OWNER: DR L. M. FOLEY, DIRECTOR OF STUDENT SERVICES
APPROVED BY: EDUCATION AND STUDENT EXPERIENCE BOARD: 27 APRIL 2021
SENATE: 9 JUNE 2021
UPDATE TO APPENDIX 4 APPROVED BY ESEB CHAIR’S ACTION: 11 May 2022
REVIEW DATE: UNDER REVIEW
1. Purpose and Scope of the Policy
1.1. The University of Kent is committed to protecting children and adults at risk from harm, exploitation and abuse and to ensuring that all staff and students are aware of their responsibilities in relation to safeguarding, are alert to safeguarding concerns and know how to respond to those concerns.
1.2. This Policy sets out the University’s approach to safeguarding children and adults at risk, whenever they are on campus and/or engaged in University activities and the type of action that the University may take in response to safeguarding concerns and to provide support. In other instances, when children, whether accompanying staff, students or visitors are present on the University campus, they remain the responsibility of their parent, carer or legal guardian.
1.3. The University has a responsibility to keep children and adults at risk safe to take appropriate safeguarding action in relation to signs and symptoms of abuse or neglect, which could include:
- Physical
- Psychological or emotional
- Sexual
- Domestic Violence
- Financial
- Neglect
- Discriminatory
- Institutional
- Modern slavery
1.4. This Policy will be reviewed every two years or when there is a significant change in legislation.
1.5. This Policy does not apply to activities undertaken by the Kent Union or GKUnions, which has separate safeguarding policies and procedures, although it does apply to University activities that take place on the Students’ Union premises.
2.1. The University of Kent is committed to taking all reasonable steps to promote and safeguard the welfare of all children and adults at risk who are accessing the institution’s activities and services.
This includes:
- prospective students and apprentices
- current students and apprentices
- children and adults at risk engaging in University activities, including teaching, research and outreach activities
- children and adults at risk living in University accommodation
- external partners where University activities engage children or adults at risk e.g., volunteering and work experience.
2.2. Legal safeguarding duties apply to all children and young people under 18. Where this policy mentions young people, this should be read as being under the age of 18 years.
2.3. Legal safeguarding duties further apply to an adult at risk. An adult at risk is someone aged 18 years or over 'who is, or may be, in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themselves or unable to protect themselves against significant harm or exploitation.'
2.4. Safeguarding is everyone’s responsibility. All staff and students who have contact with children and adults at risk should be alert to the possibility that a child or adult at risk may experience abuse or neglect. All concerns should be raised using the procedure set out in this document, but it is not the responsibility of staff or students to investigate or establish if abuse or neglect has taken place.
2.5. Safeguarding referrals to the relevant statutory authority will be proportionate and made on the basis of consideration of the identified risks, including consideration of the impact of the referral on those involved.
2.6. Making safeguarding personal means it should be person-led and outcomes-focused. It engages the person in a conversation about how best to respond to their safeguarding situation in a way that enhances involvement, choice and control as well as improving quality of life, wellbeing and safety. Adults with capacity (as defined by the Mental Health Capacity Act 2005) have the right to self-determination, including the right to make unwise decisions and/or not to engage with support.
2.7. When dealing with safeguarding concerns, confidentiality should never be guaranteed as information may need to be shared. However, confidential information will only be shared minimally or as required, where this is considered to be necessary and will only be shared with relevant third parties on a need to know basis.
2.8. When safeguarding children, the University’s approach will be informed by Working Together to Safeguard Children 2018 (including the amendments introduced in 2020), which is the statutory guidance on inter-agency working to safeguard and promote the welfare of children. In particular, it will act to promote the welfare of children and protect them from harm.
2.9. The University will follow the six key principles that underpin adult safeguarding, as set out in the Care Act 2014;
Empowerment: People are supported and encouraged to make their own decisions and informed consent. “I am asked what I want as the outcomes from the safeguarding process and these directly inform what happens.”
Prevention: It is better to take action before harm occurs. “I receive clear and simple information about what abuse is, how to recognise the signs and what I can do to seek help.”
Proportionality: The least intrusive response appropriate to the risk presented. “I am sure that the professionals will work in my best interest, as I see them, and they will only get involved as much as needed.”
Protection: To support and protect those in greatest need. “I get help and support to report abuse and neglect. I get help so that I am able to take part in the safeguarding process to the extent to which I want.”
Partnership: Working collaboratively with other agencies. 4 “I know that staff treat any personal and sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together and with me to get the best result for me.”
Accountability: To be transparent about, and responsible for, our safeguarding practices. “I understand the role of everyone involved in my life and so do they.”
3.
University Safeguarding Structure
3.1 The implementation of the policy will be overseen by the Deputy Vice-Chancellor for Education and Student Experience, who will ensure that the University of Kent is meeting its safeguarding responsibilities.
3.2 The University has identified clear leadership and lines of accountability to ensure the full implementation of this policy across the University. The University has designated a Senior Safeguarding Officer (SSO), two Deputy Safeguarding Officers (DSO) and Local Safeguarding Officers (LSOs) within Divisions and Directorates. (Contact details of the SSO and DSOs are available in Appendix 3, together with a link to the list of Local Safeguarding Officers).
3.3 The Senior Safeguarding Officer is the Director of Student Services. This individual is the University’s strategic lead for safeguarding and will ensure that the University’s policies, procedures, systems and general activities comply with current legislation and the University of Kent Safeguarding Policy. Their key responsibilities are to develop and implement policy and procedure to safeguard children and adults at risk who are engaged in University-related activities and to ensure that the policy is regularly reviewed and update, when required, and to ensure consistent implementation of the procedure throughout the University.
3.4 The Deputy Safeguarding Officers are the Deputy Director of Student Services/Head of Student Support and Wellbeing and the Head of Student Mental Health and Wellbeing. They are the operational leads for safeguarding and the point of contact for communication with external agencies.
Their key responsibilities are:
- to determine if safeguarding concerns raised by someone in the University should be referred to an appropriate external authority.
- to refer concerns to social services, the police, or an alternative external agency, for the purposes of ensuring the safety of a child or adult at risk.
- to co-operate with other agencies to safeguard and promote the welfare of children and adults at risk.
- to establish and maintain links with relevant local authority departments and education institutions.
- to develop and maintain effective reporting and recording systems.
- to raise awareness through the dissemination of policies and information across the University.
- to oversee relevant training needs on safeguarding issues and procedures.
3.5 Local Safeguarding Officers (LSOs) should be appointed within Divisions and Directorates. Each Director of Division/Directorate should ensure that it has one LSO for each relevant service area. An LSO is a point of contact and support for staff and students to seek advice and raise concerns.
Their key responsibilities are:
- to provide first line support and advice on safeguarding issues.
- to highlight and promote best practice relating to safeguarding within their Division/Directorate.
- to oversee relevant training needs on safeguarding within their Division/Directorate, where required (e.g. student ambassadors).
- to establish and develop links with relevant organisations, where the Division/Directorate works with external partners, e.g., schools, colleges and apprenticeship student employers.
3.6 LSOs will be required to undertake training, as specified by the Senior Safeguarding Officer, prior to starting their role (e.g. from the NSPCC or alternative external provider. In addition, specific training will also be provided for activities which involve a high level of engagement with children (e.g., outreach activities). The SSO, DSO and LSOs are all responsible for ensuring that they undertake appropriate training, update knowledge and skills and keep up to date with relevant developments.
3.7 While the LSOs will manage the safeguarding casework, the Director of Division/Directorate will be responsible for ensuring that:
- sufficient resources are available to deliver safeguarding commitments within their Division/Directorate.
- LSOs engage with training and refresher training, as required.
- appropriate risk assessments are undertaken for relevant activities within their Division/Directorate.
- appropriate DBS checks are undertaken for relevant staff/students/volunteers within their Division/Directorate.
- any safeguarding concerns are reported promptly to the LSO
4.1 If staff become aware that a child or adult at risk is, or may be, experiencing abuse or neglect, they should promptly discuss this with their Local Safeguarding Officer (LSO) who will advise of next steps.
Situations that could trigger a safeguarding concern include:
- Witnessing harm/neglect.
- Disclosure of abuse or neglect, either current or historic.
- Reasonable suspicion (see Appendix 5 for definitions and signs of abuse and neglect).
4.2 Staff should not assume that someone else will take action. Staff should be aware that early sharing of information is often vital to enable an effective intervention that might keep a child or adult at risk safe.
4.3 In an emergency, or if a person is at risk of immediate harm, staff should contact emergency services or if on campus call Campus Security on 01227 823333.
4.4 Before taking further action, the LSO will first establish that the person identified as having a safeguarding concern meets the definition of being a child or adult at risk (see 2.2 and 2.3 above). If these definitions are not met but the person identified requires support, they will be referred to the appropriate internal or external services.
4.5 The LSO will, if required, complete a Safeguarding Report Form, a copy of which can be found in Appendix 2 or on the University website at: http://www.kent.ac.uk/studentservices/policies.html
4.6 The LSO will provide a copy of the completed Safeguarding Report Form to the Deputy Safeguarding Officer, who will keep a record centrally of all reported concerns and outcomes on a secure SharePoint site in line with the University’s Document Retention and Archiving Policy. It should be assumed that such records may later be used in formal/legal proceedings, if required.
4.7 If there are immediate concerns of risk of harm or abuse, the Local Safeguarding Officer or Deputy Safeguarding Officer must be notified verbally straight away, and a Safeguarding Report Form completed as soon as reasonably possible thereafter.
4.8 Any concerns about the behaviour by a member of staff against a child or an adult at risk should be reported directly to the DSO, via the LSO, if available, and referred to Human Resources.
4.9 Any safeguarding concerns involving the Senior Safeguarding Officer or Deputy Safeguarding Officer should be taken to the Deputy Vice Chancellor for Education and Student Experience. Safeguarding concerns involving the Deputy Vice-Chancellor for Education and Student Experience should be raised with the Vice-Chancellor. Safeguarding concerns involving the Vice Chancellor should be taken directly to the Chair of Council.
4.10 If the person identified as having a safeguarding concern meets the definition of being an adult at risk, the principles set out in 2.9 above will be followed.
4.11 The DSO will take appropriate steps which could include one or more of the following:
- to consult with relevant colleagues to ensure all relevant facts have been gathered.
- to liaise with appropriate external partners e.g., appropriate staff in a school within which outreach activities are happening, a placement provider, an apprenticeship student’s employer.
- to arrange for the individual to be given appropriate support via internal or external services.
- to make a referral to local social services.
- to contact the police.
4.12 It is important that accurate records are kept in relation to all safeguarding concerns that are raised. Where it is necessary to share information with other agencies in order to address the risk of harm, this will normally be done by the DSO or SSO, using the form in Appendix 2.
However, in an emergency situation, where risk is imminent, any
member of staff can call Campus Security or emergency services. All records will be
kept securely and retained only as long as necessary, in line with the University’s
retention schedule.
5.1 The Prevent Duty forms Section 26 of the Counter-Terrorism and Security Act (2015), which places a statutory duty on ‘specified authorities’, including Universities, to have ‘due regard to prevent people from being drawn into terrorism’.
5.2 The University regards its Prevent duty as part of its community safeguarding responsibilities to protect the welfare and safety of our students. The University provides pastoral and wellbeing support for students through the Divisions, College and Community Life Team and Student Service Teams.
5.3 Should any member of staff become concerned that a student is exhibiting extremist beliefs or behaviours and/or that they are at potential risk of exploitation by radicalisers they must share these concerns with their Local Safeguarding Officer or line manager.
5.4 In exceptional circumstances, for example, in cases where there might be a risk of immediate harm to an individual(s) or a third party, it would be open to Local Safeguarding Officer, Deputy Safeguarding Officer or a senior member of the University Campus Security staff, to consult directly with the Prevent Officer and/or Policy Adviser to the Vice-Chancellor about the need for direct contact with other external authorities (see Appendix 3 for Prevent contact details).
6.1. DBS checks will be carried out for appropriate members of University staff, in line with the University’s DBS policy.
6.2. Risk assessments will be carried out for organised activities on campus to ensure the safety of children and adults at risk.
6.3. Participation in research will be conducted in accordance with approval from relevant ethics committee.
6.4. Where relevant, written consent will be obtained from parents/carers (or another adult acting in loco parentis) with regards to activities involving children and young people, in particular:
- presence of children on campus without a responsible adult
- taking and publishing images of children