KCSIE Draft 2026: Changes and Possible Actions for schools

We have finally received the draft/ for information version of Keeping Children Safe in Education 2026. It is deeply frustrating that it has been issued so late in the school year and then accompanied by a rush of other guidance including statutory guidance  on allergies, attendance, mobile phones and regulated activities. This feels both chaotic and disrespectful of teachers’ time and right to a school holiday. However, the good (and bad) news is that the draft version of KCSIE largely reflects the consultation document  we received in February. This comes with the proviso that it may mean that we have a few ‘curve ball’ additions or changes in the final version of the guidance issued in September or even possibly later iterations of the guidance during the school year. For instance, to allow for alignment with the forthcoming guidance on Information Sharing which is under consultation until July 14^th and will come into force in September and any new information on mandatory reporting of Child Sexual Abuse in line with the Crime and Policing Act 2026.

In this blog, I am concentrating on identifying the changes from KCISE 2025 and possible actions for schools in response.

Layout

This is effectively 2 documents in one as the guidance on supporting gender-questioning children in schools is embedded within KCSIE, largely within Part one. Beyond that the familiar five-part structure remains, though Part 5 has been significantly reordered (see below for details) and renamed as ‘Child-on-child sexual harassment and sexual violence’.

It is with the Annexes that the structural changes are evident. There are now only 3 Annexe

• Annexe A: Further Changes

• Annexe B: The Role of the DSL

• Annexe C: Summary of changes

This means that

• The former Annexe A, to be read by staff who had no direct contact with children has been removed. This highlights that safeguarding is the responsibility of all and all staff, regardless of their job description, have a role in safeguarding. They will be required to read the whole of Part 1 of KCSIE.

• The information from Annexe D on homestays has been moved into Part 3 on Safer Recruitment.

• The former Annexe E has also been removed as it focused on Statutory guidance - Regulated activity (children) - Supervision of activity with children which is regulated activity when unsupervised. Following from the Crime and Policing Act 2026 all those (staff and volunteers) involved in regulated activity need to be DBS checked and the loophole about supervision has been closed. For schools, this almost exclusively relates to volunteers. It is covered in detail in Part 3 and the specific guidance issued in June.

There is a very short summary version of Part 1 on the website. It clearly states that this ‘is intended to complement, not replace, any part of the guidance.’ Its exact purpose is not clear.

Language and definition changes

These are often very telling about the thinking behind the guidance. The key changes I have identified are:

• On page 5, the document is explicitly linked with the EYFS documentation.

• Para 2 highlights that children means everyone under  the age of 18, rather than includes everyone under the age of 18. This may be to reflect the learning from  Protecting all vulnerable babies better, National safeguarding practice review into the death of baby Victoria Marten which has been in turn reflected in the updated Working Together to Safeguard Children (March 26) where children are defined as anyone who has not yet reached their 18th birthday e.g. ‘babies, children and young people’ and for some parts of the guidance unborn children

• Early Help is replaced by Community Based Family Help. This brings KCSIE in line with WTSC (Working Together to Safeguard Children). 

• Implicit within the description in paragraph 13 and elsewhere is the implication that DSLs (and possibly others) in schools can and will be asked to take on the role of lead practitioner for these cases (paragraphs 62 and 66).

• In  paragraph 17, there is a clarification that this level of support is before statutory intervention and an extension of those who might benefit from this level of support to include

  •    ‘Those repeatedly removed from the classroom, experienced multiple suspension, on part time timetable, risk of exclusion and in AP or PRU’.

  •   is pregnant and/or is a parent themselves

  • has exhibited early signs of abusive, violent and/or harmful behaviours

  • Risk of being radicalised into terrorism (rather than radicalised or exploited as previously)

  • At risk of exploitation

  • At risk of faith-based prejudice 

• In several places, there is additional information about modern slavery. This is added to the triumvirate of abuse, neglect and exploitation in paragraph 18. It is linked with child sexual exploitation in paragraphs 36-39, and it is given its own section in Annexe A, as well as links in the sections on CCE, CSE and county lines. There are also several references to the National Referral mechanism and the role of the Independent Child Trafficking Guardian. Also, a link in Annexe A to the role of first responders in relation to this issue.

• Additional information in the definition of teenage relationship abuse (TRA) is added in paragraph 20 and includes physical, sexual, emotional abuse, stalking, criminal exploitation (including financial exploitation).

• Child-on-child abuse is consistently extended with the addition of (including harassment and violence).

• In some places, notably under the section on PSED, faith-based prejudice is added under racism and derogatory behaviour or other forms of physical violence and conflict. This is a helpful addition, particularly where schools are facing issues of antisemitism and Islamophobia but sadly is not consistent.

• A note makes clear that when the document is talking about the data protection laws, this includes the Data (Use and Access) Act 2025 in addition to Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR). Thankfully, this saves them all being listed every time they are referred to.

Paragraph 61 emphasises that Data protection laws do not prevent the sharing of information for the purposes of keeping children safe and promoting their welfare. If in any doubt about sharing information, staff should speak to the designated safeguarding lead (or a deputy). Fears about sharing information must not be allowed to stand in the way of the need to safeguard and promote the welfare of children.

• In the consultation having replaced the language of nudes and semi-nudes for the much clearer self-generated intimate images and videos, the DfE has returned to nudes and semi-nudes. They claim that this is more widely understood by young people and best captures the full range of image sharing behaviours included in the guidance. The term  ‘images’ includes all visual content, such as photographs, videos and livestreams. The guidance is clear that it includes all images digitally altered or wholly generated using artificial intelligence, including what are sometimes described as ‘deepfakes’ or ‘deep nudes’ (p.6).

• The term honour or faith-based abuse is used in place of so-called honour-based abuse.

Changes in the definitions of abuse

There are some subtle but important changes to the definitions of different forms of abuse, including

• Physical abuse (para 25) now includes that children may also cause harm to other family members, often referred to as child to parent or care giver abuse.

• Emotional abuse (para 26)  now includes the addition of verbal abuse, such as persistent criticism, belittling, or name-calling

• Sexual abuse (para 27) includes rape or penetration with an object while the reference to oral sex has been removed from the definition of rape.

Key changes

The Role of the DSL (and Information Sharing)

Changes to the role of the DSL are spread across the document and then concentrated (and often repeated) in Annexe B.

The length of  the document- 196 pages- is a clear illustration of the expectations being placed on DSLs and their deputies to read and process all this information. This is partly recognised when we are told that the DSL in addition to the ‘appropriate status, authority’, ‘needs the skills and experience within the school or college to carry out the duties of the post’ (para 126). While this begins to recognise the role is becoming increasingly specialised, there is little to suggest how this should be supported or managed. It is notable that one of the omissions in the guidance is about supervision for DSLs.

There are a few places in the document where ‘and deputies’ has been added and some which are explicit that particular decisions or roles should be completed by the DSL.

The other major changes are

• A reminder about the importance of robust cover arrangements for periods when the designated safeguarding lead is unavailable due to illness, leave, or other circumstances. The guidance suggests the establishment of a confidential shared mailbox, so messages do not get lost into email boxes that cannot be accessed by others (para 127).

• Relate to information sharing

  • Much of this is focused around transitions. When a school is deciding what information to share, they should consider

  • the relevancy of the information, including to the current safeguarding risk,

  • what is necessary for the receiving setting to know, and

  • whether it is clearly presented and appropriately contextualised (para 141)

• There is a particular focus on sharing ‘in advance of the child leaving (a setting), particularly where the information would support an assessment of risk to others in the school, as well as the individual pupil.’ (para 149). For example, where a pupil has previously carried, threatened with, or used a knife or weapon, it is incumbent on the receiving school to assess risk, and accordingly, put in place a safety and support plan for when the child arrives (para 150). This is no doubt in response to the death of Brianna Ghey and others where children have moved between schools without the full information about the risks they may present being disclosed. Paragraph 150 states ‘It would be good practice for a conversation to take place between the designated safeguarding leads at both settings, where there are issues or concerns’.

• It is for the DSL to use their professional judgement about how this information is then shared with other staff. Sharing with the SENCo is particularly mentioned (para 148)

• Professional judgement should be used to ensure that the information shared is focused and proportionate. ‘This may include summarising or omitting information which is not necessary for safeguarding purposes. But care should be taken not to omit information where it may be relevant to understanding or managing safeguarding risk. This is further supported by the new information sharing duty, which is intended to give staff greater confidence to share information appropriately and in a timely way to safeguard children.’ (para 142).

• Paragraph 58 looks at managing any support for the child internally via the school or college’s own pastoral support processes, including considering where doing so does not place the child at additional risk, whether the designated safeguarding lead (or a deputy) should inform parents or carers to further support the child’s wellbeing.

• Also, finally the reference to Skype has been replaced with Teams!

Child-on-child abuse (including harassment and violence)

This divides into 2 parts: the information within Part 5 on child-on-child harassment and violence (the order of this title has been changed!) and within the wider document.

Outside of Part 5

• A key change is the explicit inclusion of misogyny as

  • A form of harmful sexual behaviour (this is also noted in Part 5)

  • A form of child-on-child abuse

  • Part of online safety risks students face

  • Something that requires a zero-tolerance culture (paragraph 158, 191 and 527)

• The guidance also highlights the times when children are at greatest risk from this (para 30-35) and from serious violence (para 49-52) as being immediately after school.

• The list of examples of Child-on-child abuse (para 35 and 191) has been extended to include

  • serious physical assault and harm, or the threat of harm with a weapon

  • Sharing of nudes and semi nudes

• Staff responsibilities to report concerns covers those in and out of school and that issues for both the victim(s) and perpetrator(s) need to be considered. Further that child-on-child abuse is preventable. There is a need to recognise behaviours and indicators of risk and provide timely support. Though there. are little details of how.

• Paragraph 191 also recognises that for some, but not all forms of child-on-child abuse girls are more likely to be victims than boys.

Part 5: Child and child harassment and violence

This part has been substantially re-ordered with some re-writing. The title has changed from sexual violence and harassment to harassment first. This reflects an approach based on Hackett’s Continuum. This is a key document for understanding of these issues and that there occur on a continuum from developmentally normal to problematic and harmful. Here the continuum from Harmful Sexual Behaviours (HSB) to harassment to violence is considered. The issue of HSBs is embedded across this part of the guidance. This makes good sense making this section clearer and more workable. Moreover, it gives it a firmer academic and theoretical framework. The language is also clearer. There is much less ‘it is important to’ and more just stating what we need to know and do.

Paragraph 527 is clear that HSB can occur between 2 or more children and can be directed towards a single child or a group. It is part of a continuum and may escalate into sexual harassment or violence. Schools should additionally be aware of recognising the escalatory nature of misogyny and the benefits of early identification to support their approach to minimising the risk of HSB, sexual harassment and sexual violence,taking a safeguarding approach in response to all incidents involving the sharing of nude or semi-nude images, regardless of whether they are consensual or non-consensual. All such incidents require a safeguarding response, with a proportionate approach that considers the age, development, and circumstances of the children involved, as well as any elements of coercion, exploitation or vulnerability.

Misogyny is explicitly linked with HSB.

When considering when sexual harassment crosses into sexual violence school should talk to and consider the experience of the victim (para 537) . It also emphasises that schools need clear processes and awareness of local services (para 541). They should not be working in isolation (paragraph 548-552) but with other agencies. Paragraphs 568-574 outline how they can work with Universal services and community based Early Help assessments and services and refer to other services including the Families First Partnership Programme (FFP).

Mental health

The information on Mental health has been strengthened and moved from Annexe B (as was) to Part 1 (para 45-48).

• There is clarification that safeguarding concerns about mental health needs could include self-harm, suicidal ideation or risk of suicide. Also, that these could be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

• A reminder that only trained staff should attempt diagnosis and that education staff’s role is to observe. There is a short list of potential warning signs (para 47).

• If a member of staff believes the concern is a safeguarding concern, they should speak to the DSL. But this does not remove the need for a medical or emergency response (para 48).

Mental health needs are picked up again in the section on children potentially at greater risk of harm (starting on page 56). Here it is highlighted that:

• Mental health problems can develop into safeguarding problems. This includes self-harm, signs of an eating disorder, suicidal ideation or suicide. (Para 225)

• Paragraph 226 identifies 4 key roles for education staff.

  • Promoting good mental wellbeing and preventing the onset of mental illness

  • Observing pupils and identifying early those who may be experiencing mental health problems or be at risk of developing one.

  • ensuring early targeted support is provided, and

  • liaison with/referral to specialist services where needed.

• Schools are reminded to use local resources, including Mental Health Support Teams (MHST) to support their pupils (para 230)

• Paragraphs 231 and 232 contain new resources.

Online Safety

There is considerable recognition of the risks associated with AI, deepfakes and misogynistic influencers. Including in paragraph 158 that adds ‘understanding online harms such as sharing images, the prevalence of deepfakes, pornography and misogynistic influencers and when and where to seek help.’ should be taught in RSHE.

Beyond this the key changes in this area are

• Para 168 states ‘All schools should be mobile phone-free environments by default; anything other than this should be by exception only.’  Schools are to implement a policy where children do not have access to their mobile phones throughout the school day.

• An updating of the 4 Cs (para 163)

  • Content  now includes extreme sexual or physical violence

  • Contact  now includes  generative AI applications that simulate this; for example: peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes, 

  • Conduct now includes generative AI explicit images

• More information about AI use and the training available (para 165-166)

• There is also clarification with regard to filtering and monitoring that systems  should be reviewed at least annually and that this should include checks that filtering is working appropriately on all internet-connected devices in all relevant locations, and a record should be kept of these checks. Interestingly, these ‘Reviews should be carried out by the SLT member responsible for filtering and monitoring, with the support of the school’s designated safeguarding lead and IT support.’ This removes them from the sole responsibility of the DSL. (para 171)

• Improved clarity about Information security and access management (para 170-172)

• In Annexe A, the section on Cybercrime includes information on the Computer Misuse Act 1990 and that children can be involved in these actions without understanding the legal or ethical implications and scope of such crime.

Children potentially at greater risk of harm

This is an interesting section starting on page 56 covering a wide range of topics, ending with gender questioning children. Apart from gender questioning, which I consider in detail below, this section includes new information on:

• Children who are absent from education (para 219) This clarifies the link with guidance on CME and includes the information schools must provide to the local authority when removing a child from the school roll at standard and non-standard transition points. In additional how schools should be supporting local authorities with joint reasonable enquiries to help identify and support children missing in education

• Looked after Children and previously looked after children (para 241-243). This section clarifies the role of the Virtual School Head in relation to attendance and its role as a key factor in safeguarding. Virtual School Heads should work with local authorities to set and report on ambitious targets to improve the attendance of their cohort.

• SEND (para 247)Two additional bullet points focused on children with physical needs have been usefully added to the list of additional vulnerabilities faced by children with SEND.

  • the need for intimate care or that these children are isolated from others.

  •  that these children are more likely to be dependent on adults for care

though unfortunately these still do not make much grammatical sense.  Two of the other bullet points have been extended to read

• communication barriers and difficulties in managing or reporting these challenges risks that they do not understand that what is happening to them is abuse,

• these children may have issues over cognitive understanding.

There are 2 important new groups covered in this section:

Young carers 

There is much welcomed new information in paragraph 246 about schools needing to be alert to the needs of young carers, recognising that their caring responsibilities can impact on their attendance, attainment, behaviour and wellbeing. Also, the importance of early identification and support.

Children with medical conditions (para 250)

While recognising that medical conditions (including allergies and conditions requiring delegated healthcare tasks) is not in itself an indicator that a child is at greater safeguarding risk. The links with safeguarding are highlighted as is the need for joint working with healthcare professionals. There is clear links to the new guidance on medical conditions and allergy safety.

Serious Violence and Child Exploitation

The information on Child Exploitation (para 36-42) and Serious Violence(para 49-52) have been expanded  to include:

• An explicit responsibility to report to the DSL where a child is carrying a weapon or expressed an intention to do so. The designated safeguarding lead should assess the risk to both the individual pupil and others in the school, considering wider information or concerns, and take appropriate action. Depending on the risk, they should put in place a safety and support plan, and where relevant, consider action to de-escalate peer conflict. (para 49)

• Links with CCE- the child may also be a victim and may not be able to give consent or recognise what is happening to them (Para 38 and 42).

• The greater risk for those with disrupted education or a history of offending.

• Increased risks at particular times of day, notably immediately after school.

• The need for evidence-based support including resources from Youth Endowment  Fund (YEF).

• There is a focus on the issues of grooming, manipulation and exploitation

• In paragraph 41, there is a useful reminder that most sexual abuse is committed by those known to the victim, not organised gangs.

Operation Encompass

In November 2025, a new statutory duty was placed on the police to notify a child’s education setting, and where relevant, local authorities, if they have reasonable grounds to believe a child may be a victim of domestic abuse. This includes children connected with the household even if they are not present. There is then a list of the information the referral should include. Hopefully, this might act to improve the detail and reliability of Operation Encompass referrals to schools.

Part 3: Safer recruitment

The main changes in Part 3 are around DBS checks and the removal of the exemption for those undertaking regulated activity under supervision. This was covered by specific guidance issued in June regarding these changes which will need focused attention from schools.

Other changes include:

• The need to carry out a search (via an online search engine) rather than an online search (para 299).

• Updated links in paragraph 311 to the DfE Check a teacher site

• Clarification about groups of visitors (para 369)

• If an individual working at a school or college is self-employed, the school or college should either obtain the DBS check, or request to see the certificate if the self-employed person has obtained their own check and ensure that the DBS check is at the level required by the school (para 370).

• Paragraph  373 continues that schools ‘Should check visitor’s DBS for appropriate level depending on the activity they are there to carry out (or that the visitor’s employers have confirmed that their staff have appropriate checks. Schools and colleges should not ask to see the certificate in these circumstances). Where a visitor will have no contact with children, it is unlikely that a DBS check will be required.’ This may need some working out.

• Useful guidance on supervision for those on work experience (para 398-402). The NSPCC produced information on this as well.

• Volunteers who do not need DBS checks will continue to need risk assessments (para 384-387)

• Information about homestays has been removed from the previous Annexe D and included in Part 3.

Part 4: Safeguarding concerns or allegations made about staff, including supply teachers, trainee teachers, volunteers and contractors

The major change here relates to Trainee Teachers. The confusion about the status of trainee teachers within the response to safeguarding concerns and allegations about adults is cleared up. They are firmly included in the information about concerns reaching the harm threshold and low level concerns and possible referrals to the DBS throughout Part 4, in paragraphs 75-77 and reiterated in paragraphs 180-183.

The other changes here are minimal and are mainly to clarify where there is an allegation or low level concern about a supply teacher, trainee teacher or contractor who is not directly employed by the school, the school should still lead on the investigation as they have access to the necessary information. However, they should continue to work directly with the relevant training institution, agency or business who will lead on any disciplinary action (para 452 and 456).

Quick clarifications

• The role of the headteacher or principal in making referrals to the LADO is highlighted in paragraph 76.

• Reasonable force is updated to reflect the restrictive practices guidance which came into force in April 2026 (para 203-205) and clarifies that restraint should be  ‘using no more force than is necessary for the least amount of time’.

• Alternative Provision is updated to reflect current guidance and non-statutory standards. It also reaffirms that the school remains ultimately responsible for safeguarding when a child attends an AP, including safeguarding checks and that the provision is appropriate to meet the child’s needs.

• Children with family members in prison- new information on impacts and links.

• Teenage Relationship Abuse. This is a focus in WTSC and highlighted in paragraph 20.

• Overlapping and multiple harms. This is included in paragraph 29.

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Gender questioning pupils

This is the most controversial part of the new guidance, though little changed from the consultation version. The biggest change from there is clarification about how this guidance affects 6^th form colleges. The information is included in a specific section under the Children potentially at greater risk of harm section that begins on page 56 and sprinkled throughout the rest of the document.

First, to consider the information outside the specific section which is focused on practical and logistical issues with guidance on:

• Sport (in Part 2 para 95-98). This is linked to governors’ responsibilities under the 2010 Equality Act. It considers issues of social transitioning and single sex sporting activities. It ends with the advice: ‘This means that the school or college would need to take into account all the relevant factors, including whether supporting social transition is overall in the best interests of the child, as well as considering the impact on other children and the aim of creating safe and fair environments for children to participate in PE.‘ (para 97)

• Toilets (para 106-116) It states that schools must not allow children into toilets designated for the opposite biological sex. This includes where schools are responding to a request to support any degree of social transition for children who are questioning their gender. (Para 105). Schools must provide separate toilets for boys and girls aged 8 and over, except for toilets designed for use of one pupil at a time (Para 106). Schools should consider the provision of alternative toilets e.g. self-contained toilets for those gender questioning children not wanting to use toilets designated for their biological sex. ‘These alternative arrangements should not compromise the safety, comfort, privacy or dignity of the child, or of other children.’ (para 109)

• Changing rooms and showers (para 112-116). This starts with Schools and colleges must not allow a child, aged 11 years or older at the start of the school year (e.g. Year 7 and above, except where children are out of year group), to undress in front of a child of the opposite biological sex, to comply with their safeguarding duties. When responding to a request to support any degree of social transition this must not include allowing access to changing rooms designated for the opposite sex (para 112). It continues with basically the same advice as with toilets.

• Boarding and residential accommodation (para 192- 196). This covers dormitories, tents or shared rooms on school trips. The bottom line is ‘To comply with their safeguarding duties, schools and colleges must not allow a child to share overnight accommodation with a child of the opposite biological sex. Responding to a request to support any degree of social transition must not include allowing access to boarding or residential accommodation designated for the opposite sex.’(para 198)

While much of the remaining guidance may be helpful to schools and provide the much looked for clarity that has been lacking over a number of years, some of the language and implications are worrying and, in my view, misjudged. While for LGB children, it is recognised that “A child or young person being lesbian, gay, or bisexual is not in itself a risk factor for harm; however, they can sometimes be vulnerable to discriminatory bullying,”  (para 251) the language for those who are questioning their gender is very different,  “Schools and colleges should remain aware of the potential vulnerabilities of children who are questioning their gender, including the possibility of complex mental health and psychosocial needs, for example relating to relationships with family, peers or their broader social environment, including discriminatory bullying.” (para 255). The implication is clear that these children are an inherent and social based risk.

The guidance states that

• Accommodating social transition is an active intervention so schools and colleges should take a very careful approach (para 269).

• Schools should not initiate any action when children are questioning the way they feel about being a boy or a girl. (para 253). They should only act in response to a request from a child or their parents.

• Schools and colleges should consider adopting policies across school and college life that maintain flexibility and avoid rigid rules based on gender stereotypes (para 256).

• All decisions relating to social transitions should follow a policy, should be documented and a record kept (para 251). It should balance safeguarding, human rights and equality legislation and the best interests of the child and welfare and safeguarding of all children (para 259-60). This is reasserted in paragraph 268 where schools are asked to consider if policies place a gender questioning  child or children at a disadvantage relative to other children.

• In the vast majority of cases, schools should work with the parents to determine the best interests of the child (para 254 and 266) including considering clinical and other professional evidence and advice. There is a recognition of the rare circumstances where involving parents or carers would constitute a greater risk to the child than not involving them, the school or college should involve their Designated Safeguarding Lead (DSL) to determine what action is needed to safeguard the child, before the parents are contacted or any decisions are taken (para 267). Involvement of parents only applies in cases where there is a request for social transition, if a child is just sharing feelings, staff should respect their confidentiality (para 269).

• Schools should be particularly aware of the safeguarding concerns with primary age children (para 271).

• Having the correct information about a child is important in the context of schools and colleges fulfilling their safeguarding duties, and they should make sure all relevant staff are aware of a child’s biological sex in all cases. Schools and colleges are legally required to record a child’s biological sex accurately wherever it is recorded (Para 280).

  
  

There are number of references (para 265, 278 and by implication in 280 above, plus a paragraph 282) to concerns about children who might be ‘living in stealth’. Meaning in particular those who socially transitioned before puberty, so staff are not aware of the biological sex, so may present safeguarding concerns. Personally, I find this language implying that children would seek to hide their gender by stealth with the implication of the intent to deceive or harm disturbing.

Possible actions for schools

• Establish a shared DSL inbox that can be accessed by the whole DSL/ safeguarding team. You will need to consider how this will be organised, so that it is clear who has read what and when. This should also be monitored during school holidays. It should also be added to the school website, so it is seen as the point of contact for safeguarding for professional colleagues and other searching there for information.

•  Work out how you will ensure that all staff, regardless of role, read and understand Part 1 of KCSIE. This may require specific training aimed at HR and admin, catering, cleaning or site staff who have little or minimal contact with children. LGfL each year produce translations of Part 1 in various home languages which might be supportive.

• Review the school’s policy and procedures regarding volunteers and DBS checks to ensure that all volunteers are checked at the correct level. This will need to include:

  • If any of your current volunteers need re-checking to include barred list check

  • If any of your occasional volunteers reach the frequency measure (more than 3 times in 30 days) because they also volunteer elsewhere

  • Review of risk assessments for any volunteer who does not have a DBS check with your school.

• Ensure the various language and other changes are reflected in your Safeguarding Policy e.g.

  • The definition of a child

  • Replacing Early Help with Community based Family Help

  • More on modern slavery, particularly linked with CSE and CCE

  • Inclusion of language about faith-based prejudice

  • Changing so called honour-based abuse to honour or faith-based abuse

  • The description of data protection laws includes the Data (Use and Access) Act 2025 in addition to Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR). This will impact other policies as well.

  • Changed definitions of physical, emotional and sexual abuse, including that oral sex is removed from the definition of rape.

  • Extended bullet points on the additional vulnerabilities of those with SEND to reflect paragraph 247

• Check that young carers are included.

• Check that your Safeguarding Policy includes the language of nudes and semi-nudes ‘images’ and is explicit that this includes all visual content, such as photographs, videos and livestreams. Further that  all digitally altered or wholly generated  images using artificial intelligence, including what are sometimes described as ‘deepfakes’ or ‘deep nudes’ are included within the policy.   

• Review your school’s information sharing policy and information about the sharing of safeguarding information at transition. I would suggest that this is not done in detail until the new statutory guidance for this area is released in September.

• Review your Safeguarding and Behaviour policies to reflect the latest language and thinking around Child-on-child abuse and Harmful Sexualised Behaviours (HSB), including the re-ordering from sexual harassment to violence.  

• Update your Safeguarding and online policies to reflect the updated version of the 4 Cs.

• Ensure your behaviour policy and use of devices/ phone policy reflects this and the latest guidance. 

• Ensure your safeguarding, behaviour and reasonable force policies are updated to reflect the latest guidance and include that reasonable means ‘using no more force than is necessary for the least amount of time’.

• Link your Safeguarding policy and Policy for children with medical conditions and allergies.

• Consider your procedures relating to the use of Alternative Provision and how this relates to the non-statutory standards released in August 2025.

• Ensure that there is an effective system, with a written policy or protocol for the transfer of safeguarding information, including where pupils move mid-year. This should include where any safeguarding information received from another setting that it is reviewed by an appropriately trained member of staff so that the key risks and needs are clearly understood. Safeguarding information should be used to support, not disadvantage, the child. Where the receiving school or college considers that safeguarding information is unclear or incomplete, it should seek clarification where necessary to support effective safeguarding (Annexe B).

• Clarify the language in your safeguarding policy around the risks of serious violence, including the carrying of weapons or expression of intent to carry weapons. The Staff Code of Conduct should be clear about staff’s responsibilities to share concerns in this area relating to events in and out of school.

• Ensure that you have an appropriate policy for the support of gender-questioning children and procedures for recording any decision made in relation to social transition or requests to use different toilets, changing rooms, etc. There are some questions to consider in this area in paragraph 275.

• Ensure that a clear summary identifying current safeguarding concerns, relevant context, and any ongoing support needs also including information on historic information is included when information is transferred to a new setting (Annexe B).

• Training for staff to ensure that all safeguarding records are clear, factual, and distinguish between observed concerns, professional opinion, and historic information.

• Clarify with staff about when mental health and safeguarding concerns meet.

• Check that you have a clear procedure for filtering and monitoring checks at least annually, who is responsible for them and who they report to.

• Develop clear procedures for working out which visitors require DBS checks and then checking them.

• Consider how all these changes are going to be shared with staff effectively. It is probably too much for a single safeguarding session and may need drip feeding over the next term through focused update sessions.