Safeguarding Procedures: Identifying, Reporting, and Managing Concerns

The Provider has established clear procedures for identifying safeguarding issues, reporting concerns, and managing incidents. All staff and employers must follow these procedures whenever a potential safeguarding matter arises. We operate a “zero hesitation” approach – if anyone has a concern, we act on it.

Recognising Signs of Abuse or Harm

Staff and employers receive training on the categories and signs of abuse, exploitation, or neglect, as applicable to both children and adults. While our apprentices are adults, they may still be vulnerable to many forms of harm, including:

• Physical abuse: Infliction of pain or injury, e.g. hitting, shaking, improper restraint. Signs can include unexplained bruises, burns or fractures, or the apprentice appearing fearful.

• Emotional/Psychological abuse: Acts that cause mental anguish or isolation, such as threats, humiliation, harassment, or bullying (including workplace bullying or cyberbullying). Signs include low self-esteem, anxiety, withdrawal, or sudden changes in confidence or mood.

• Sexual abuse or harassment: Any non-consensual sexual act or attempt, sexual assault, or workplace sexual harassment. Indicators can be trauma, inexplicable behavior changes, or the apprentice reporting inappropriate comments or touches. (Even as adults, apprentices can be victims of grooming or coercion, including potentially by those in authority or domestic partners.)

• Neglect or self-neglect: Neglect in an adult context might involve an employer or living situation failing to meet basic needs, or an individual neglecting their own health due to various factors. Signs include poor appearance, fatigue, untreated medical issues, or confusion. Apprentices could also struggle to care for themselves if under extreme stress or mental illness.

• Financial abuse: Particularly relevant for vulnerable adults – exploitation of finances, fraud, or coercion around money. Signs might be unexplained financial difficulty, someone exerting unusual control over the apprentice’s finances or benefits.

• Discriminatory abuse: Harassment or unfair treatment due to race, gender, disability, or other characteristics, which can severely impact mental well-being.

• Domestic abuse: Some apprentices may be in abusive relationships at home. This can include physical, emotional, or sexual harm by a partner or family member, or coercive control. Staff should be alert to signs like frequent injuries with dubious explanations, or the apprentice appearing extremely controlled or anxious about pleasing someone in their personal life.

• Exploitation: This could include modern slavery (being forced into labor or servitude) or criminal exploitation. While less common, an apprentice could be coerced by someone outside work into illicit activities (for example, involvement in crime or “county lines” drug trafficking). Signs include unexplained new possessions or money, secretive behavior, or associates causing concern.

• Mental Health Concerns: KCSIE (2023) highlights that mental health issues can be an indicator or outcome of abuse. If an apprentice shows signs of severe depression, self-harm, suicidal thoughts, or eating disorders, we treat this as a safeguarding concern to ensure they get help. Staff are trained not to make clinical diagnoses but to recognize when behavior or comments suggest the apprentice’s mental health is at risk.

• Radicalisation and Extremism: As part of the Prevent duty, staff and employers watch for signs that an apprentice may be becoming drawn into extremist ideology or terrorism. This might manifest as expressing extremist views or sympathy for extremist causes, sudden disrespect for other religions or cultures, isolation along with fixation on certain (possibly extremist) websites or groups, or even openly indicating intent to harm for an ideological cause. Changes in language or dress can accompany radicalisation, but these signs must be interpreted carefully and in context. (More detail in the Prevent section below.)

• Online Risks: These cut across several categories. Apprentices might be exposed to online grooming, sexual exploitation (e.g. being persuaded to share indecent images), cyberbullying by peers, or extremist propaganda. They may also inadvertently or deliberately access inappropriate or illegal content. Staff should be attentive to changes in an apprentice’s online behavior or distress caused by online interactions.

Everyone must remember that abuse or harm can occur in any setting – at home, in the workplace, among peers, or online – and that adults may be reluctant to disclose due to shame or fear. We therefore encourage a climate of trust and vigilance.

Reporting a Safeguarding Concern (Referral Process)

When a safeguarding concern is identified, the following reporting procedure must be followed by Provider staff and, where relevant, employers or apprentices themselves:

1. Immediate Safety First: If the situation is an emergency – for example, an apprentice is in immediate danger or needs urgent medical care – call the appropriate emergency service without delay (999 for police or ambulance). Take any feasible immediate action to safeguard the individual (this might include administering first aid or, if trained and safe to do so, de-escalating a violent situation). Then, inform the DSL as soon as possible about the incident.

2. Inform the DSL: As soon as practicable, report the concern to the Designated Safeguarding Lead (or Deputy DSL). This should be done on the same working day and preferably within hours of noticing the concern. During office hours, this may be a direct conversation or phone call to ensure quick action. A written record (see next step) should follow. If the DSL is not available (e.g. out of hours), and the concern cannot wait, staff should contact the Deputy DSL or a senior manager. The report should include all relevant details known: who is involved, what has been observed or disclosed, when and where it occurred, etc.

3. Record the Details: The person raising the concern must complete a Safeguarding Incident Report as soon as possible to document the concern in writing. IBIS Consultancy provides a standardised form (or secure electronic system) for this purpose. The report should record factual information and observations in the reporter’s own words, including the date, time, persons present, and exactly what the apprentice said (if a disclosure) or what signs were seen. It should distinguish facts from personal judgments. If the apprentice has disclosed something, use their quotations as much as possible. This record is critical for any future investigation. The report must be marked confidential and submitted only to the DSL (and kept securely).

4. Preserve Evidence (if any): In cases of physical or sexual abuse, there may be evidence (e.g. emails, text messages, screenshots of social media, photographs of injuries). The reporter should secure any such evidence if possible and safe – for example, saving messages or not deleting content – and hand it to the DSL. In cases of alleged online abuse or radicalisation, do not immediately remove or delete digital evidence before the DSL reviews it, unless instructed by police (to avoid inadvertently destroying proof).

5. Respect Confidentiality: Apart from notifying the DSL and possibly a line manager on a need-to-know basis, the reporter should not discuss the matter with others. This is to protect the privacy and integrity of any ensuing investigation. They should certainly not contact the alleged perpetrator of abuse (if there is one) or attempt to mediate themselves.

6. DSL Assessment: Upon receiving a report, the DSL will acknowledge receipt and then promptly assess the information. Using their training and any consultation needed (e.g. checking guidelines or talking to safeguarding partners), the DSL will determine the next steps. This may involve gathering a bit more context (for example, speaking to the reporting person for clarification, or discreetly checking records for any prior related issues). The DSL will always take concerns seriously – even if they prove unfounded, it is important to respond correctly.

7. External Referral if Required: If the DSL judges that the apprentice is at risk of significant harm or in need of specialist support, they will refer to the appropriate external agency. This could mean contacting:

   • Local Authority Adult Safeguarding Team: for cases of abuse or neglect involving an adult apprentice who has care and support needs (making what is often called a Section 42 enquiry referral under the Care Act). We will work with the local Safeguarding Adults Board procedures.

   • Local Authority Children’s Social Care: if the concern involves a person under 18 (for example, if an apprentice discloses current child abuse of a sibling or a 17-year-old apprentice is identified at risk), a referral under child protection procedures will be made.

   • Police: if a crime is suspected (e.g. sexual assault, physical assault, exploitation, hate crime, extremist activity). The DSL may contact the police directly or via social services depending on the urgency.

   • Channel Programme/Prevent Leads: if the issue is radicalisation, the DSL will follow Prevent referral procedures. Typically, this involves contacting the regional Prevent Coordinator or local Channel Panel. (As recommended, the DSL has already “found out [the] Prevent referral process in [our] local authority”and established contacts.)

   • Medical or Mental Health Services: if an apprentice is in urgent need of medical or psychiatric intervention (e.g. expressing suicidal intent), the DSL might facilitate immediate medical attention or contact community mental health crisis teams.

   • Other support services: in cases not requiring statutory intervention, the DSL might suggest or help arrange counseling, mentoring, or other support (for instance, referring to an Employee Assistance Programme or external charities like domestic abuse helplines).

   In making referrals, the DSL will provide the agency with all necessary information and will follow up in writing (using the required referral forms). We acknowledge our duty to refer promptly – delays can put individuals at further risk, so referrals typically occur within 24 hours of the initial report (and sooner for urgent cases).

   Documentation: The DSL will keep a record of all communications regarding the referral, including noting the agency contacted, the date/time, and the advice or decisions given.

8. Internal Follow-Up: If the DSL decides an external referral is not required (for example, the issue can be managed internally or does not meet external thresholds), appropriate action will still be taken internally. This might include providing pastoral support to the apprentice, addressing a minor misconduct issue via HR, or monitoring the situation closely. The rationale for not referring will be recorded. If in doubt, the DSL will err on the side of consulting with authorities, even informally.

9. Feedback to Reporter: The DSL (or Deputy) will inform the staff member or employer who reported the concern of the general outcome or next steps, as appropriate. They may say, for instance, that “the concern has been referred to the local safeguarding team” or “we are handling it internally with support measures.” They will not usually share detailed confidential information, but enough to assure the reporter that the concern is being addressed. If the reporter does not receive any acknowledgment, they should follow up, in case the report wasn’t received.

10. Ongoing Case Management: After referral, the DSL (and deputies) remain involved. They will attend any strategy meetings or contribute to multi-agency plans as needed. They also ensure the apprentice is supported during this process – e.g. arranging for a trusted staff member to check in on them, or adjusting their training schedule if needed for recovery. The DSL will continue to update the case file with any developments and outcomes (for example, the result of a police investigation, or improvement in the apprentice’s situation). We aim to “help learners reduce their risk of harm by securing the support they need”, so we will track that the needed support is indeed in place.

11. Resolution and Review: Once a safeguarding case is resolved or closed, the DSL will review the circumstances to see if any lessons can be learned or if any changes to policy are required. They will also ensure that any commitments (like ongoing counseling or reasonable adjustments at work) are maintained for the apprentice’s benefit. If the situation does not improve or new information comes to light, the DSL will re-evaluate and possibly re-refer to get additional help.

Throughout this process, the apprentice’s wishes and views will be taken into account wherever possible. Especially with adults, we seek consent to share information and involve them in decision-making. However, there are situations where we may act without consent (for example, if others are at risk, or the apprentice lacks capacity, or in Prevent cases where a serious crime could be prevented). In all cases, the DSL will adhere to information-sharing principles: “Fears about sharing information must not be allowed to stand in the way of safeguarding”.

All steps taken will be in line with the detailed flowcharts and guidance appended to this policy (Appendix A: Reporting Flowchart; Appendix B: Key Contact Information for local agencies).

Responding to Disclosures

If an apprentice discloses abuse or a serious issue to a staff member or employer, that adult should handle it with care and in line with training:

• Listen calmly and actively: Let the apprentice speak at their own pace. Don’t interrupt or probe with lots of questions (especially leading questions). Use open prompts like “Can you tell me more about that?” rather than “Why did you…?” or suggesting answers. This initial conversation is not an investigation but a listening exercise.

• Reassure the apprentice: They should be thanked for sharing and assured that they were right to tell someone. Confirm that you take what they say seriously. Avoid any expression of shock or disbelief that might shut them down.

• No promises of secrecy: Make clear (if not already) that you will need to pass this information on to the DSL, and possibly to professionals who can help, but it will only be shared with people who absolutely need to know. Usually say, “I will do my best to get you help and I will only tell the people who need to be involved.” This manages expectations that others (like the DSL or police) may become involved.

• Record as verbatim as possible: As soon as you can, write down what was said, using the apprentice’s own words. If the conversation is happening in person, you might jot brief notes if appropriate, but do not delay the empathy and listening in that moment. Afterward, complete the report form thoroughly.

• Ensure immediate safety: Depending on what is disclosed, the apprentice may need protection right away (for example, if they just fled an abuser or if they have injuries). Make sure they are not in danger at that moment; this might involve keeping them company in a safe place while calling for help.

• Explain next steps: Before the apprentice leaves, gently explain what will happen next (e.g. “I’m going to talk to our Safeguarding Lead, [Name], who knows how to get you some help. They might want to speak with you too. We may need to contact someone outside who has the expertise to help in this situation. I will stay with you if you want when we talk to them.”). This transparency helps reduce anxiety.

The staff member should then follow the formal reporting procedure (inform DSL, etc.) as above. Staff and apprentices are encouraged to understand that reporting can be life-saving and is done to protect them and others from harm.

Whistleblowing (Reporting Concerns about the Organisation or Staff)

Whistleblowing is the mechanism by which staff can voice concerns, in good faith, about improper conduct or failures in the organisation’s safeguarding practices outside of the normal line management structure. While we encourage an open culture where issues can usually be raised with managers or the DSL, we recognise that there may be circumstances where a staff member feels unable to report concerns internally – for example, if the concern is about a colleague or senior manager’s behaviour, or if they believe a reported issue isn’t being addressed.

Key points of our whistleblowing approach:

• Covered Concerns: Whistleblowing could include reporting that a staff member or volunteer is behaving inappropriately towards learners (e.g. grooming, harassment), that there is a culture of ignoring safeguarding issues, or that leadership is not properly responding to known problems. It also covers any suspicion of illegal or dangerous activity by the organisation that affects apprentices or children.

• Internal Route: Staff (or volunteers) should ideally first raise the matter with a senior manager or director who is not implicated in the concern. For example, if the issue is about the DSL or a failure at that level, they might go to the CEO or a Board member responsible for safeguarding. The Provider has a Whistleblowing Policy that names specific individuals (like the HR Director or a Trustee) whom staff can contact confidentially. These individuals are required to investigate and respond to whistleblowers.

• External Route: If a staff member feels they cannot raise it internally, or they have done so and nothing was done, they have the right to contact external authorities directly. They can whistleblow to bodies such as Ofsted (which has a whistleblowing hotline for education safeguarding concerns), or the NSPCC Whistleblowing Advice Line (an independent helpline at 0800 028 0285 for professionals to get advice or report concerns about how an organisation is dealing with safeguarding). The NSPCC line is highlighted in KCSIE as a resource for those who feel unable to report internally. Staff can also approach the Local Authority Designated Officer (LADO) in children’s services if the concern relates to a person in a position of trust with under-18s, or the Local Safeguarding Adults Board if it concerns adult safeguarding practices.

• No Retaliation: IBIS Consultancy assures all staff that they can raise concerns without fear of reprisal. We will not tolerate any harassment or victimisation of a whistleblower. Any attempt to retaliate against someone for speaking up will itself be treated as a serious disciplinary matter. Whistleblowers can remain anonymous if they wish, though it may hinder investigation if we cannot ask follow-up questions; however, all disclosures will be handled sensitively and confidentially as far as possible.

• Acting in Good Faith: Staff should whistleblow only in the interest of learner safety and not for malicious reasons. Provided they act in good faith (even if the concern later proves unfounded), they will be supported and protected. Abuse of the whistleblowing process (making knowingly false allegations) is not acceptable.

We encourage a problem-solving culture where most issues can be resolved through open dialogue. However, whistleblowing is an important safety net. It ensures accountability at the highest levels. If an incident or pattern emerges indicating that safeguarding is not being taken seriously by the organisation, we expect and want staff to speak out. This helps uphold the ethical standards and legal compliance that apprentices deserve.

Introduction

IBIS Consultancy is committed to the highest standards of openness, probity, and accountability. An important aspect of accountability and transparency is a mechanism to enable staff and other members of IBIS Consultancy to voice concerns in a responsible and effective manner. Where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of team management (although in relatively minor instances the Chief Executive Officer (CEO) would be the appropriate person to be told).

In relation to DFE funded Bootcamps and Apprenticeships the reporting mechanism is provided at the end of the Policy.

The Public Interest Disclosure Act, which came into effect in 1999, gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. IBIS Consultancy has endorsed the provisions set out below so as to ensure that no members of staff should feel at a disadvantage in raising legitimate concerns. It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial, or business decisions taken by IBIS Consultancy, nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures. Once the “whistleblowing” procedures are in place, it is reasonable to expect staff to use them rather than air their complaints outside SST.

Scope

This policy is designed to enable employees to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include:

• Financial malpractice, impropriety or fraud
• Failure to comply with a legal obligation or Statutes
• Dangers to Health & Safety or the environment
• Criminal activity
• Improper conduct or unethical behaviour
• Attempts to conceal any of these

Legislation, Guidance and Best Practice

The titles below indicate the legal framework that informs this policy. Each title is the most up to date version of each document to include ongoing revisions and outcomes of consultations. Each title is a hyperlink, which will take you straight to the document if you are viewing this policy electronically.

• Whistleblowing for employees
• The Whistleblowing Charity – Protect (speak up, stop harm)
• Contact Department for Education – webform – Complaints
• The National Society for the Protection of Children (NSPCC). If you are a professional with concerns about how child protection issues are being handled in your organisation, or another organisation, you should contact the national child abuse whistleblowing advice line on 0800 028 0285 or help@nspcc.org.uk.
• Keeping children safe in Education 2022

In the discharge of its functions, and in implementing this policy and procedure, IBIS Consultancy will remain mindful of its duty of care and other legal obligations. Such as, those it owes under the Health and Safety at Work Act 1974, the Data Protection Act 2018, the Safeguarding Vulnerable Groups Act 2006, Equality Act 2010, the Protection of Freedoms Act 2012, the Counter Terrorism and Security Act 2015.

Related policies

IBIS Consultancy will keep its policies and procedures on children, young people, and adults at risk at risk under review to take account of any new Government legislation, regulations, or best practice documents. This will ensure staff are kept fully up to date with their responsibilities and duties regarding the safety wellbeing of children, young people, and adults at risk.

The policy should be read alongside our policies and procedures on:

• Safeguarding, Child Protection and Prevent Policy and Procedure
• Recruitment and Selection Policy and Procedure
• Equality and Diversity Policy
• Health, Safety and Wellbeing
• General Data Protection Regulations (GDPR) Policy

Designated safeguarding team

• Designated Safeguarding Lead 
  
  • +44 1622 37 0617
  • office@ibisconsultancy.com
• Deputy Safeguarding Lead
  
  • office@ibisconsultancy.com
• Deputy Safeguarding Lead
  
  • +44 1622 37 0617
• • office@ibisconsultancy.com

Please note that all Skills Coaches can support with safeguarding issues.

Unless it is an emergency, please submit your Safeguarding Disclosure Form by email and the Designated Safeguarding Lead will deal with your report swiftly.

All staff are trained in safeguarding. Learners, parents, and careers can contact the Designated Safeguarding Lead directly by telephoning as above or by emailing office@ibisconsultancy.com.

Safeguards

Protection

This policy is designed to offer protection to those employees of the Company who disclose such concerns provided the disclosure is made:

• In good faith
• In the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below)

It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.

Confidentiality

IBIS Consultancy will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

Anonymous allegations

This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they will be considered. In exercising this discretion, the factors to be taken into account will include:

• The seriousness of the issues raised
• The credibility of the concern
• The likelihood of confirming the allegation from attributable sources

Untrue allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

Procedures for making a disclosure

On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:

• In the first case, all employees are specifically encouraged to raise any concern with the CEO. The concern will be discussed, and actions assigned as necessary.

If there is evidence of criminal activity, then the investigating officer should inform the police. IBIS Consultancy
will ensure that any internal investigation does not hinder a formal police investigation.

If you are a professional with concerns being handled in your organisation, or another organisation, you should contact the national whistleblowing advice line on 0800 028 0285 or help@nspcc.org.uk.

Timescales

Due to the varied nature of these sorts of complaints, which may involve internal investigators and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The investigating officer, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed. If the investigation is a prolonged one, the investigating officer should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.

All responses to the complainant should be in writing and sent to their home address.

Investigating procedure

The investigating officer should follow these steps:

• Full details and clarifications of the complaint should be obtained.
• The investigating officer should inform the member of staff against whom the complaint is made as soon as is practically possible. The member of staff will be informed of their right to be accompanied by a representative at any future interview or hearing held under the provision of these procedures.
• The investigating officer should consider the involvement of the Company accountants and the Police at this stage.
• The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.
• A judgement concerning the complaint and validity of the complaint will be made by the investigating officer. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement.

If the complainant is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the CEO.

If the investigation finds the allegations unsubstantiated and all internal procedures have been exhausted, but the complainant is not satisfied with the outcome of the investigation, the Company recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health and Safety Executive), or, where justified, elsewhere.

Apprenticeships

This is to make sure that all applicants, learners and staff are aware of the Ofsted contact details. His Majesty’s Chief Inspector of Education, Children’s Services and Skills (‘the Chief Inspector’). Contact them about matters relating to the welfare of children provided with accommodation by boarding schools, colleges and residential special schools.

The Chief Inspector
Ofsted
Piccadilly Gate
Store Street
Manchester
M1 2WD
0300 123 3155
whistleblowing@ofsted.gov.uk

Skills Bootcamps

This is to make sure all applicants, learners and staff linked to DFE funded Skills Bootcamps delivery are aware of the Authority’s (DFE) Whistleblowing and Complaints policies and processes.

Whistleblowing involves entering a ‘whistleblowing’ webform on the ‘Contact the Department for Education’ page, which can be found here: Contact the Department for Education – webform – Complaints

Administration

This policy must be reviewed and approved annually AS A MINIMUM or when legislative or policy amendments dictate. All changes must be signed off in accordance with the below document control and revision history statement.

Prevent Duty: Countering Radicalisation and Extremism

As an apprenticeship provider, we take our responsibilities under the Prevent duty extremely seriously. Prevent is one of the four strands of the UK’s counter-terrorism strategy and focuses on preventing people from being drawn into terrorism. The law “requires all education providers ‘to help prevent the risk of people becoming terrorists or supporting terrorism’”. This includes protecting learners from extremist ideologies (whether violent or non-violent extremism) that oppose fundamental British values and could potentially radicalise them.

Risk Assessment and Prevent Action Plan

IBIS Consultancy maintains a Prevent risk assessment and action plan as recommended by the Prevent duty guidance. This means we have evaluated where and how our apprentices or staff might be at risk of exposure to extremism (e.g. local community influences, online risks, specific learner vulnerabilities) and outlined actions to mitigate these risks. This plan is reviewed annually with input from the DSL (who is our Prevent Lead) and senior management.

Key elements include:

• Ensuring robust IT filtering (addressed in Online Safety above) to limit access to extremist material.

• Safeguarding processes to identify concerning behavior early (e.g. via staff observations or learner self-disclosure).

• Training and awareness activities to equip everyone with knowledge about Prevent.

• Fostering a culture of openness where controversial issues can be discussed safely and misinformation can be challenged.

Training and Awareness of Staff and Learners

All staff receive Prevent training (often via an approved Workshop to Raise Awareness of Prevent or online module). They learn about the causes of radicalisation, the kind of extremist groups that exist (far-right, Islamist, etc.), and the signs that someone may be vulnerable – such as isolation, expressing extremist narratives or a sudden change in peer group. Staff are trained on how to report Prevent concerns just like any safeguarding concern. We reinforce that Prevent is fundamentally about safeguarding individuals who may be exploited by radicalisers, not about spying on beliefs.

Apprentices are also made aware of the dangers of radicalisation as part of their curriculum on safeguarding and British values. We encourage healthy debate on topics like democracy, tolerance, and how to critically evaluate news and online content. This helps build resilience to extremist propaganda. Apprentices should know that they can approach staff if they encounter someone trying to pressure them into extremist activity or if they are worried about a friend.

Promoting Fundamental British Values

A core part of Prevent is to promote British values as a counterweight to extremist ideologies. We integrate the values of Democracy, Rule of Law, Individual Liberty, Mutual Respect and Tolerance into our apprenticeship programme. This might occur through:

• The way classes or workshops are run (e.g. encouraging respectful discussion and allowing learners to voice opinions).

• Specific learning activities or projects that involve understanding democratic processes, laws relevant to the workplace, or diversity in society.

• Inviting guest speakers or using case studies that highlight positive examples of these values in action.

• Clear codes of conduct that reinforce respect and zero tolerance for prejudice.

Inspectors or auditors may ask apprentices about British values; our goal is that apprentices “understand the principles and how they relate to their learning and work”. For instance, an apprentice in management can relate individual liberty to empowering team members, or rule of law to following industry regulations. By embedding these concepts, we create an environment that actively challenges extremist narratives and supports social cohesion.

Referral and Intervention

If a specific Prevent concern arises (e.g., a staff member finds extremist literature in an apprentice’s possession, or an employer reports the apprentice made extremist statements), the DSL/Prevent Lead will assess the situation and may consult with the local Prevent professionals. The DSL knows how to contact:

• The Local Authority Prevent Lead or Education Officer,

• The regional DFE Prevent Coordinator, and

• The local police Prevent team or Channel Panel.

After initial consultation, a formal Channel referral might be made if the apprentice is identified as at risk of radicalisation. The Channel programme is a multi-agency approach to support individuals away from extremism. The DSL will share relevant information (observations, incident details) with the Channel Panel, which will then consider tailored support (such as a mentor, ideological intervention, mental health support, etc.).

Throughout, the DSL will ensure to keep matters confidential and involve as few people as necessary – often only the apprentice, possibly their employer if a risk in the workplace, the Channel/Prevent staff, and any needed family/support. Participation in Channel is voluntary; we will encourage the apprentice to engage if referred, explaining it is supportive and not criminal.

If at any point an imminent threat is identified (e.g. the individual is planning to travel to join a terrorist group, or to commit violence), the DSL or any staff should call 999 immediately. The Prevent duty does not override emergency action when needed.

All Prevent-related actions are documented in our safeguarding records (with appropriate security). We also recognize the importance of balancing safeguarding with maintaining trust – actions under Prevent will be done with sensitivity to not stigmatize or alienate the individual.

No Platform for Extremism

As part of our preventative measures, IBIS Consultancy will not allow training sessions or communications to be used to promote extremist views. Any external speakers or curriculum content are vetted for suitability. If controversial topics are covered, they are handled by staff in a sensitive manner that allows critical discussion. Extremist propaganda materials are not permitted on-site or on our systems.

By fulfilling the Prevent duty, we ultimately aim to protect apprentices from harm – just as we protect them from other forms of exploitation. Our efforts in this area are coordinated with our overall safeguarding procedures, as recommended (i.e. “Providers should consider radicalisation concerns in line with their existing safeguarding processes” rather than treat them in isolation).

Recruitment Procedures

Our recruitment process for positions that involve contact with apprentices (which is most roles in our context) incorporates the following safeguards, in line with KCSIE and best practice:

• Job Adverts and Information: All job descriptions and adverts highlight our commitment to safeguarding and state that rigorous vetting (including reference checks and DBS checks) will be undertaken. Applicants are informed that safeguarding questions will form part of the selection.

• Application Stage: We use application forms that require a full employment history (to identify any gaps) and ask specifically about the candidate’s suitability to work with vulnerable groups. We also require a self-disclosure of any criminal convictions that would not be filtered by the DBS process.

• Interviews: At least one member of the interview panel has completed safer recruitment training. Interviews include specific questions designed to probe the candidate’s values and understanding of safeguarding (e.g., “Tell us about a time you had to handle a safeguarding or confidentiality issue” or scenario-based questions to gauge their response to suspected abuse). Any gaps in employment or ambiguous answers are explored during the interview. Candidates are asked if they have anything to declare in light of the need to safeguard apprentices.

• References: We obtain at least two professional references for the preferred candidate, including one from the most recent employer. We specifically ask referees about the candidate’s suitability to work with young people or vulnerable adults and any concerns or disciplinary issues related to safeguarding. We do not rely solely on open “to whom it may concern” references; our reference requests include tailored questions. References are verified for authenticity (e.g. we might call the main switchboard of a company to verify the person who signed the reference). Any vague or negative comment is followed up.

• DBS Checks: All staff (and long-term contractors or volunteers) who will be in regular contact with apprentices undergo an Enhanced Disclosure and Barring Service (DBS) check prior to finalizing employment. Given that our apprentices are adults, this may not legally fall under “Regulated Activity with Children” unless some are under 18; however, we choose to conduct enhanced DBS checks on staff to ensure no known history that could pose a risk. If any apprentices are or become under 18, or if staff engage in regulated activity with children, we will also check the children’s Barred List. For staff in roles which might involve caring for adults with additional needs, a DBS with adult barred list is considered if applicable. The job offer is conditional on satisfactory DBS clearance. If a check reveals past convictions or information, HR and the DSL assess the relevance and risks before proceeding; a risk assessment may be done for disclosed offenses that don’t automatically disqualify hiring.

• Right to Work and Identity: We verify each candidate’s identity via original documents (passport, etc.) and ensure they have the right to work in the UK. We also obtain original copies of qualifications claimed.

• Additional Checks: For roles with management responsibilities, we check section 128 directions (for those barred from management in education, applicable to independent training providers in certain cases). If recruiting someone from overseas or who has lived abroad, we obtain overseas police checks or certificates of good conduct as far as possible. We also perform an online search (social media/internet footprint) for shortlisted candidates as recommended by KCSIE 2023, to see if any concerning information surfaces that the provider should know.

• Appointment and Probation: Only once all checks are returned satisfactorily will a new hire be confirmed in post. The details of checks (DBS disclosure number, date, who checked it) are recorded on our Single Central Record of recruitment checks, which is maintained and audited regularly. New staff undergo an enhanced supervision during their initial induction and probation. If any concerns arise in that period regarding conduct, we act immediately.

Our safer recruitment process aims to “manage safe recruitment and allegations about adults who may be a risk to learners” as Ofsted expects. By front-loading these safeguards, we reduce the likelihood of hiring someone who could harm learners. However, we remain vigilant as checks are not foolproof – ongoing supervision and training are key.

Staff Code of Conduct

IBIS Consultancy has a clear Staff Code of Conduct (or Professional Boundaries Policy) which all employees must read and sign. This code outlines expected standards of behavior when interacting with apprentices, including:

• Maintaining appropriate physical and social boundaries (e.g., avoiding being alone with an apprentice in isolated areas where possible, not exchanging personal contact info or befriending on social media).

• Prohibition of any sexual or romantic relationships with apprentices (even if over 18, it is an abuse of position of trust and strictly forbidden).

• Not showing favoritism or giving gifts to individual learners that could be misinterpreted.

• Use of appropriate language – no swearing, degrading comments or overly personal comments.

• No tolerance for any form of discrimination or oppressive behavior.

• Guidelines on physical contact (generally to be avoided unless necessary and appropriate, like first aid or training contexts with permission).

• The requirement to report any boundary breaches or even if they find themselves in a compromising situation (to be transparent).

• Confidentiality rules in dealing with learner information.

This code of conduct is in place to prevent grooming or mishandling. It aligns with guidance such as the Safer Recruitment Consortium’s “Guidance for Safe Working Practice”. Breaches of the code are taken seriously and may lead to disciplinary action or referral to authorities depending on severity.

Managing Allegations Against Staff or Others in Positions of Trust

Despite preventative measures, there may be instances where an apprentice or colleague alleges that a member of staff (or contractor or even an employer’s staff member) has behaved in a way that harmed a learner or posed a risk. We have a specific procedure to handle such allegations against staff, in line with Chapter 4 of KCSIE:

• Any allegation or concern that a staff member or someone in a position of trust has:

  • Behaved in a way that has harmed or may have harmed a child or vulnerable adult;

  • Possibly committed a criminal offence against or related to a child or vulnerable adult; or

  • Behaved towards a child or vulnerable adult in a way that indicates they may pose a risk of harm in the future;

  must be reported immediately to the Head of the Organisation (CEO) or their designate. (If the allegation is about the CEO, it goes to the Chair of the Board). The DSL can facilitate this reporting but the case will be managed by senior management to ensure impartiality.

• We will act swiftly. The accused person may be suspended (a neutral act) pending investigation, to remove any potential current risk to learners. We will consult with the Local Authority Designated Officer (LADO) if the allegation relates to harm or potential harm to someone under 18 (the LADO gives guidance on managing such cases). For adults, we might consult the local authority Safeguarding Adults team for advice on handling the case if applicable.

• A decision will be made whether it’s a matter for:

  • Internal investigation (if it’s more of a misconduct issue not reaching external referral threshold),

  • Police investigation (if a crime is alleged – we do not investigate those ourselves, but we will gather initial facts and then hand over to police),

  • Strategy meeting with social services (for child victims) or with the Safeguarding Adults Board (for adult victims) to plan next steps.

• Throughout, we will ensure support for the person who made or is subject of the allegation. The reporting apprentice (or staff member who raised it) will be protected from any backlash. The accused staff member will be treated fairly and confidentially, with a named contact person to liaise with them (they may seek union or legal support as well).

• If the allegation is substantiated and the individual is dismissed or resigns, the Provider will fulfill its legal duty to refer to the Disclosure and Barring Service (DBS) for consideration of barring that person from working with children and/or vulnerable adults, as appropriate. We will also inform any professional regulator if applicable. Similarly, we would inform the ESFA/Ofsted if the situation meets serious incident criteria.

• If an allegation is found to be false or malicious, IBIS Consultancy will consider appropriate action towards whoever made the false claim (if it was a deliberate act to harm someone’s reputation), while also ensuring the staff member’s reputation is supported (they may need help reintegrating and clearing their name).

Allegations against an employer’s staff member (someone not employed by us but in the apprentice’s workplace) will be handled in partnership with the employer. We will still ensure it’s reported to authorities as needed and may advise the employer on suspension or other measures. The apprenticeship might be paused or the apprentice relocated if necessary for their safety.

Through careful safer recruitment and a strong code of conduct, we aim to minimize the likelihood of such allegations. But if they do arise, these procedures ensure they are handled consistently, fairly, and with the paramount aim of protecting the apprentice/victim and upholding safeguarding.

Data Protection, Record Keeping and Confidentiality

Handling of safeguarding information is done in compliance with data protection laws (DPA 2018 and UK GDPR) and with utmost respect for privacy – but always balanced against the need to protect individuals from harm. We follow the principle that information will be shared on a “need to know” basis in order to safeguard.

Key points of our approach:

• Secure Record-Keeping: All safeguarding records (concern forms, referral notes, meeting minutes, reports) are kept securely, separate from academic records. If paper-based, they are in locked storage accessible only by the DSL and limited authorised personnel. If electronic, we use a secure case management system or encrypted files with access limited to the safeguarding team. Records are retained in accordance with our retention schedule (usually until the apprentice would be mid-20s at least, or longer for serious cases as per legal advice).

• Confidentiality: We ensure that the information about safeguarding cases is kept confidential within the safeguarding team. Staff are reminded not to share details with colleagues or others who are not directly involved. Even among those involved, we might use anonymized information in discussions if possible. For example, an instructor might be told “Watch out and support [Learner A], they are going through some difficulties” without being told the specific safeguarding details, unless they truly need to know to help.

• Consent and Information Sharing: With adult apprentices, wherever feasible, we seek their consent before sharing personal sensitive information with external agencies. However, we make it clear that if we judge them or someone else to be at serious risk, or if a law requires it, we may share information without consent. According to government guidance “DPA and UK GDPR do not prevent the sharing of information for the purposes of keeping children safe” – the same applies to keeping adults safe. In practice, this means if an apprentice refused consent for a referral but the DSL believes there is an overriding interest (public protection, vital interests, etc.), we may lawfully share that information. We document our decision-making rationale in such instances (referring to the “seven golden rules for information sharing” from HM Government advice.

• Multi-Agency Working: When we do share information with other agencies (social services, Channel panel, police, etc.), we ensure it is done securely. We use secure email or phone calls to known professionals. We share only the information that is relevant to the case at hand, not unnecessary details. We expect those agencies to also handle the data appropriately. We might also enter into information sharing agreements for ongoing collaboration if needed.

• Apprentice Access to Records: Learners have the right under data protection law to request access to their personal data, but safeguarding records can be exempt from full disclosure if doing so would risk harm to them or someone else, or if it includes third-party information. If an apprentice (or parent/guardian in the case of a younger apprentice) makes a subject access request for safeguarding files, the DSL will consult legal advice and likely supply a redacted summary if appropriate rather than full case notes, to protect others mentioned and ensure no adverse impact on any investigations.

• Data Breaches: We have protocols in place in case any sensitive data is accidentally disclosed or lost (e.g. an email sent to wrong address). The DSL would inform the Data Protection Officer, and if it meets the threshold, report the breach to the ICO. All efforts would be made to mitigate any damage, e.g. recalling the email, informing the subject of the breach if needed.

• Confidential Reporting: We maintain the confidentiality of those who report concerns (whistleblowers or informants). If a staff member reports a concern about a colleague, we handle it discreetly. The accused person will not be given the identity of the reporter in the initial phase (and possibly not at all, especially if it was a protected disclosure), unless required by law in disciplinary proceedings. Similarly, if an apprentice reports abuse, we limit who knows their identity to those necessary (the alleged perpetrator will not be given details of the allegation beyond what’s necessary for investigation, and certainly not told who said what beyond what procedure demands).

• Storage Duration: Typically, if an apprentice leaves our programme, we retain safeguarding records at least until a reasonable time has passed in which any investigation or inquiry could occur. Often this is for several years after they leave, in line with recommended retention periods (for child records until age 25, and for adult records often a similar length of time). This is in case historic allegations surface or for reference if the individual ever re-engages in learning and issues reoccur.

• Transfer of Records: If an apprentice were to transfer to another training provider or educational institution and we had ongoing significant safeguarding concerns, the DSL would securely and confidentially transfer the relevant safeguarding records to the new institution’s DSL, ensuring continuity of care (with the apprentice’s knowledge, ideally).

Our overriding goal is to handle personal information ethically and lawfully while never compromising on safety. As KCSIE notes, “Fears about sharing information must not stand in the way of safeguarding children [or adults].” All staff are trained on this balance, and our Privacy Notices reflect the possibility of sharing data for safeguarding reasons.

Embedding Safeguarding Across the Curriculum and Organisation

Safeguarding at IBIS Consultancy is not seen as a standalone duty but as an integral part of our educational and organisational culture. We embed safeguarding, including Prevent and online safety, into the apprentice experience and into the ethos of our company.

Apprentice Curriculum and Learning

• Induction for Apprentices: At the start of the apprenticeship, every learner participates in an induction session that covers safeguarding and Prevent. They learn what safeguarding means, the types of issues they might face, and most importantly, how to get help. We introduce them to the DSL/team (or at least provide names and contact info), explain the reporting channels (including that they can talk to any staff who will then help them get support), and provide a learner-friendly handbook on safeguarding. We also cover basics of online safety and Prevent during induction, perhaps via interactive activities or videos, to engage them from day one in thinking about these topics. Key messages like “your welfare is our priority” and “it’s okay to speak up” are emphasized. They also receive information on external sources of support (e.g. helplines for mental health, domestic abuse, or the FE student support services).

• Taught Sessions / Off-the-Job Training: Throughout the apprenticeship, there are planned opportunities where safeguarding-related topics are revisited. For example, many apprenticeship programs include “personal development” or tutorial sessions. In these, we include content such as:

  • Health and Wellbeing: stress management, mental health awareness, where to seek help (thus reducing stigma and encouraging self-care).

  • Healthy Relationships: understanding consent, respect in relationships, addressing sexual harassment (relevant in workplaces too), and how to spot unhealthy or controlling behaviors.

  • Substance Misuse: education on the risks of drugs and alcohol, which links to personal safety.

  • Prevent and British Values: interactive discussions or projects around what British values mean in practice, and how to respectfully challenge extremist ideas. We might do case studies or debates on current events, supervised in a safe environment.

  • Digital Footprint: building on online safety, guiding apprentices on maintaining a professional digital presence (important for their careers as well) and avoiding negative consequences online.

  • Equality and Diversity: promoting an understanding of different backgrounds, cultures, and orientations, and fostering empathy and inclusion. This ties into safeguarding by combating bullying and discrimination.

  These sessions are often tailored to the context of business and management apprenticeships – for instance, discussing ethical leadership (embedding respect and law), or how diversity in teams is a strength. By making safeguarding relevant to their course and work context, learners see it as part of their professional development, not something separate.

• Workplace Visits and Reviews: Training staff (tutors/assessors) who visit apprentices in the workplace or conduct progress reviews always include a check-in on welfare. They might ask, “Do you feel safe and supported at work and in training? Any concerns inside or outside of work you’d like to talk about?” This is done privately with the apprentice at each review. Staff have prompts to discuss topics like workload (to catch if they are overworked or stressed), inclusion (how are they treated by colleagues), and life outside work if the apprentice is willing to share. Notes of these discussions are recorded, and any issues trigger follow-up by the DSL if needed. By systematically asking, we provide multiple chances for apprentices to disclose concerns.

• Learner Voice: We actively seek feedback from apprentices about safeguarding. This could be through surveys (asking if they feel safe, if they know who to contact for help, etc.), learner rep meetings, or suggestion boxes. We analyze this feedback to improve our approaches. For example, if some learners indicate they aren’t sure about how to report a concern, we will refresh that information in classes and posters.

• Enrichment Activities: We may observe national campaigns like Safeguarding Adults Week, Mental Health Awareness Week, Safer Internet Day, etc., through special activities or communications to reinforce messages. We sometimes bring in external speakers – e.g., someone from the local police Prevent team to talk about extremism, or a charity speaker on domestic abuse. These sessions broaden understanding and show apprentices the network of support beyond our organisation.

Organisational Culture and Environment

• Posters and Reminders: At our training center(s) and on our learner VLE (Virtual Learning Environment), we display safeguarding information prominently. This includes pictures/names of the DSL and key staff (“Here to help” posters), helpline numbers (Samaritans, National Domestic Abuse Helpline, etc.), and short statements encouraging a safe and respectful environment. Online, we might have a safeguarding tile or link where apprentices can also report a concern or find resources.

• Safeguarding in Policies: Safeguarding considerations are woven into other policies: e.g., the Behaviour Policy (which covers bullying, harassment), the Attendance Policy (recognising that missing sessions could be a sign of issues and requires follow-up), and Health & Safety Policy (ensuring physical safety at all venues). Our disciplinary procedures for learners take into account whether misconduct might indicate a safeguarding need (for instance, if a learner is aggressive, are they actually acting out due to being abused elsewhere?).

• Employer Engagement: We embed safeguarding in how we engage with employers too. For example, in employer newsletters or review meetings, we include a standing agenda item on apprentice welfare and remind them of safeguarding responsibilities. We celebrate those employer partners who demonstrate great support for their apprentices’ wellbeing, setting them as examples.

• Continuous Improvement: Safeguarding is a constant in our self-assessment and quality improvement plans. We monitor how effectively safeguarding is being taught and understood. Observations of teaching sessions consider whether British values and safe practices are being appropriately promoted. We keep records of any incidents or near misses and review them for patterns (for example, if multiple online safety issues arise, we adjust our training or IT controls).

• Support Services and Signposting: We maintain a directory of support services (local and national) for various issues – mental health clinics, sexual health resources, citizens advice (for financial or legal issues), etc. Apprentices are given this information so they can self-refer or seek help beyond what we provide. The DSL or support officers will also help apprentices contact these services if needed, sometimes even going with them to initial appointments for moral support if appropriate.

• Safe Environment: If we have physical training premises, we ensure they are safe: adequate security on entry, visitor badging and supervision, and a culture where any unknown person on site is politely challenged. Apprentices should feel secure when they come to us for workshops or meetings. We also adhere to Prevent guidance on managing risks associated with any external speakers or materials on site (no extremist content allowed, etc.).

By embedding safeguarding in all these ways, we strive to create a holistic protective network around our apprentices. Safeguarding is not a one-off lesson but a golden thread that runs through the entire apprenticeship journey – from initial assessment to the endpoint assessment. This helps apprentices not only stay safe during their programme but also equips them with knowledge and values to keep themselves and others safe throughout their lives and careers.

Safeguarding Vulnerable Adults (Adult Learners at Risk)

All our apprentices are adults, and some may be classified as “adults at risk” or “vulnerable adults” due to particular circumstances. An adult learner may be vulnerable, for example, if they have a learning difficulty or disability, mental health condition, or a temporary crisis in their life that reduces their ability to protect themselves. IBIS Consultancy is committed to safeguarding such adults with the same rigor applied to children’s safeguarding, but also with recognition of their rights and autonomy as adults.

Definition and Legal Context

For the purposes of this policy, and in line with the Care Act 2014, a vulnerable adult / adult at risk is defined as an individual aged 18 or over who “may need 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.” This can include adults with physical or learning disabilities, those with sensory impairments, older adults with frailty, or anyone who is subjected to abuse or neglect and cannot easily stop it or get help.

Local authorities have a duty (often referred to as a Section 42 duty) to make enquiries if such an adult is suspected to be at risk of abuse. IBIS Consultancy will cooperate fully with any such enquiries when our apprentice is the subject.

We also note that the Safeguarding Vulnerable Groups Act 2006 provides for barring individuals from working with vulnerable adults in certain contexts. While teaching most adult learners is not a regulated activity by law (unless the adult has specific care needs), we still observe high standards of recruitment and vigilance to ensure no one unsuitable is in a position to exploit any apprentice (see Safer Recruitment).

Empowerment and Consent

A key difference in adult safeguarding is the emphasis on empowerment. We actively involve adult apprentices in decisions about their own safeguarding wherever possible. If an apprentice has capacity to make decisions (under the Mental Capacity Act 2005, most apprentices will have capacity unless a condition impairs this), their wishes cannot be overridden except in specific circumstances (e.g. serious crime or risk to others).

This means if an adult discloses abuse but strongly refuses any action or referral, the DSL will discuss the possible consequences with them and try to persuade them by explaining the benefits of getting help. We respect their autonomy but also have to consider wider risks. If others might be at risk (for instance, the alleged perpetrator is also around other vulnerable people) or if the abuse is severe, we might still share information without consent – but we would inform the apprentice of this decision unless telling them would further jeopardize safety. All such judgments are made in line with the Calderdale principles or ‘six principles’ of adult safeguarding described below, particularly Proportionality (the response is least intrusive and takes account of the person’s wishes) and Protection (duty to ensure safety of those in need).

The Six Principles of Safeguarding Adults

We endorse the six key principles that underpin adult safeguarding work nationally:

1. Empowerment: People being supported and encouraged to make their own decisions and give informed consent. Outcome: Apprentices feel involved in decisions about how to keep them safe. We seek consent for referrals and support them to make choices. (“No decision about me without me.”)

2. Prevention: It is better to take action before harm occurs. Outcome: We proactively provide support and information to reduce the chance of abuse occurring. For instance, by educating apprentices about risks (financial scams, abusive relationships) and by having robust policies, we aim to prevent situations of harm.

3. Proportionality: The least intrusive response appropriate to the risk presented. Outcome: Our actions will not be overbearing if not necessary. We respond in a way that matches the seriousness of the situation. For example, low-level concerns might be resolved with support and monitoring, while serious abuse triggers formal intervention. We also balance safety with respecting the adult’s freedoms.

4. Protection: Support and representation for those in greatest need. Outcome: We ensure that adults who need help to protect themselves receive it. If an apprentice is unable to protect themselves, we will step in to protect them, e.g. by involving social services or even removing them from a harmful environment (with their agreement where possible). We stand up for our learners’ right to be safe.

5. Partnership: Local solutions through services working with communities. Outcome: We work together with external agencies and share information appropriately. By partnering with employers, local authorities, police, health services and community organisations, we create a network of support. For example, if an apprentice with a mental health issue is struggling, we might coordinate with their doctor or a support charity in addition to our efforts.

6. Accountability: Accountability and transparency in safeguarding practice. Outcome: The Provider is open about its actions and decision-making. Clear roles (like the DSL’s role) ensure accountability. We document decisions and rationale. If something goes wrong, we acknowledge it and learn. Safeguarding is everyone’s duty, and we foster a culture where staff feel accountable for doing the right thing.

These principles guide all interactions – from planning support for a vulnerable apprentice, to deciding whether to share information, to reviewing how a case was handled. They align closely with our organisational values of respecting and supporting our learners.

Responding to Adult Safeguarding Concerns

The procedures described earlier under “Reporting a Concern” apply equally to adult cases. If an adult apprentice is suffering abuse (say, by a family member or carer), the DSL will contact the Adult Social Care Safeguarding team rather than children’s services. The referral will ask for an adult safeguarding enquiry. In such a case, we expect the local authority to coordinate an appropriate response (which could involve strategy meetings, protective measures, etc.). We will support the apprentice through that process, making sure they have advocacy if needed (some adults might benefit from an advocate if they struggle to understand or participate in proceedings).

It’s also worth noting:

• If an apprentice lacks mental capacity to make certain decisions related to their safety, decisions will be made in their best interests following the Mental Capacity Act guidelines. We would involve any power of attorney or consult with professionals to ensure their safety.

• We are attentive to transitions – if an apprentice at risk was previously known to children’s social services (perhaps they had a social worker up to 18), we ensure continuity by liaising with adult services as needed.

• In cases of alleged abuse by someone in a position of trust (like a staff member or fellow learner), even though the victim is an adult, we may need to inform other bodies (for example, if the perpetrator works in care settings, their employer or DBS may need notification). We treat such cases as very serious.

In summary, our approach to safeguarding vulnerable adult learners is holistic and person-centered. We treat each apprentice with dignity and involve them in solutions, while also fulfilling our duty to shield them from harm. All staff are made aware that “safeguarding vulnerable adults is as important as safeguarding children” – abuse is never acceptable whatever the person’s age. By working within this framework, we aim to ensure every apprentice (including those who may be most vulnerable) can learn and work in a safe and supportive environment.

Staff Training and Development

High-quality training for staff and all stakeholders is a cornerstone of our safeguarding arrangements. IBIS Consultancy ensures that everyone understands their safeguarding responsibilities and has up-to-date knowledge of risks, procedures, and best practices.

Induction Training

New staff, including trainers, administrative staff, and volunteers, receive mandatory safeguarding induction training upon joining the organisation. This induction covers:

• An overview of this Safeguarding Policy and key procedures (reporting concerns, contacting DSL, etc.).

• Basics of child protection and adult safeguarding law and guidance, including a summary of KCSIE and Prevent duty.

• The different types of abuse and how to recognize indicators.

• Specific emphasis on our context: safeguarding adult learners, Prevent, and the importance of professional boundaries.

• Introduction to the DSL and how to contact them, as well as the Deputy DSLs.

• Instructions on reading Part 1 of KCSIE (if applicable) or our condensed policy summary, as per guidance that all education staff should read and understand at least the basic safeguarding info.

• Completing any required e-learning modules (e.g. an online Prevent awareness module or basic safeguarding awareness course) within their first week.

New staff sign off that they have read and understood the Safeguarding Policy and KCSIE Part 1 (or Annex A for those who won’t work directly with under-18s, per organisational decision). This sign-off is kept on file.

Ongoing Training and Refreshers

All staff undertake formal safeguarding training at least annually. This may be delivered as an in-house workshop, online training, or at an all-staff meeting. The annual training covers any updates in legislation (for example, changes in KCSIE for that year), emerging risks (such as trends in online challenges or local issues like gang activity), and reinforcement of core procedures. We incorporate scenarios and case studies relevant to apprenticeships to keep training practical.

Key aspects regularly reinforced include: reporting routes (who to contact, with some “test” questions to ensure everyone remembers the DSL’s name and number), Prevent and British values, online safety practices, and the boundaries of confidentiality. We also include “safeguarding quizzes” or discussions to keep knowledge fresh.

In addition to the annual update, we send out safeguarding briefings via email or newsletters termly – for instance, reminding staff of the whistleblowing process, or sharing learning from any incidents or near-misses (anonymized). Staff are required to attend these sessions or read these updates; non-compliance will be followed up by managers.

The DSL and HR track who has completed training and will chase any lapsed certifications. Safeguarding training completion is a part of everyone’s performance reviews.

Specialist Training

• DSL and Deputies: The DSL and deputy DSL(s) receive advanced multi-agency safeguarding training (usually via the local authority or accredited body) every 2 years, at minimum. They also attend Prevent Lead training and Channel Panel briefings. They keep up with networking events or conferences for DSLs in further education to continually improve practice. The DSL team also does training on specific issues like managing allegations against staff, online safety technology, mental health first aid, etc. Continuous Professional Development (CPD) records are maintained to show the DSL’s competence is current.

• Prevent: In line with the Counter Terrorism and Security Act 2015, all staff undertake Prevent training appropriate to their role. Typically, this means basic Prevent awareness for most, and additional training for those in pastoral roles. We often use the government-approved Prevent e-learning and supplement it with discussions about local risks. This training is refreshed every 2 years or when significant updates occur. We document Prevent training as part of our compliance evidence.

• Safer Recruitment Training: At least one person on every interview panel for staff or volunteer recruitment has undertaken Safer Recruitment training (as recommended by KCSIE). We have multiple senior staff trained in safer recruitment principles to ensure that interviews and hiring processes incorporate safeguarding (see Safer Recruitment section). This training is renewed every 3 years or after major updates.

• First Aid and Mental Health: While not purely safeguarding, we ensure a number of staff are trained in first aid and in Mental Health First Aid or similar, so that immediate support is available for physical or mental health emergencies that could relate to safeguarding incidents (e.g. a panic attack triggered by trauma).

• Employer Training/Briefings: We offer basic safeguarding training or briefings to employer partners as well. For example, we provide a short online course or briefing pack on safeguarding and Prevent for workplace mentors. We strongly encourage at least one staff member per employer to complete this (especially if they are new to apprenticeships). This helps ensure our expectations of employers (outlined earlier) are understood. We keep records of which employers have attended our annual employer safeguarding webinar or received our guidance materials.

Continuing Development and Culture

Safeguarding is included in agendas for staff meetings and standardisation meetings. We discuss any issues, share best practices and keep the topic alive. For instance, an internal newsletter might highlight a “Safeguarding Spotlight” topic each month (one month domestic abuse, another month online scams, etc.).

We encourage a culture where staff ask questions and seek clarification. The DSL operates an “open-door” policy for any concerns or uncertainties about procedures. New or less experienced staff are mentored by seasoned staff in dealing with sensitive disclosures.

Our goal is to ensure staff not only know their duties but are also confident and competent in carrying them out. Through robust training and a supportive environment, safeguarding knowledge is embedded and continuously updated, so that we are always ready to protect our apprentices.

Safer Recruitment and Staff Conduct

IBIS Consultancy recognizes that safeguarding starts before any staff member or volunteer joins our organisation. We therefore have stringent safer recruitment practices to deter and prevent unsuitable individuals from working with our apprentices. We also enforce clear conduct standards to ensure that once hired, staff maintain appropriate boundaries.