This publication is largely an update and rehash of the guidance produced on 27th March with the inclusion of changes for the phased return to school planned for June. There is a promise that the guidance will be reviewed again before that date, presumably once the return date is confirmed.
There are few significant changes. The broad safeguarding principles remain the same as in KCSIE and the previous guidance. Local Authorities retain their safeguarding responsibilities and should continue to ensure that schools can access the safeguarding and child protection support they need. Although there may need to be changes in practice and procedures under the Covid crisis and as more children return to school, schools should continue to be safe places for children. To support this, schools should take a whole institution approach to safeguarding and ensure that any new policies or processes do not weaken their approach to safeguarding or undermine the safeguarding policy. There should be clear links between the safeguarding policy, or more practically the addendum created to cover the period of the Covid crisis and lockdown, and
· Any updates from the Safeguarding Partners
· Any update from the Local Authority regarding EHCPs
· Risk assessments for the wider opening of schools
· Health and safety risk assessments
· PREVENT strategy
With regard to the phrased return itself, there is a recognition that all settings’ circumstances will be different, and some will struggle to achieve the small groups necessary for this. These schools should discuss options with the LA or MAT. More importantly, there is recognition of the possible impacts of the lockdown. Schools will need to be aware of new safeguarding concerns that have arisen while children have not been on the school site. Staff need to be aware of these, responsive and act on them immediately and appropriately.
Further, there is a recognition that safeguarding will change as more children return to the school site. Equally it is important that schools do not lose sight of those still at home. This is going to be a be a difficult and demanding balancing act. Schools will need to work with multi-agency colleagues and parents to promote the safety of both groups. The DSL should support teachers and other staff to maintain contact with children not attending the site and their families. There are particular focuses on online safety and the impact of Covid and the lockdown on mental health. The information offered about these issues reflects the guidance issued elsewhere.
Schools should work with parents to ensure that vulnerable children attend school where appropriate. They need to inform a child’s social worker where the child is not attending school. There is recognition that the cohort of vulnerable children might include ‘children and young people on the edge of receiving support from children’s social care services, adopted children, those at risk of becoming NEET (‘not in employment, education or training’), those living in temporary accommodation, those who are young carers and others at the provider and local authority’s discretion.’ This is in part a consideration and acceptance that there will be children who will have to face new or increased risks and vulnerabilities during the period of lockdown. In reality, it is this ‘below the radar’ group that is the greatest concern and challenge for many schools.
The guidance refers to the risks of online abuse and peer on peer abuse and their increased impact and risk for children during this crisis. Schools know that, in addition, there is evidence of a significant increase in the reporting of incidents of domestic abuse during the Lockdown. This is likely to be only the tip of the iceberg with many incidents unreported and more children at risk and suffering abuse. There are also increases in substance misuse, particularly alcohol. Moreover, schools are only too aware that the majority of abuse suffered by children is at the hands of a member of their family. Where children have been shut up with their families out of the sight of schools or other agencies, it has placed many of them at increased or new risk. All these vulnerabilities and risks need to be reflected in schools’ practice and policies, even though they are not highlighted in the government guidance.
The role of the DSL in leading and managing the school’s practice and policies is emphasised. As in the previous guidance, it is identified there might be circumstances where it is not possible for the DSL to be on site. In which case they may be available by phone or video, or DSLs maybe shared between schools. It is key that all staff are clear who the DSL is and how to contact them. If the DSL is not on site, another senior leader should take responsibility for the updating and management of safeguarding files.
There is a recognition that the DSL (and deputies) may need more time to deal with new concerns and update the records for children who were already a source of concern. It is important that schools communicate with parents who are encouraged and supported to share any new risk or vulnerabilities with the school. There is a new element that highlights ‘Where possible staff should try and speak directly to children to help identify any concerns.’ This is picking up on the key concern that where neither schools or other professionals are seeing children, we are relying on the parents to identify, assess and share concerns. This is a particular worry for children who are at risk of abuse from their parents.
Staff should continue to be aware of the risks that adults, including staff and volunteers, may pose to children. Schools need to ensure that their safer recruitment procedures are not compromised by the pressure to recruit in these difficult circumstances. Also, under safer recruitment are reminders about DBS. Schools do not need to get a new DBS for staff who have remained continually employed, even if they have been working off site. Nor do staff changing between roles or settings (e.g. working in hubs on a different site) need a new DBS. However, any new setting must be satisfied that all the appropriate checks, including TRA checks, have taken place. The Single Central Record should be kept up to date and reflect this. There is a suggestion that any risk assessment for new staff to a site could be included in the SCR and this could be updated daily to reflect the staff on site. This is not a requirement.
Schools should maintain safeguarding training, including induction. DSLs will continue to be regarded as trained, even if they miss update training. Online training should be considered, and DSLs should make efforts to stay up to date.
If children are moving schools, it is important that safeguarding and special needs information is shared with the new school, ideally before the child arrives. This should happen at DSL and SENCo level. Data protection does not prevent sharing of information for the purposes of keeping children safe. This is going to become more of an issue as the term goes on and we move towards transition, particularly from Year 6 to Year 7.
Schools should continue to be aware of online safety issues on the school site and take ‘reasonable steps’ to keep those offsite safe online. Staff interacting with children online should continue to look out for and act on signs that a child may be at risk. There is no expectation for the provision of live steam or pre-recorded online lessons. Where these are made, teachers should be aware that this is different to teaching in school and follow the staff code of conduct to protect themselves and the children.
Possible School Actions:
· Review your policy or addendum and update this where necessary as more children return to site. This should be shared with staff and volunteers.
· Ensure that staff and other adults know who the DSL on site that day is and how to contact them.
· Identify vulnerable children, including those just below the thresholds, and work with parents to support their return to school where appropriate. This will include risk assessments and notes of actions.
· Confirm emergency contacts for all children on and off site.
· Consider risk assessments for when it is not possible to speak directly to a child including when to involve social care, police or other agencies to ensure their safety.
· Resume taking your attendance register from 1st June and follow your normal attendance procedures, including first day calling, for those who are expected on the school site. You also need to continue to complete the online Educational Setting Status form which gives the Department for Education daily updates on how many children and staff are attending the school site.
· Review the staff code of conduct and acceptable use policies for online teaching, if you have not already done so using the guidance from the Safer Recruitment Consortium
· Review your reporting procedures for children to raise online safety concerns and do all you ‘reasonably’ can to keep children safe online.
I am offering ‘face to face’ DLS update training online on June 17th, please contact me at seainclusion@btinternet.com for further details.