Safeguarding Policy

Safeguarding Policy

1. Our Commitment 

All our employees who work with learners have a crucial role to play in shaping their lives. You have a unique opportunity to interact in ways that are both affirming and inspiring. This policy has been produced (and is supported by Information, Advice and Guidance), to help you to establish safe and to enhance awareness of the broader welfare spectrum, specifically the issues facing young people in society.  responsive environments which safeguard all and reduce the risk of you being unjustly accused of improper or unprofessional conduct. We all have a duty of care to safeguard and promote welfare.

2. Objectives 

The policy aims to ensure you are aware of and understand your responsibilities, and those of others, signs there might be a safeguarding concern, along with the reporting procedures for all safeguarding issues. 

3. Scope 

This policy covers safeguarding Children and Adults at Risk – our learners, learners during EPA, learners within sub-contracted provision, and those persons in settings in which we practise which fall into the category of child or adult at risk. It is inclusive of specific highlighted safeguarding agenda areas – as defined by law, as specified in Keeping Children Safe in Education (2024) and in the wider context of all our students and learners. This policy is also influenced by and aligns with requirements set out in ‘The Education Act (2002) Section 175’, ‘Working Together to Safeguard Children (2023) Updated Dec 2023’ , This policy also aligns with The government Counter-terrorism and Security Act 2015, that places a duty upon all education providers to have regard to the need to prevent people from being drawn into terrorism. This Prevent Duty forms part of the wider government CONTEST counter-terrorism strategy:

The aim of the Prevent strategy is to reduce the threat to the UK from terrorism by stopping people from becoming terrorists or supporting terrorism. The Prevent strategy has three specific strategic objectives:

  1. Respond to the ideological challenge of terrorism and the threat we face from those who promote it 
  2. Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support.
  3. Work with sectors and institutions where there are risks of radicalisation that we need to address. 

Puzzled Education has a separate Prevent Policy for more detail in relation to how it meets the Prevent Duty 

4. Key Contacts 

The safeguarding team can be contacted on enquiries@puzzledtraining.co.uk 

Designated Safeguarding Lead: Katy Akkers – 01709 828006 

Deputy Safeguarding Lead:  Samantha Evans – 01709 828006

5. Definitions 

Safeguarding is the protection of children and of adults at risk from abuse and neglect, promoting health and development, ensuring safety and care, and ensuring optimum life chances. The Safeguarding Agenda includes a wide range of potential risks (see Appendix F for full definitions and indicators of a Safeguarding concern). 

A child is defined as anyone under the age of 18 as cited in the Education Act (2002), 

An adult at risk as defined by the Care Act (2014) as any person over the age of 18 and at risk of abuse or neglect because of their need for support or personal circumstance. Alongside the Safeguarding Agenda risks above this could be due to, and not limited to any of the following: 

The definitions of a child and adult at risk give the rationale for legislative intervention, it is important to note that that learners can be temporally vulnerable due to changes in circumstances or due to poor mental health. A person may also be deemed at higher risk of a safeguarding issue affecting them due to other factors. This is termed contextual safeguarding. Examples of areas to consider are: 

Poor numeracy and literacy skill, or specific learning need 

English not a first language 

Unsupportive employer 

Under-represented group 

Acting as a carer for another family member 

Background in offending or is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement and association with organised crime groups 

Has a disability or social need 

Has special educational needs (whether or not they have a statutory Education, Health and Care Plan) 

Lives ‘In Care’ or has recently transitioned out of Care 

Is a young carer 

Is frequently missing/goes missing from care or from home 

Is within a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues domestic abuse or generally unsupportive. 

Several groups of learners have been identified as being more vulnerable, and each have proportionate measures in place in order to ensure the learners are fully supported. These include learners on an EHCP, tutor core learners and in-care learners 

6. Our Responsibility 

We all have a responsibility to ensure that children, young people and adults at risk are protected from harm, informed about potential risks to their welfare, and understand how to seek help. We ensure all concerns are dealt with timely and appropriately. We also have a responsibility to minimise the risk of allegations against you. 

All staff are expected comply with any background disclosure check request and to have a good understanding of what constitutes a safeguarding or welfare concern, have read KCSIE (2024) Part 1 along with any other relevant policies, know how to provide support, guidance in such instances, and the channels for escalating a concern. To assist you in this, on-going training and awareness, as well as continuous information, advice and guidance will help you to feel confident in proactively promoting safeguarding and understanding your individual responsibilities. 

The responsibilities of particular individuals are detailed below: 

Our Director – to be knowledgeable about safeguarding and to ensure we have effective policies to receive reports on safeguarding at each board meeting. To ensure policies are implemented and followed, and sufficient time and resources are allocated to employees to carry out their responsibilities. 

Designated Safeguarding Lead – to maintain links with local multi-agency safeguarding partners (local authorities, chief officers of police, and clinical commissioning groups), and Prevent Coordinators, inform and advise all parties on legislation changes and current safeguarding themes, plan and implement training for all employees including CPD, quality assurance and standardisation for the designed safeguarding officer team. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as safeguarding board where appropriate. Support and coordinate escalation process. Overall management of safeguarding issues and report to board on any issues that arise. Review procedures and policies on a timely basis. Maintain own CPD to ensure their role can be fulfilled competently. They will also provide advice and support to other staff on child welfare, safeguarding and child protection matters, taking part in strategy discussions and inter-agency meetings, and/or supporting other staff to do so, and to contributing to the assessment of children. They will lead on policy and training, making referrals to external agencies such as Local Authority children’s social care/Chanel/ Police and DBS. Have awareness of those children that are in need and how their education is impacted and progressing; this includes children allocated a social worker where this has been alerted to Puzzled Education, acknowledging the risk to these learners could be higher, and ensuring support is in place. They will also pass this information where relevant to a learner’s new training provider if they leave a Puzzled Education programme. They act as Puzzled Educations Mental Health lead for both learners and employees when informed, oversee information security for safeguarding and work with the data protection team where required, including monitoring web filtering systems for both employee and learners. The lead will also nominate and ensure Deputy Designated Safeguarding Officers are in place and trained to the same level. They will also report to the Board on safeguarding. 

Designated Safeguarding Officers – to deal with employee concerns over learners’ welfare, signpost and offer guidance. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as Regional Prevent Coordinators, local multi-agency safeguarding partnerships (which constitute local authorities, chief officers of police, clinical commissioning groups) where appropriate. Maintain own CPD to ensure their role can be fulfilled competently and seek guidance where appropriate.

Our Tutors – to check safety and welfare with all learners at each visit/communication, ensuring learners complete all safety-related learning activities within their programme. You must be aware of indicators and that there may be a safeguarding issue and if required to follow the 5 R’s procedure (Recognise, Respond, Record, Report, Refer), (see Appendix D). To provide support and referral to external agencies as they see fit, if comfortable to do so, and then inform safeguarding team of their actions. To complete allocated training as directed by the safeguarding team in a timely manner.

Support Teams – You must be mindful of indicators that there may be a safeguarding issue should you come into contact with a learner or potential learner – see Appendix D, and if required to follow the 5 R’s procedure ( Recognise, Respond, Record, Report, Refer) .To complete allocated training as directed by the safeguarding team in a timely manner.

The topic of Safeguarding can be very sensitive due to the content and may be difficult for you to discuss. If you have any concerns over issues raised, please contact a Designated Officer as quickly as possible. 

7. Safer Recruitment 

Puzzled Education undertake a range of Safer recruitment practises throughout the recruitment process including sharing our commitment to Safeguarding in job adverts, a thorough interview process and collation of references. Puzzled Education ensures that all appropriate checks are carried out on new staff that will work or come into contact with children and adults at risk in line with the Disclosure and Barring Service and Teacher Regulation Agency (TRA) requirements, and KCSIE. Puzzled Education reserves the right to do online checks as part of Safer Recruitment (KCSIE 2024).

7.1. Disclosure and barring service checks 

The Disclosure and Barring Service (DBS) is the executive agency of the UK government whose primary purpose is to help employers make safer recruitment decisions and appointments. 

By conducting checks and providing details of criminal records and other relevant information, DBS helps to identify applicants who may be unsuitable for certain work and positions, especially those involving contact with children (those less than 18 years old) or adults at risk. 

Depending on the type and regularity of contact with children or adults at risk involved in a particular role, employers are entitled to make appropriate types of enquiries about the applicant’s criminal record and seek a disclosure through a DBS check. Puzzled Education can undertake two types of criminal records checks depending on the role applied for: 

Standard DBS Check 

This will be for positions that are included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975. 

This type of check contains details of an individual’s convictions, cautions, reprimands or warnings recorded on police central records and includes both ‘spent’ and ‘unspent’ convictions that will be shown on a criminal records check. 

Enhanced DBS Check 

This will be for positions included in both the ROA 1974 Exceptions Order and in the Police Act 1997 regulations. This type of check contains the same details as the standard check plus any information held locally by police forces that it is reasonably considered to be relevant to the post applied for. 

7.2. When and what type of DBS check is appropriate 

A senior member of the Management Team and Designated Safeguarding Lead are responsible for deciding which level of check is appropriate for a particular role and whether barred list checks are necessary. Even where a post has some contact with children or adults at risk, the definition of regulated activity may not be fully satisfied, but to safeguard our learners any unsupervised contact with learners will result in an enhanced DBS check with child barred list. The Safeguarding Vulnerable Groups Act 2006 (amended by the Protection of Freedoms Act 2012) defines what types of activities involving children and adults at risk are regulated and therefore require barring list checks. Appendix A specifies current posts at Puzzled Education that require DBS and/or barring list checks. 

Regulated Activity – is a term that defines activities that an individual engages in, defined by the Disclosure and Barring service. The criteria for regulated activity differ for adults and children as shown overleaf: 

Children 

Regular activity (once per week or 4 times over the course of 1 month) 

Unsupervised activity 

Teaching, training, assessing, mentoring based activities in relation to nonwork-related activities – working intensively and closely with a child 

Within specified settings 

Adult 

Healthcare professionals – those whose role includes providing first aid 

Receiving or giving personal assistance to those due to age, illness or disability (going to the toilet/washing/nutritional advice) 

Providing social care – being subject to or assessing the need for health/social care 

Providing assistance in someone’s personal affairs or allowing someone else to do so 

Provide assistance with cash, bills and shopping (allowing someone else to or shopping on someone’s behalf) 

Person who transports or is transported because of their illness 

Individuals must not engage in regulated activity with either children or adults at risk if they have been barred from doing so by the DBS scheme. How we meet our responsibility towards this is explained below. Further advice on types of DBS disclosure and the circumstances in which regulated activity applies can be obtained from the Management Team. 

Where Puzzled Education is recruiting for a role that qualifies for a DBS/PVG check, the advert and further information during the interview process will confirm the type of check required. When the most suitable candidate for the position has been identified, the offer of appointment will be made subject to a satisfactory DBS check, right to work, references and qualification checks. In the instance that the outcome of a DBS check has not yet been received from the appropriate authority prior to learner visits being carried out, all visits with learners aged below 18 will be supervised by a person whose DBS outcome has been received and approved. The Area Manager will be responsible for arranging this supervision. Quality assurance of this process is in place. 

As a DBS check forms part of our recruitment process, we encourage all candidates to declare anything relevant to the type of check required for the role. Once an offer has been made, candidates should tell us of any further details of convictions, including those that normally would be considered as spent, cautions or reprimands. 

As part of our safeguarding obligations, we will re-apply for the appropriate types of DBS/PVG checks on a 3-year basis during employment with Puzzled Education. If someone is already part of the update service: 

Some contractual requirements dictate an annual declaration from employees in relation to conforming to any changes that may affect the outcome of their DBS check. Any changes will be risk-assessed following the procedure set out in 7.5

7.3 Confidentiality  

Information provided in a disclosure report must be kept confidential and on a need-to-know basis. Such information will be handled in accordance with Puzzled Education’s ‘Statement on the Secure Storage, Handling, Use, Retention and Disposal of Disclosures and Disclosure Information’, Appendix B. Any other information regarding offences must be kept securely and in accordance with Puzzled Education’s Data Protection Policy. 

We recognise that job applicants and our employees need to feel confident that information about their convictions will not be disclosed to colleagues unless there is a specific reason for doing so. Those involved in recruitment decisions should ensure that when appointing an individual with a conviction, they are advised as to whom within Puzzled Education knows of their conviction and the reasons why the information has been disclosed. 

If you would like further information on our disclosure process, please see Appendix C. 

7.4. Failure to disclose information relevant to the type of DBS check relevant to your role 

Having a criminal record does not necessarily preclude an individual from working at Puzzled Education. The decision as to whether a person with a criminal record should be appointed, or an offer of employment withdrawn, or employment terminated will be taken only after careful and thorough consideration of the outcome of any DBS check as well as the job and offence related factors as explained in 8.6. 

Nonetheless, we request all employees to tell us about any information relevant to the type of DBS check appropriate for their role. This could mean, for example, that if your role requires satisfactory Enhanced DBS and barring check, you need to tell us about any convictions, cautions or reprimands or being barred from working with children as soon as any of these have been issued. Failure to disclose information relevant to the type of DBS/PVG check appropriate to your role would be seen by Puzzled Education as a breach of trust and confidence. Such acts are considered as gross misconduct and you would be invited to a disciplinary hearing with a potential outcome of instant dismissal. 

7.5 Exploring the relevance of information provided in the disclosure report 

As we explained in the previous section having a criminal record does not necessarily preclude an individual from working at Puzzled Education. The decision as to whether a candidate with a criminal record should be appointed, or an offer of employment withdrawn, will be taken only after careful and thorough consideration of the outcome of any DBS check as well as the job and offence-related factors as explained in section 8.6. 

Similar to the recruitment process, a disclosure of a criminal record will not necessarily lead to termination of your employment with us and the decision will be taken only after careful and thorough consideration of the job and offence-related factors. Any decision to terminate employment would follow our Disciplinary Policy (or Probationary Policy if you have not yet passed your probation). 

A senior member of the Management Team, alongside the Designated Safeguarding Lead will make an initial assessment of the content of the disclosure report. If the report provides no evidence of convictions or any other relevant information, no further action will be taken. If the report confirms a conviction or any other relevant information, a senior member of the Management Team, alongside the Designated Safeguarding Lead, will make an initial assessment of whether the information provided has any potential relevance to the post. If there is no potential relevance, no further action will be taken. 

If the report confirms a potentially relevant conviction or any other potentially relevant information further exploration will be required following the process outlined below.

7.6. Exploring a conviction and its relevance

All discussions relating to convictions must take place after the selection process has been completed and will involve the line manager a senior member of the Management Team and the Designated Safeguarding Lead. As part of the decision-making process, they will normally meet with the individual to gain more information from the person about the nature and circumstances of any conviction. 

The suitability for employment of a person with a criminal record will clearly vary, depending upon the nature of the job and the details and circumstances of any convictions. The decision will be made on the basis of a risk assessment to enable the applicant’s criminal record and circumstances to be assessed in relation to the tasks he or she will be required to perform and the circumstances in which the work is to be carried out. The following job-related factors should be taken into account: 

Does the post involve direct contact with learners or the public?

What level of supervision will the post-holder receive?

What level of trust is involved? Will the nature of the job present any opportunities for the postholder to reoffend in the place of work? 

Does the post involve any direct responsibility for finance or items of value? 

Does the post involve any contact with children or other vulnerable groups of learners or employees? 

The assessment is also likely to include consideration of the following factors relating to the individual’s offence(s): 

The seriousness of the offence(s) and relevance to the safety of other employees, students, research subjects, the public etc. 

The length of time since the offence(s) occurred. 

Relevant information offered by the person about the circumstances that led to the offence(s) being committed, for example, the influence of domestic or financial difficulties. 

The degree of remorse, or otherwise, expressed by the person and their motivation to change.

Whether the offence was a one-off or part of a history of offending. 

Whether the person’s circumstances have changed since the offence(s) was(were) committed, making re-offending less likely.

Whether the offence has since been decriminalised. 

Following careful and thorough consideration of all these matters and consultation with a senior member of the Management Team and Designated Safeguarding Lead, a decision will be made as to whether the individual should be appointed. If appropriate we may seek further information from relevant bodies when reaching this decision. If the decision is not to appoint, a letter will be sent to the individual confirming the reasons for this decision. 

The above process will also be followed in the event of a criminal conviction coming to light after the formal offer of employment has been made or during employment. In such cases, Puzzled Education would reserve the right to withdraw the offer of appointment where appropriate or terminate employment in line with the Puzzled Education’s Disciplinary Policy (or Probationary Policy if in probationary period). 

7.7. Learner DBS checks 

We have a duty to ensure that learners understand what a DBS check is and if it is required for their role. The employer is ultimately responsible for ensuring anyone they employ has the necessary checks in place.  However, we do support employers to engage with the DBS to fully understand their role and responsibility. 

Work-Based Learning – Each employer partner site undergoes a H&S vetting process. This requires the tutor to check the mandatory legislative DBS requirements are understood by the learner and employer in the relevant sectors. The learners curriculum is contextualised to their work setting and reinforces the importance of the DBS process. 

8. Reporting a concern 

If a learner raises a concern/allegation with you: If the learner has a concern over their welfare and wellbeing, you are to listen to and record all information given, making no judgement or assumptions. Take any actions required to secure the immediate safety of the child or adult at risk if deemed appropriate; this may involve staying with them until a responsible adult can be located. This will only be recorded on the review if learner agrees and raised with the manager if learner agrees. If the learner gives consent, you must report the issue to a Designated Safeguarding Officer. You should always consider the wishes of the individual, even those aged under 18; if you feel the learner’s safety and wellbeing are at risk and they do not give consent for the matter to be escalated, you should work with the learner to encourage this.

If the learner is aged under 18, at risk of harm and no consent agreed you should still escalate, (as set out in Working together to safeguarding children 2023). If a learner is at risk of harm; getting them the correct support is likely to be more important than maintaining their confidentiality. Guidance should be sourced with a Designated Safeguarding Officer if you are unsure and concerns can be reported anonymised initially until it has been established there is need to share information. those learners aged 18 and over the concerns should still be recorded even if no action taken. They will then decide the appropriate course of action, and if a referral for early help intervention or to local authority.

If a learner/parent has a concern/allegation about a member of Puzzled Education or Innovate staff: All learners are to be informed that if they have a concern over the conduct of a Puzzled Education employee , they are to contact a Puzzled Education Designated Safeguarding Lead .If the learner informs the tutor or another Puzzled Education employee they are to report it to the Designated safeguarding lead  Contact details are available in this policy (see section 4 above), The LADO may also be informed where relevant. 

If a parent contacts you to report a concern about their child: Ensure you listen and record the details in the same way as a learner reporting a concern to you (see (a) above). Ensure you have contact details for the parent. You must report the issue to the Designated Safeguarding Officer. They will then decide the appropriate course of action, and if a referral outside the organisation is appropriate, liaise with the parent as appropriate. Be mindful of confidentiality as all learners aged 16 and above, and of employed status, are deemed to be adults, and therefore no information should be passed to parents or carers without prior consent to do so from the learner.

If you observe a safeguarding issue taking place within the working practices of an employer’s setting or during Puzzled Education group delivery sessions: An example would be a practitioner hitting a child or observing inappropriate restraint techniques, or learners verbally or physically abusing each other. Take action to stop the activity immediately and inform the individual of your concerns. Ask them to remove themselves from the area and advise them you will inform their senior manager. In those cases where learners are not on a work-based learning programme inform the safeguarding team. Take any actions to secure the safety of the child or adult at risk; this may involve staying with them until a responsible adult can be located. Inform your Designated Safeguarding Officer in all cases. Be mindful of the differences between poor practice and a safeguarding issue and apply your action appropriately.

You mustn’t pass any information to other parties or try to investigate the concern yourself. All concerns should be reported to enquiries@puzzledtraining.co.uk in the first instance using the Disclosure reporting form (Appendix C). 

If you require an immediate response, call a Designated Safeguarding Officer immediately; it is noted that the designated officer may not be available out of normal working hours, so in circumstances where the individual is in immediate danger report the incident to the police on 999.

The Designated Safeguarding Officer will endeavour to make initial contact regarding the concern within 24 hours (not including weekends). Contact:  01709 828006 / 07340169024. 

The Designated Safeguarding Officer will assess if the individual is at risk of significant harm and decide upon the next course of action; this can range from offering signposting to support agencies to referral to the police and local safeguarding authorities. This may also involve passing information to the LADO, DBS. 

If you feel a Designated Safeguarding Officer has not complied with their duty of care to a reported learner concern, please contact the Designated Safeguarding Lead identified in this policy (section 4 above). If you feel the Designated Safeguarding Lead has not complied with their duty of care to a reported learner concern, please contact the Quality Director. You may also escalate the concern yourself to the relevant external agency 

9. Managing allegations against employees

The Department for Education guidance sets out procedures for managing safeguarding allegations or concerns against teaching staff, other staff, volunteers and contractors. In this guidance training providers are now expected to respond to two levels of concern about staff behaviour:

Puzzled Education intends to create a culture in which all concerns about adults (including allegations that do not meet the harm threshold) are shared responsibly and with the right person, recorded and dealt with appropriately. We aim to create and embed a culture of openness, trust and transparency in which our expected behaviours, which are set out in the staff Code of Conduct, are constantly lived, monitored and reinforced by all employees.

Alongside our Code of Conduct and Safeguarding policy which detail expected behaviours, Puzzled Education will also:  

Ensure that employees are clear about what is appropriate behaviour through awareness and training. 

Through case analysis identify any business improvements required.

 9a Allegations that may meet the harms theshold 

Puzzled Education will consider that behaviour meets the harm threshold if employees – including employees on temporary contracts, volunteers or contractors – have: 

Behaved in a way that has harmed a learner or may have harmed them.

Possibly committed a criminal offence against a learner.

Behaved in a way that may pose a risk of harm to a learner. 

Behaved in a way that indicates they may not be suitable to work with learners.

Safeguarding allegations or concerns arising from the above should be reported to the Designated Safeguarding Lead (DSL). Where there are concerns/allegations about the Safeguarding Lead this should be referred to HR.

If the allegation/concern identifies that a learner has been harmed, is at immediate risk of harm or is an emergency situation, the DSL (or Management Team as appropriate) will immediately contact social care services and where appropriate, the police. They will also ensure that:

The learners affected are safe. 

Inform and support the person subject to the allegation as soon as possible.

Conduct basic enquiries to establish the facts to help them determine whether there is any foundation to the allegation. They will collect as much evidence as possible by speaking directly to the person who raised the concern (unless raised anonymously), to the individual involved and

any witnesses. The information collected will be reviewed against the employee code of conduct to determine what further action may need to be taken, including liaising with a senior member of the Management Team should the disciplinary policy need to be followed.

If appropriate, liaise with the Local authority Designated Officer to consider the allegation and agree on a course of action. 

If appropriate, conduct an internal investigation carried out aligning with the misconduct policy.

Work with the Management Team to implement any internal disciplinary procedures where required. 

Work with the Management Team to support the subject of the allegation. 

All relevant information is shared with police/social care if appropriate.

Any parent/ guardian/ employer is informed and updated where required.

9b. Low-level concerns that do not meet the harm theshold

A low-level concern is any concern about employees – including employees on temporary contracts, volunteers or contractors – who may have acted in a way that is inconsistent with the staff code of conduct (including inappropriate conduct outside of work) but does not meet the harms allegations threshold. Examples of such behaviour could include but are not limited to offering personal favours to learners, being overly friendly, using inappropriate language or sharing personal information.

Puzzled Education will seek to identify and deal with inappropriate behaviour early to mitigate the risk of abuse. Low-level concerns should be reported to the DSL (or a deputy). Where a low-level concern is raised about the DSL, it should be reported to a senior member of the people team. The DSL (or Management Team as appropriate) will collect as much evidence as possible by speaking directly to the person who raised the concern (unless raised anonymously), to the individual involved and any witnesses. The information collected will be reviewed against the employee code of conduct to determine what further action may need to be taken, including liaising with a senior member of the Management Team should the disciplinary policy need to be followed. 

All concerns should be recorded.

Records will be reviewed periodically so that potential patterns of concerning behaviour can be identified. Where a pattern of such behaviour is identified (including where low-level concerns move to meeting the harms threshold) Puzzled Education will decide on a course of action.

10 Training and education employees  

Each member of the safeguarding team holds at least a formal L2 designated officer safeguarding qualification and undertakes regular CPD events and standardisation meetings to keep updated with legislation and refresh their knowledge. 

All employees undertake a Safeguarding Induction and/or completion of a L2 online course specifically for Safeguarding Young Vulnerable People. 

The training received is continually reviewed to ensure the most appropriate and up to date training is given. Aligning with the mandatory duty surrounding the Counter Terrorism and Security Act 2015, all staff undertake Prevent training aligning with their role within Puzzled Education. 

There is annual CPD training for formal procedures and emerging themes. Periodic updates surrounding key safeguarding concepts are communicated monthly via internal communication channels. Monthly focus topics are also distributed via these channels to raise awareness and promote discussion in all areas under the wider safeguarding agenda including areas such as radicalisation, mental health issues, positive relationships, and staying safe on the internet, which will educate employees alongside giving greater knowledge to be passed onto learners. 

There is reference to safeguarding in team meetings, with managers utilising the information in the monthly safeguarding and equality newsletters (Thrive) as well as a health and safety section, to stem discussions. 

11. Expected behaviors & keeping yourself safe 

This section extends the expected behaviours set out in the code of conduct. To maintain your and learners’ safety, the following are strictly prohibited: 

It also important to be mindful of the following when conducting yourself: 

Locations of one-to-one meetings with colleagues. These should take place at a neutral location. 

You will naturally build a rapport with learners through apprenticeship contact, and the learners may see you as a confidante and supportive but be sure to maintain professional boundaries whenever carrying out work on Puzzled Education’s behalf. 

Be respectful of all young and vulnerable people, and appreciate you are in a position of trust. We have the opportunity to listen to their concerns and support them.

Uphold confidentiality within certain remits when required by the situation but be careful not to promise to keep secrets or ask others to do so.

Avoid spending time alone with learners in a closed environment. If this is unavoidable for example during a formal assessment/examination, ensure a member of the site staff is aware where you are and monitors this. 

Be careful when giving learner advice – as this is based on your opinion, focus support around information (facts), and guidance (signposting).

Be mindful of any learners you acquire that by default create a conflict of interest, i.e. a partner or friend becomes a learner. Discuss appropriateness/alternative trainer arrangements with your line manager.

If a learner offers you gifts of any sort as a result of the support through their programme, please refer to the bribery policy for the process to follow. 

If at any point you feel unsafe in a learner’s company, inform the site manager, your line manager, the Designated Safeguarding Officer and leave the premises. 

Digital boundaries are equally important – remote working or online contact should follow the same professionalism as face-to-face delivery.

Avoid using personal WhatsApp or messaging accounts for learner contact. Use official channels where possible.

During remote learning, ensure learners are dressed appropriately and their environment is safe before continuing.

Do not share screen content from personal devices use Puzzled Education systems only.

12. Keeping learners safe

Puzzled Education offers an apprenticeship recruitment service which places potential apprenticeship learners into employment. It is recognised that this creates a duty of care for Puzzled Education to ensure that employers are suitable to receive an apprentice. 

To this end:

A service level agreement is undertaken prior to an apprentice commencing employment to clarify expectations about basic health and safety, and other employment requirements for the learner. 

There is an employer guide to welfare that is available to employers to help them understand Puzzled Education and their own responsibilities under safeguarding, health and safety and Prevent agendas.

Health and safety vetting is carried out during learner induction for new sites. This involves a discussion between the tutor, employer and learner, and allows for the trainer to be confident in the employer’s ability to keep the learner safe during their employment, and also to help educate the learner in looking after their own welfare, and that of others, while at work. Its supports health and safety, and other essential legislative requirements such as a need for some leamers to have a DBS check . H&S is also covered during enrolment directly with the learner and is part of the Life Skills mandatory learning plan modules 

Learners are made aware of all of Puzzled Education’s relevant policies, who the designated persons are and how to report a concern during their induction to the programme.

Puzzled Education request contact details for Next of Kin for all under 18 learners, alongside relevant employer contact details  

Additional social needs identification and process is support that is provided by Puzzled Education for all learners who are facing Social, Emotional, Behavioural and Mental Health difficulties. This process supports Increasing the ability to learn & making learning more accessible whilst dealing with personal issues, helps with motivation to reach their potential, provides extra support avenue giving them quality time as and when needed 

Learners can self-declare at sign up stage that they require support or tutor can refer them 

Care leaver support and bursary access – learners highlight if they are residing in care or a recent care leaver. This is alerted to the ASN team, who work with the learner to check bursary eligibility, provide support and facilitate access to and guidance for use of the bursary funding  

Online Safety is being aware of the nature of the possible threats that you could encounter whilst engaging in activity through the Internet. These are based around the 4 areas of e-safety –  conduct, content, contact and commerce These could include security threats, protecting and managing your data, online reputation management, and avoiding harmful or illegal content. These might manifest as online abuse, bullying, threats, impersonation, grooming, harassment or exposure to offensive and/or violent content. We educate learners around online dangers of this nature through a variety of avenues including our Life Skills learning module and remote taught sessions in relation to conduct and content of the session including appropriate behaviours. This is inclusive of supporting learners understanding of using both Puzzled Education and their own devices. To ensure we monitor and act upon accessing of inappropriate content and comments, filtering systems are in place on employee and distributed learner devices to restrict access to illegal and unsuitable content and our social media platforms.

Child on Child abuse/ Sexual Harassment and Violence between children. 

As a result of Ofsted’s review into sexual abuse in schools in 2021, a range of interventions have been applied to educate and support learners around identification and accessing support around sexual harassment and abuse. Puzzled Education takes a zero-tolerance approach to sexual harassment and abuse, and while we have noted that concerns are alerted to us through the safeguarding reporting process, including those by perpetrators under investigation, acknowledge that this may underrepresent issues that our learners encounter. Tutors are provided with training on indicators and support avenues as part of the safeguarding support process. Annual CPD is also provided to refresh knowledge This training includes identification of and action required for incidents of this nature alongside what learners might view as accepted norms, and what constitutes sexual harassment and abuse both face-to-face and online. This includes sexual harassment and violence in the workplace. Any concerns of this nature ( including those alerted to us by a perpetrator under investigation ) should be reported to the safeguarding team at enquiries@Puzzledtraining.co.uk, so a designed safeguarding officer can support any internal workplace and external reporting procedures and/ or required education. Where required the DSO can work with partnership teams to ensure importance is highlighted with s, and suitable investigations are in place by an employer 

Physical Health 

Physical health describes the condition of our body and encompasses illness, injury, and health conditions, acute or chronic. Where a learner discloses any physical health support needs, they will be supported appropriately to both access, progress with and complete their apprenticeship. This may involve supporting learners’ employers with adjustment awareness 

Mental Health 

The increased importance of supporting poor mental health has been seen through the increased prevalence of mental health concerns raised by learners both as a sole issue and also as an associated issue as a result of experiencing another safeguarding issue. All learners have access to the Learner Welfare Helpline which provides counselling if required and are provided with bespoke support where required. They are encouraged to seek support from their employers, where appropriate, who in the main, have robust support networks in place.

Learner Accidents

If an accident occurs in the workplace, the overall responsibility to investigate lies with the employer, but Puzzled Education will still investigate the incident to ensure the workplace are supporting them appropriately. If an accident occurs out of the workplace whilst under the supervision of Puzzled Education, Puzzled Education have the overall responsibility to investigate the tutor is to complete the accident reporting form

Learner Risk Assessment 

To ensure Puzzled Education supports the health and safety of all learners, in certain situations Puzzled Education may risk assess support requirements for learners, e.g. if a medical condition has been declared, has been subject to sexual harassment/violence or is on bail. 

Where Puzzled Education acts as a subcontract to other companies, we commit to upholding the policies and procedures of the training provider/college which holds the funding. Puzzled Education will also attend any relevant training/updates, adhere to monitoring requirements, be aware of and adhere to funding regulations as set out by the different funding authorities. 

13. Leadership and Management 

Feedback received through learner surveys is analysed and informs policy updates, staff training, and support strategy refinements, ensuring a cycle of continuous improvement.

14. Associated policies 

VersionDateAuthorSummary of Change
V1.0June 2024K AkkersInitial Policy Issued
V1.1June 2025C PyleUpdated KCSIE reference, digital boundaries added

APPENDIX A 

List of posts that require appropriate type of DBS and barring list check

LTG PostNo Check Basic DBSEnhanced DBSEnhanced DBS with Child barred 
Main learner-facing teams (e.g. Tutors, Learner support tutors, AR)   ✓  
Designated Safeguarding officers    ✓  
Potential to be learner-facing (e.g. Area Managers & Engagement Leads)   ✓  
Learner contact with potential influence  ✓   
Employees with access to CRM and Government contract information  ✓    
Other Support functions  ✓     

Appendix B 

Statement on the secure storage , handling, use, retention and disposal of disclosures and disclosure information 

General principles 

As an organisation using the Disclosure and Barring Service (DBS) to help assess the suitability of applicants for positions of trust, Puzzled Education complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of disclosures and disclosure information. It also complies fully with its obligations under the Data Protection Act and other relevant legislation pertaining with the safe handling, use, storage, retention and disposal of DBS disclosure information. 

Storage and access 

Disclosure information is never kept on an applicant’s personnel file and is always kept separately and securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties. 

Handling 

In accordance with section 124 of the Police Act 1997, disclosure information is only passed to those who are authorised to receive it in the course of their duties. The HR Team will be responsible for maintaining a record of all those to whom disclosures or disclosure information has been revealed. It is recognised that it is a criminal offence to pass this information to anyone who is not entitled to receive it. 

Usage 

Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given. 

Retention

Once a recruitment (or other relevant) decision has been made, Puzzled Education may retain disclosure information to cross check 3 yearly DBS refresher disclosures Throughout this time, the usual conditions regarding safe storage and strictly controlled access will prevail. 

Disposal 

Once the employee leaves Puzzled Education Puzzled Education will ensure that any disclosure information is immediately destroyed by secure means, i.e. by shredding or confidential waste disposal. While awaiting destruction, disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). Puzzled Education will not keep any photocopy or other image of the disclosure or any copy or representation of the contents of a disclosure. However, Puzzled Education will keep a record of the date of issue of a disclosure, the name of the subject, the type of disclosure requested, the position for which the disclosure was requested, the unique reference number of the disclosure and the details of the recruitment decision taken. 

Appendix C

DBS Disclosure process 

Potential candidates are also told prior to and during the interview stage they will be subject to a DBS check and asked to declare anything at the interview stage that they feel is relevant in this area. 

Wherever possible the DBS disclosure should be obtained prior to the individual commencing employment, but sometimes this may not be possible. In such cases the individual can commence employment but only on a supervised basis for those aspects of the job involving contact with children or adults at risk until such time as a satisfactory disclosure report is received. 

In some cases, an applicant may already have received a satisfactory disclosure report for their current or previous position at Puzzled Education. It may be appropriate to use the existing report to assess suitability for the post, taking into account the date the report was produced and the similarities between the two positions. A member of the Management Team should be consulted in such cases. 

Disclosure reports for applicants with a substantial record of overseas residence, including current UK residents and British nationals, may not include information on convictions from outside the UK. In most circumstances, however, a disclosure report should still be sought. The DBS can also offer guidance on the availability of criminal record checks in a variety of foreign countries and the applicant can be requested to obtain the equivalent checks from the country in question, where available. 

Appendix D

Reporting and safeguarding issues

1. Recognise

Be alert to signs of abuse, neglect, or a safeguarding issue. This could include physical, emotional, sexual abuse, poor mental health, self-harm, changes in behaviour, or disclosure by the learner.

2. Respond

React calmly and reassure the individual. Do not promise confidentiality. Listen without judgement or leading questions. Explain that you need to share the concern with the safeguarding team.

3. Record

Make a factual, timely record of what was seen, heard, or disclosed. Use the safeguarding disclosure form or make dated, signed notes including who, what, where, and when.

4. Report

Contact a Designated Safeguarding Officer as soon as possible. Send the record securely (e.g., via email to enquiries@puzzledtraining.co.uk). Do not investigate the concern yourself.

5. Refer

The Designated Safeguarding Officer will assess the concern and decide on referral. This could include Early Help, Local Authority services, police, or other agencies.

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