sharing;
• reasons for decisions made.

Copies of any correspondence or notes from conversations with the LSP, school DSL or other external agency will be included in the file.

Bright World Guardianships will ensure that the indication of the existence of the additional child protection file is marked on the student file record. Information will only be shared on a need-to-know basis in order to safeguard the student.

If in doubt about recording requirements, staff or host families should discuss with the DSL (or DDSL).

Training and updates

Bright World Guardianships is committed to ensuring that everyone working on behalf of Bright World has the knowledge, skills and confidence to safeguard children effectively.

Safeguarding training is an ongoing process and forms an integral part of Bright World’s safeguarding culture. Training enables staff, host families, volunteers and other individuals working on behalf of Bright World to recognise concerns, respond appropriately and understand their individual safeguarding responsibilities.

Bright World Guardianships will ensure that all head office staff, Local Coordinators and relevant individuals receive safeguarding training and regular updates appropriate to their roles.

Training and updates will reflect:
• changes in legislation;
• statutory guidance;
• local safeguarding priorities;
• emerging safeguarding risks;
• organisational learning from safeguarding practice.

A formal record of all safeguarding training will be maintained.

DSL and DDSL

The DSL and DDSL will attend suitable safeguarding training appropriate to their responsibilities, as approved or provided by Local Safeguarding Partners (LSP), AEGIS, the NSPCC or another recognised safeguarding training provider.
This training will be renewed in accordance with statutory guidance and supplemented by regular safeguarding updates, professional reading and continuing professional development.
The DSL and DDSL will ensure that their safeguarding knowledge remains current and that they are aware of changes to legislation, guidance and emerging safeguarding risks.

Other staff and host families

All other members of staff, volunteers and host families will receive appropriate safeguarding training relevant to their role and level of contact with children.

This will include safeguarding awareness training at an appropriate basic awareness level (previously referred to as Level 1), which will be refreshed at least every three years.

Training may be completed online or in person.

Members of staff, volunteers and host families who have completed suitable safeguarding training with another recognised provider that remains current will not normally be required to repeat the training. However, the DSL will ensure that the individual understands Bright World Guardianships’ own safeguarding procedures, reporting arrangements and expectations.

Induction

All new staff and relevant individuals working on behalf of Bright World Guardianships will receive safeguarding information as part of their induction.

This will include:
• Bright World Guardianships’ Safeguarding and Child Protection Policy;
• relevant Codes of Conduct;
• safeguarding reporting procedures;
• the identity and contact details of the DSL and DDSLs;
• whistleblowing procedures;
• professional boundaries;
• online safety responsibilities;
• safeguarding expectations relevant to their role.
Individuals should understand safeguarding procedures before undertaking duties involving children.

Safeguarding Updates

All staff and host families will receive regular safeguarding updates at least once per year.
These will normally be delivered:
• in June at the annual conference for Head Office staff and Local Coordinators; and
• through termly newsletters and communications for Host Families.

Updates will reflect changes in:
• legislation;
• statutory guidance;
• local safeguarding priorities;
• emerging safeguarding risks;
• online safety;
• artificial intelligence and emerging technologies;
• child-on-child abuse;
• information sharing;
• exploitation;
• mental health;
• other relevant safeguarding themes.

Additional safeguarding updates may also be provided following safeguarding incidents, organisational learning, changes to procedures or emerging risks.

This policy will be reviewed annually with Head Office staff and safeguarding updates will be delivered by one of the DSLs or another appropriately trained safeguarding professional.

Specialist Safeguarding Training

Where appropriate, Bright World Guardianships may provide additional safeguarding training on specific areas of risk, including:
• child sexual exploitation;
• child criminal exploitation;
• county lines;
• Prevent and radicalisation;
• online safety;
• artificial intelligence and emerging technologies;
• mental health;
• self-harm and suicide awareness;
• domestic abuse;
• honour-based abuse;
• forced marriage;
• female genital mutilation (FGM);
• child-on-child abuse;
• trauma-informed practice;
• professional curiosity;
• safer recruitment.

Bright World recognises that safeguarding risks continually evolve and training arrangements will be reviewed accordingly.

Host Family Training

Host families receive safeguarding guidance relevant to their role before accommodating students.
This includes guidance on:
• recognising abuse and neglect;
• responding to safeguarding concerns;
• reporting procedures;
• professional boundaries;
• online safety;
• missing student procedures;
• mental health awareness;
• child-on-child abuse;
• maintaining safe family environments.
Host families are expected to remain familiar with Bright World Guardianships’ safeguarding expectations throughout their registration.

Local Coordinator Training

Local Coordinators receive safeguarding training appropriate to their responsibilities.
Training includes:
• recognising safeguarding concerns during welfare visits;
• responding to disclosures;
• reporting procedures;
• record keeping;
• professional curiosity;
• host family safeguarding;
• maintaining professional boundaries;
• safeguarding during emergency situations.
Local Coordinators are expected to participate in safeguarding refresher training and updates throughout their appointment.

Recording Training

Bright World Guardianships maintains records of safeguarding training undertaken by staff and relevant individuals.
Training records will include:
• dates completed;
• training provider;
• subject matter covered;
• refresher requirements;
• attendance at safeguarding updates where appropriate.
The DSL monitors safeguarding training compliance and identifies where additional training or updates are required.

Whistleblowing

Bright World Guardianships has a separate policy that outlines Whistleblowing . This protect staff members who report colleagues they believe are doing something wrong or illegal, or who are neglecting their duties.

Bright World recognises that effective safeguarding depends upon everyone working on its behalf feeling confident to raise concerns about unsafe practice, poor professional standards or organisational failures.

Whistleblowing procedures protect staff members and others who raise genuine concerns about colleagues, safeguarding practice or failures in responsibilities.

Concerns may include:
• unsafe practice;
• breaches of safeguarding procedures;
• inappropriate conduct towards children;
• failure to report safeguarding concerns;
• attempts to conceal safeguarding incidents;
• poor professional boundaries;
• unsafe recruitment practices;
• failures in organisational safeguarding systems.

Concerns should be reported immediately to the Designated Safeguarding Lead.
Where a concern relates to the DSL, it should be reported directly to a Director.
Bright World will not tolerate retaliation against anyone who raises a safeguarding concern in good faith.
Individuals making genuine disclosures will be treated fairly and with respect throughout the process.
Malicious or deliberately false allegations may be managed through appropriate disciplinary procedures.

Local Safeguarding Partnerships (LSPs)

Bright World Guardianships will work in partnership with Local Safeguarding Partnerships (LSPs), local authorities, schools and other safeguarding agencies in accordance with “Working Together to Safeguard Children”.

Bright World recognises that effective safeguarding requires strong multi-agency working and will cooperate with safeguarding partners where concerns arise regarding the safety or welfare of a child.

Partner schools have their own safeguarding policies and procedures, which include details of their relevant Local Safeguarding Partnership arrangements.

Bright World recognises that safeguarding concerns may arise in different geographical areas. Where a student is placed with a host family outside the school’s local authority area, Bright World will identify and liaise with the relevant Local Safeguarding Partnership and follow the appropriate local safeguarding procedures.

The website here provides links to safeguarding partnerships across the country.

Details of local safeguarding contacts can also be found on individual Local Authority websites.

The local LADO for West Sussex is available through West Sussex LADO Information

If Bright World experiences difficulties identifying the appropriate safeguarding contact, advice will be sought from the Police or relevant safeguarding agency.

Bright World Guardianships understands how to access local safeguarding arrangements, including:

• Local Safeguarding Partnerships;
• Children’s Social Care;
• Multi-Agency Safeguarding Hubs (MASH);
• locally agreed safeguarding procedures;
• non-emergency Police support via 101.

For emergency situations, Bright World will contact the relevant emergency services by calling 999.

This applies across England, Wales and Scotland.

In Scotland, for non-emergency safeguarding concerns, Bright World will contact the relevant local authority children’s social work team. Alternatively, advice may be sought from the Scottish Children’s Reporter Administration (SCRA): https://www.scra.gov.uk/contact-us/

In Wales, Bright World will contact the relevant local authority child protection services for non-emergency safeguarding concerns.
The website here provides a link to all of the LSPs in the country:

Liaison with parents, agents and partner schools

Bright World Guardianships recognises the importance of working openly and collaboratively with parents, legal guardians, agents and partner schools wherever appropriate.

• Bright World may need to share safeguarding information with the Designated Safeguarding Lead (DSL) of the school or college attended by the student. When a student moves school or college, safeguarding information may be shared with the DSL of the new school where this is necessary to safeguard the child.

• All schools and colleges have their own safeguarding and child protection policies, which outline their safeguarding procedures.

• Whilst Bright World will work openly with parents and legal guardians wherever possible, it reserves the right to contact Children’s Social Care, the Local Safeguarding Partnership or the Police without notifying parents where this is considered necessary to protect the child or where notification may increase risk or prejudice an investigation.

• Bright World will not usually share safeguarding information with education agents unless this is necessary to safeguard the student. Where information is shared, it will be provided on a need-to-know basis and with the expectation that confidentiality will be maintained.

The Bright World Emergency Procedure

Please refer to our Emergency Procedure and Policy.

Safer Recruitment
Bright World is committed to ensuring that all adults working with or on behalf of children are suitable for their roles and understand their safeguarding responsibilities.

Safer recruitment forms an essential part of Bright World’s safeguarding arrangements and applies, where appropriate, to:
• employees;
• Directors;
• Local Coordinators;
• volunteers;
• host families;
• contractors; and
• any other individuals acting on behalf of Bright World.

Bright World’s safer recruitment procedures are designed to ensure that appropriate checks and assessments are completed before individuals undertake roles involving children.

These procedures may include:
• identity verification;
• right to work checks where applicable;
• references;
• Disclosure and Barring Service (DBS) checks where required;
• suitability assessments;
• verification of relevant experience and qualifications;
• ongoing safeguarding suitability checks.

Bright World recognises that safeguarding does not end once recruitment checks have been completed. All individuals working on behalf of Bright World must continue to demonstrate appropriate professional standards, maintain boundaries and report any concerns that may affect their suitability to work with children.

Detailed safer recruitment procedures are contained within Bright World’s separate Safer Recruitment Policy, which should be read alongside this Safeguarding and Child Protection Policy.

Any safeguarding concerns identified during recruitment, vetting or ongoing suitability assessments will be referred immediately to the Designated Safeguarding Lead (DSL) and managed in accordance with this policy.

To see how we screen all staff and vounteers who work with Bright World, please refer to:

Safer Recruitment Policy for Staff
Safer Recruitment for Host Families Policy
Safer Recruitment for Taxi Companies Policy and Procedure

Monitoring, Quality Assurance and Continuous Improvement
Bright World is committed to regularly reviewing and strengthening its safeguarding arrangements to ensure that children receive the highest standards of protection, care and support.

Safeguarding is not a static process. It requires ongoing monitoring, evaluation and improvement to reflect changes in legislation, statutory guidance, emerging safeguarding risks and learning from practice.

The Directors and Designated Safeguarding Lead (DSL) have overall responsibility for ensuring that safeguarding arrangements remain effective across both Bright World Education and Bright World Guardianships.

Monitoring Safeguarding Practice
Bright World will monitor the effectiveness of its safeguarding arrangements by reviewing:

• safeguarding concerns and referrals;
• safeguarding records;
• welfare concerns and emerging themes;
• complaints involving safeguarding issues;
• allegations against adults;
• low-level concerns;
• host family safeguarding concerns;
• Local Coordinator reports;
• student feedback where appropriate;
• school feedback; and
• outcomes of safeguarding audits.

Monitoring enables Bright World to identify strengths, emerging risks and opportunities to improve safeguarding practice.

Quality Assurance
Bright World will undertake quality assurance activity to ensure safeguarding procedures are implemented effectively and consistently.

Quality assurance may include:

• safeguarding audits;
• record reviews;
• policy compliance checks;
• review of safeguarding training records;
• case reviews;
• management oversight;
• supervision discussions; and
• review of safeguarding incidents and emergency situations.

Findings from quality assurance activity will be used to strengthen safeguarding practice across the organisation.

Learning from Safeguarding Incidents
Bright World recognises that safeguarding incidents provide important opportunities for learning and improvement.

Following significant safeguarding concerns, the DSL and Directors will consider:

• whether safeguarding procedures operated effectively;
• whether communication was timely and appropriate;
• whether decisions made were proportionate and child-centred;
• whether additional training or support is required;
• whether policies or procedures require updating; and
• whether wider organisational learning can be identified.

Learning from safeguarding practice will be incorporated into future procedures wherever appropriate.

Student Voice
Bright World recognises that listening to children is fundamental to effective safeguarding.

Where appropriate, Bright World will seek feedback from students regarding:

• their sense of safety;
• the welfare support they receive;
• their experience of host family accommodation;
• communication with Bright World;
• their understanding of safeguarding information; and
• their confidence in raising concerns.

Student feedback will be used to improve safeguarding arrangements and ensure that children’s views remain central to Bright World’s practice.

Working with Schools and Partner Organisations
Bright World recognises the importance of partnership working in safeguarding children.

Feedback and learning from schools, parents, legal guardians, host families, Local Coordinators and safeguarding partners may be used to:

• improve safeguarding procedures;
• strengthen communication;
• identify training needs;
• enhance risk management; and
• improve the quality of services provided to children.

Bright World will continue to work collaboratively with organisations and professionals who share responsibility for safeguarding children’s welfare.

Complaints

Bright World Guardianships has a “Complaints Policy and Procedure”: as we recognise that there may be legitimate concerns from students, parents, agents host families or transfer companies about the service we provide. As a company we encourage these concerns being made known to Bright World staff so that they can be addressed in partnership with us, and we can continuously improve our service.

14.2 Bright World Guardianships has an internal complaints policy and procedure for staff who have complaints and these are detailed in the Staff Handbook.

14.3 If complainants are not satisfied with the outcome as decided by Bright World, they can contact AEGIS to report their concerns if they wish to do so (as detailed in the Complaints Policy). The relevant contact details are set out below:

Yasemin Wigglesworth
Executive Officer,
Association for the Education and Guardianship of International Students (AEGIS)
The Wheelhouse,
Bond’s Mill Estate,
Bristol Road,
Stonehouse,
Gloucestershire,
GL10 3RF
+44 (0) 1453 821293 www.aegisuk.net

We are committed to reviewing our policy and good practice annually.

This policy was last reviewed on: 03/08/2026

Signed: Robbie Piper, Designated Safeguarding Lead

The content in this manual is confidential and not to be shared with anyone outside the organisation. The contents are subject to copyright.