Child Protection Policy

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Document Title

Child Protection Policy

Policy status


Date of Issue

September 2023

Date to be revised

September 2024

This is a core policy that forms part of the induction for all staff. It is a requirement that all members of staff have access to this policy and sign to say they have read and understood its contents

This policy will be reviewed at least annually and/or following any updates to national and local guidance and procedure.

Key Contacts


Designated Safeguarding Lead (DSL)

Victoria Hayes

Deputy Designated Safeguarding Lead

Nicole Galinis, Sophie Smith, Steph Bransgrove

Looked After Children Coordinator

Nicole Galinis

Mental Health Lead

Nicole Galinis

Medical Needs Lead

Steph Bransgrove

Key Contacts



Nicole Galinis

Safeguarding Link Governor

Mary Taylor

Trust Safeguarding Lead

Emma Elwin

Trust Director – Safeguarding

Graham Clewes

What to do if you have a welfare concern in Hartley Primary Academy

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1) Introduction and Ethos

Hartley Primary Academy recognises our statutory responsibility to safeguard and promote the welfare of all children. Safeguarding is everybody’s responsibility and all those directly connected (staff, volunteers, governors, leaders, parents, families, and learners) are an important part of the wider safeguarding system for children and have an essential role to play in making this community safe and secure. 

Staff working with children at Hartley Primary Academy will maintain an attitude of ‘it could happen here’ where safeguarding is concerned. 

We believe that the best interests of children always come first. All children (defined as those up to the age of 18) have a right to be heard and to have their wishes and feelings taken into account and all children regardless of age, gender, ability, culture, race, language, religion or sexual identity, have equal rights to protection. 

We recognise the importance of providing an ethos and environment within Hartley Primary Academy that will help children to be safe and feel safe. In our academy children are respected and encouraged to talk openly. All our staff understand safe professional practice and adhere to our safeguarding policies. 

Our core safeguarding principles are: 

  • Prevention – positive, supportive, safe culture, curriculum and pastoral opportunities for children, safer recruitment procedures. 
  • Protection – following the agreed procedures, ensuring all staff are trained and supported to recognise and respond appropriately and sensitively to safeguarding concerns.
  • Support – for all learners, parents and staff, and where appropriate specific interventions are required for those who may be at risk of harm. 
  • Working with parents and other agencies – to ensure timely, appropriate communications and actions are undertaken when safeguarding concerns arise. 

Hartley Primary Academy expects that if any member of our community has a safeguarding concern about any child or adult, they should act immediately. 

This policy is implemented in accordance with our compliance with the statutory guidance from the Department for Education, ‘Keeping Children Safe in Education’ 2023 (KCSIE) which requires individual schools and colleges to have an effective child protection policy. 

The procedures contained in this policy apply to all staff, including governors, temporary or third-party agency staff and volunteers) and are consistent with those outlined within KCSIE 2023. 

2) Policy Context 

This policy has been developed in accordance with the principles established by the Children Acts 1989 and 2004 and related guidance. This includes: 

  • DfE Keeping Children Safe in Education 2023 (KCSIE) 
  • Working Together to Safeguard Children 2018 (WTSC) 
  • Ofsted: Education Inspection Framework’ 2019 
  • Framework for the Assessment of Children in Need and their Families 2000) 4
  • Kent and Medway Safeguarding Children Procedures (Online)
  • Early Years and Foundation Stage Framework 2021 (EYFS) 
  • The Education Act 2002 
  • The Education (Independent School Standards) Regulations 2014 
  • Sexual Violence and Sexual Harassment Between Children in Schools and Colleges 2021 
  • Human Rights Act 1998 and the Equality Act 2010. 

Section 175 of the Education Act 2002 requires school governing bodies, local education authorities and further education institutions to make arrangements to safeguard and promote the welfare of all children who are pupils at a school, or who are students under 18 years of age. Such arrangements will have to have regard to any guidance issued by the Secretary of State. 

We acknowledge that some learners, during the period of the pandemic and subsequently, may have been exposed to a range of adversity and trauma including bereavement, anxiety and in some cases increased welfare and safeguarding risks. We will work with local services (such as health and the local authority) to ensure necessary services and support are in place to support learners.

3) Definition of Safeguarding 

In line with KCSIE 2023, safeguarding and promoting the welfare of children is defined for the purposes of this policy as: 

  • protecting children from maltreatment 
  • preventing impairment of children’s mental and physical health or development
  • ensuring that children grow up in circumstances consistent with the provision of safe and effective care, and 
  • taking action to enable all children to have the best outcomes. 

Hartley Primary Academy acknowledges that safeguarding includes a wide range of specific issues including (but not limited to): 

  • Abuse and neglect
  • Bullying, including cyber bullying
  • Children with family members in prison
  • Children Missing Education (CME)
  • Children missing from home or care
  • Child on child abuse
  • Child Sexual Exploitation
  • Child Criminal Exploitation (CCE)
  • Contextual safeguarding (risks outside the family home)
  • County lines and gangs
  • Domestic abuse
  • Drugs and alcohol misuse
  • Fabricated or induced illness
  • Faith abuse
  • Gender based abuse and violence against women and girls 
  • Hate
  • Homelessness
  • Human trafficking and modern slavery
  • Mental Health
  • Nude or semi-nude image sharing, aka youth produced/ involved sexual imagery or ‘sexting’
  • Online Safety
  • Preventing radicalisation and extremism
  • Private fostering
  • Relationship abuse
  • Serious violence
  • Sexual violence and sexual harassment
  • Sexting
  • So-called honour-based abuse including Female Genital Mutilation (FGM) and forced marriage
  • Upskirting

4) Related Safeguarding Policies

This policy is one of a series related to safeguarding and should be read and actioned in conjunction with the policies as listed below:

Trust Policies

Academy Policies

  • Staff Code of Conduct
  • Searching, screening and confiscation
  • Online safety
  • Data protection & Information Sharing Policy
  • Health and Safety Policy including Risk Assessment Policy
  • Managing Allegations Against Staff, including Low Level Concerns
  • Whistleblowing
  • Safer Recruitment Policy
  • First Aid Policy
  • Behaviour Policy
  • Anti-bullying Policy
  • Acceptable Use Templates/ Policy
  • Relationship and Sex Education (RSE)
  • Attendance Policy

5) Policy Compliance, Monitoring and Review 

Hartley Primary Academy will review this policy at least annually. The policy will be revised following any national or local policy updates, in conjunction with the Leigh Academies Trust (LAT) Safeguarding Lead, along with any significant national events, local child protection concerns and/or any changes to our procedures.

All staff (including temporary staff and volunteers) will be provided with a copy of this policy and Annex A of KCSIE 2023. This policy can be found on the academy website. 

Parents/carers can obtain a copy of this Child Protection Policy and other related policies via the academy website. 

The academy Principal will ensure regular reporting on safeguarding activity and systems to the Academy Board. Neither the Academy Board nor individual members will receive details of individual learner situations or identifying features of families as part of their oversight responsibility. The Trust will monitor child protection and safeguarding activity through the commissioning of external reviews, termly DSL forums and regular modular reviews of the academy performance.

6) Key Responsibilities 

The Academy Board members will read and will follow KCSIE 2023. 

All Academy board members will attend the regular safeguarding training they are offered which will equip them with the knowledge to provide strategic challenges to test and assure themselves that the safeguarding policies and procedures are effective and support the delivery of a robust whole school approach to safeguarding. 

The academy has a nominated governor responsible for safeguarding. The nominated governor will support the DSL and have oversight in ensuring that the academy has an effective policy which interlinks with other related policies; that locally agreed procedures are in place and being followed; and that the policies are reviewed at least annually and when required. The academy safeguarding governor will make regular visits to review procedures that are in place and provide reports to the Academy Board. A copy of the Link Governor for Safeguarding roles and responsibilities can be found here. 

The Academy Board, LAT Trust Executive and academy leadership team will ensure that the Designated Safeguarding Lead (DSL) is supported in their role.

6.1) Designated Safeguarding Lead (DSL) 

Hartley Primary Academy has appointed a member of the senior leadership team as the Designated Safeguarding Lead (DSL). The DSL has overall responsibility for the day-to-day oversight of safeguarding and child protection systems in the academy. 

The academy has appointed Deputy DSL/s who will have delegated responsibilities and act in the DSLs absence. 

Leigh Academies Trust maintains records of all designated staff for reference and use at Trust level. 

Whilst the activities of the DSL may be delegated to the deputies, the ultimate lead responsibility for safeguarding and child protection remains with the DSL and this responsibility will not be delegated.

The DSLs will undergo appropriate and specific training to provide them with the knowledge and skills required to carry out their role. Deputy DSLs will be trained to the same standard as the DSL. The DSLs training will be updated formally every two years, but their knowledge and skills will be updated through a variety of methods at regular intervals and at least annually. 

The Principal will be kept informed of any significant issues by the DSL. 

The DSL (and any deputies) will be provided with sufficient time so they can provide appropriate support to staff and children regarding any new safeguarding and welfare concerns. This may include handling of referrals to integrated social care and working with other agencies where appropriate. 

It is the role of the DSL to: 

  • Act as the central contact point for all staff to discuss any safeguarding concerns 
  • Maintain a confidential recording system for safeguarding and child protection concerns
  • Coordinate safeguarding action for individual children 
  • When supporting children with a social worker or looked after children the DSL should have the details of the child’s social worker and the name of the virtual school head in the authority that looks after the child (with the DSL liaising closely with the designated teacher) 
  • Liaise with other agencies and professionals in line with KCSIE 2023 and WTSC 2018
  • Ensure that locally established procedures as put in place by the three safeguarding partners including referrals, are followed, as necessary. 
  • Represent, or ensure the academy is appropriately represented at multi-agency safeguarding meetings (including Child Protection conferences) 
  • Manage and monitor the academy role in any multi-agency plan for a child.
  • Be available during term time (during academy hours) for staff in the academy to discuss any safeguarding concerns. 
  • Help promote educational outcomes by sharing the information about the welfare, safeguarding and child protection issues that children, including children with a social worker, are experiencing, or have experienced, with teachers and academy leadership staff. 
  • Ensure adequate and appropriate DSL cover arrangements in response to any closures and out of hours and/or out of term activities. 
  • Ensure all staff access appropriate safeguarding training and relevant updates in line with the recommendations within KCSIE (2023)

6.2) Members of Staff 

All members of staff have a responsibility to: 

  • Provide a safe environment in which children can learn. 
  • Be prepared to identify children who may benefit from early help. 
  • Understand the early help process and their role in it. 
  • Understand their academy safeguarding policies and systems. 
  • Undertake appropriate training which is regularly updated. 
  • Be aware of the process of making referrals to children’s social care and statutory assessment under the Children Act 1989. 
  • Know what to do if a child tells them that he or she is being abused or neglected and understand the impact abuse and neglect can have upon a child.
  • Be able to identify and act upon indicators that children are experiencing, or at risk of developing, mental health issues. 
  • Know how to maintain an appropriate level of confidentiality. 
  • Be aware of the indicators of abuse and neglect so that they can identify cases of children who may need help or protection. 
  • Read and adhere to the Trust’s staff code of conduct. 

6.3) Children and Young People 

Children and young people (learners) have a right to: 

  • Feel safe, be listened to, and have their wishes and feelings taken into account. 
  • Contribute to the development of academy safeguarding policies and procedures.
  • Receive help from a trusted adult 
  • Learn how to keep themselves safe, including when online 
  • Be accompanied by an appropriate adult when involved in police investigations carried out on/in the academy premises. 

6.4) Parents and Carers 

Parents/carers have a responsibility to: 

  • Understand and adhere to the relevant academy policies and procedures. 
  • Talk to their children about safeguarding issues and support the academy in their safeguarding approaches. 
  • Identify behaviours which could indicate that their child is at risk of harm including online.
  • Seek help and support from the academy or other agencies.

7) Recognising Indicators of Abuse and Neglect 

All staff are made aware of the definitions and indicators of abuse and neglect as identified by Working Together to Safeguard Children (2018) and Keeping Children Safe in Education 2023. 

Hartley Primary Academy recognises that when assessing whether a child may be suffering actual or potential harm there are four categories of abuse: 

  • Physical abuse 
  • Sexual abuse 
  • Emotional abuse 
  • Neglect 

For additional information see Annex B Further information (KCSIE 2023). 

All members of staff are expected to be aware of and follow this approach if they are concerned about a child:

‘What to do if you are worried a child is being abused’ 2015 

Members of staff are aware that concerns may arise in many different contexts and can vary greatly in terms of their nature and seriousness. The indicators of child abuse and neglect can 

vary from child to child. Children develop and mature at different rates, so what appears to be worrying behaviour for a younger child might be normal for an older child. 

It is important to recognise that indicators of abuse and neglect do not automatically mean a child is being abused; however all concerns should be taken seriously and explored by the DSL on a case-by-case basis. 

The academy recognises that some children have additional or complex needs and may require access to intensive or specialist services to support them. 

Parental behaviours’ may also indicate child abuse or neglect, so staff should also be alert to parent-child interactions or concerning parental behaviours; this could include parents who are under the influence of drugs or alcohol or if there is a sudden change in their mental health. 

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn. 

Children may report abuse happening to themselves, their peers or their family members. All reports made by children to staff will be taken seriously and will be responded to in line with this policy. Staff should recognise that children may not feel ready to or know how to tell someone they are being abused, exploited or neglected. 

Safeguarding incidents and/or behaviours can be associated with factors outside the academy and/or can occur between children offsite. Children can be at risk of abuse or exploitation in situations outside their families. Extra-familial harms take a variety of different forms and children can be vulnerable to multiple harms including (but not limited to) sexual exploitation, criminal exploitation, and serious youth violence.

By understanding the indicators of abuse and neglect, we can respond to problems as early as possible and provide the right support and services for the child and their family. 

If deemed necessary by the Principal or by staff authorised by the Principal following a concern about a child’s safety or welfare, the searching and screening of children and confiscation of any items, including electronic devices, will be managed in line with the academy ‘Searching, Screening and Confiscation’ Policy and behaviour policy, which is informed by the DfE Searching, screening and confiscation at schoolguidance.

8) Child Protection Procedures 

If staff are made aware of a child protection concern, they are expected to: 

  • listen carefully to the concern and be non-judgmental; 
  • only use open questions to clarify information where necessary, e.g. who, what, where, when or Tell, Explain, Describe (TED); 
  • not promise confidentiality as concerns will have to be shared further, for example, with the DSL and potentially Integrated Children’s Services; 
  • be clear about boundaries and how the report will be progressed; 
  • record the concern in line with the academy record keeping requirements (see section 9); 
  • inform the DSL (or deputy), immediately using Bromcom safeguarding module. If this is not possible, please tell them face-to-face. 

Hartley Primary Academy adheres to the 

  • Kent Safeguarding Children Multi-Agency Partnership procedures (KSCMP). The full KSCMP procedures and additional guidance relating to reporting concerns and specific safeguarding issues can be found on their website:

Hartley Primary Academy is an Operation Encompass School. This means we work in partnership with Kent Police to provide support to children experiencing domestic abuse. 

The academy recognises that in situations where there are immediate child protection concerns identified in line with Support Level Guidance, it is NOT to investigate as a single agency but to act in line with KSCMP guidance which may involve multi-agency decision making. The DSL may seek advice or guidance from their Area Education Safeguarding Advisor from the Education Safeguarding Service before deciding next steps. They may also seek advice or guidance from a social worker at the Digital Front Door. 

If a child is in immediate danger or is at risk of harm, a request for support will be made immediately to Integrated Children’s Services/Medway Social Services (Front Door/ MASH/ SPA) and/or the police in line with KSCMP procedures/ LCP/ Medway Safeguarding Procedures. 

All staff are aware of the process for making requests for support referrals for statutory assessments under the Children Act 1989, along with the role they might be expected to play in such assessments.

In most cases, a request for support will be made by the DSL or a deputy. However if the DSL or a deputy is not immediately available to discuss an urgent concern, staff will seek advice from another member of the academy leadership team or from the Education Safeguarding Service or via consultation with a social worker from the Front Door to do this, staff would phone the following number and ask for a consultation: 03000 41 11 11. If anyone other than the DSL makes a referral to external services, they will inform the DSL as soon as possible. 

In the event of a request for support to the Front Door being necessary, parents/carers will be informed and consent to this will be sought by the DSL in line with guidance provided by KSCMP. Parents/carers will be informed unless there is a valid reason not to do so, for example, if to do so would put a child at risk of harm or would undermine a criminal investigation. 

The DSL will keep all early help cases under constant review and consideration will be given to a request for support to the Front Door if the situation does not appear to be improving or is getting worse. 

If, after a request for support or any other planned external intervention, a child’s situation does not appear to be improving, the DSL will consider following KSCMP escalation procedures to ensure their concerns have been addressed and, most importantly, that the child’s situation improves. DSLs may request support with this via the Education Safeguarding Service.

9) Record Keeping 

All safeguarding concerns, discussions and decisions, and reasons for those decisions, will be recorded in writing on the academy safeguarding incident/concern form/system and pass them without delay to the DSL. 

Child Protection records will record facts and not personal opinions. A body map will be completed if injuries have been observed (this will be done on Bromcom safeguarding module). If members of staff are in any doubt about recording requirements, they will discuss their concerns with the DSL or member of the Safeguarding team. 

The recording of Incident/Welfare concerns will be completed on the Bromcom safeguarding module. If there is no internet, a member of the DSL team will need to be told the concern face-to-face. After a concern has been raised, the DSL will acknowledge the concern and let the referee know the next steps that will be taken. Other members of staff will be updated as appropriate and necessary. 

Records will be completed as soon as possible after the incident/event, using the child’s words and will be signed (electronically) and dated by the member of staff/amend as appropriate. If there is an immediate concern the member of staff should consult with a DSL before completing the form as reporting urgent concerns takes priority. 

Safeguarding records are kept for individual children and are maintained separately from all other records relating to the child in the academy. Safeguarding records are kept in accordance

with data protection legislation and are retained centrally and securely by the DSL. Safeguarding records are shared with staff on a ‘need to know’ basis only. 

All safeguarding records will be transferred in accordance with data protection legislation to the child’s subsequent school, under confidential and separate cover. These will be given to the new DSL and a receipt of delivery will be obtained. 

In addition to the child protection file, the DSL will also consider if it would be appropriate to share any information with the DSL at the new school or college in advance of a child leaving. For example, information that would allow the new school or college to continue to provide support.

10) Multi-Agency Working 

Hartley Primary Academy recognises and is committed to its responsibility to work within the KSCMP multi-agency safeguarding arrangements. The leadership team and DSL will work to establish strong and co-operative local relationships with professionals in other agencies in line with statutory guidance, including Virtual schools heads. 

Academy Name recognises the importance of multi-agency working and is committed to working alongside partner agencies to provide a coordinated response to promote children’s welfare and protect them from harm. This includes contributing to KSCMP processes as required. Such as, participation in relevant safeguarding multi-agency plans and meetings, including Child Protection Conferences, Core Groups, Strategy Meetings, MARACs, Child in Need meetings or other early help multi-agency meetings.

11) Confidentiality and Information Sharing 

Hartley Primary Academy recognises our duty to share relevant information with appropriate agencies in matters relating to child protection at the earliest opportunity as per statutory guidance outlined within KCSIE 2023. 

The Data Protection Act 2018 and GDPR do not prevent the sharing of information for the purposes of keeping children safe. Fears about sharing information must not be allowed to stand in the way of the need to safeguard and promote the welfare and protect the safety of children (KCSIE 2023). 

The Principal or DSL will disclose information about a learner on a ‘need to know’ basis. 

Leigh Academies Trust (LAT) has an appropriately trained Data Protection Officer (DPO) as required by the General Data Protection Regulations (GDPR) to ensure that the academy is compliant with all matters relating to confidentiality and information sharing requirements. The academy also has appropriately trained staff locally to deal with issues related to GDPR. 

All members of staff must be aware that whilst they have duties to keep any information confidential and that they also have a professional responsibility to share information with other agencies to safeguard children. All staff are aware they cannot promise confidentiality in

situations which might compromise a child’s safety or wellbeing.

12) Complaints 

All members of the academy community should feel able to raise or report any concerns about children’s safety or potential failures in the academy safeguarding regime. The academy has a Complaints Procedure available to parents, learners and members of staff and visitors who wish to report concerns or complaints. This can be found on the academy website

Whilst we encourage members of our community to report concerns and complaints directly to us, we recognise this may not always be possible. Children, young people, and adults who have experienced abuse at school can contact the NSPCC ‘Report Abuse in Education’ helpline on 0800 136 663 or via email: 

Staff can also access the NSPCC whistleblowing helpline if they do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285 (8:00 AM to 8:00 PM Monday to Friday) or email 

The leadership team at Hartley Primary Academy and the Trust Executive Leadership team will take all concerns reported in relation to the academy seriously and all complaints will be considered and responded to in line with the relevant and appropriate process. Anything that constitutes an allegation against a member of staff or volunteer will be dealt with in line with section 17 of this policy.

13) Staff Induction, Awareness and Training 

All members of staff have been provided with a copy of Part One of ‘Keeping Children Safe in Education’ (2023) which covers safeguarding information for all staff. Academy leaders, including the DSL will read the entire document and leaders and all members of staff who work directly with children will access Annex A. Staff also have access to the Trust Code of Conduct. 

All members of staff will sign to confirm that they have read and understood the guidance shared with them. This will be undertaken and recorded by the DSL on the HPA safeguarding overview sheet. 

All new staff will receive child protection induction through the Trust People Services team when they are “on boarded”. The academy DSL will ensure they are familiar with local academy policies and procedures on their first day. Volunteers (including agency and third-party staff) receive child protection training and information from the academy DSL or DDSL to ensure they are aware of internal safeguarding processes. 

All staff members (including agency and third-party staff) will receive appropriate child protection training to ensure they are aware of a range of safeguarding issues. This training will include online safety and will take place at least annually. 

In addition to specific child protection training, all staff will receive regular safeguarding and child protection updates at least annually, to provide them with relevant skills and knowledge to safeguard children effectively.

All staff members (including agency and third-party staff) will be made aware of the academy expectations regarding safe and professional practice via the staff code of conduct and acceptable use of IT policies. 

Weekly staff briefings will be used to communicate key safeguarding updates to all staff. Any training will be provided in CPD time for staff. 

Staff will be encouraged to contribute to and shape academy safeguarding arrangements and child protection policies through peer to peer discussion and training events. 

The DSL and Principal will provide an annual report to the Academy Board at its June meeting detailing safeguarding training undertaken by all staff through the academic year and will maintain an up to date register of who has been trained. 

Although Hartley Primary Academy has a designated safeguarding governor for its Academy Board, all members of the Academy Board will access appropriate safeguarding training which covers their specific strategic responsibilities on a regular basis. 

14) Safer Working Practice 

All members of staff are required to work within our clear guidelines on safer working practice as outlined in the staff code of conduct. The DSL will ensure that all staff and volunteers have read the Child Protection Policy and Leigh Academies Trust staff Code of Conduct and understand that their behaviour and practice must be in line with it. 

Staff will be made aware of the academy Behaviour Policy, and where appropriate physical intervention policies, and any physical interventions/use of reasonable force must be in line with agreed policy and procedures and national guidance. 

All staff will be made aware of the professional risks associated with the use of social media and electronic communication (such as email, mobile phones, texting, social networking). Staff will adhere to relevant academy policies including staff code of conduct and Acceptable Use of IT Policies. Staff will be provided with training annually to highlight the risk associated with the use of social media and email.

15) Staff Supervision and Support 

The induction process will include familiarisation with child protection responsibilities and procedures to be followed if members of staff have any concerns about a child’s safety or welfare. 

The academy will ensure that members of staff who are working within the foundation stage are provided with appropriate supervision in accordance with the statutory requirements of Early Years Foundation Stage (EYFS) 2021. Staff should refer to the academy Child Protection Policy for Early Years Settings. 

The academy will provide appropriate supervision and support for all members of staff to ensure that: 

  • All staff are competent to carry out their responsibilities for safeguarding and promoting the welfare of children. 
  • All staff are supported by the DSL in their safeguarding role. 
  • All members of staff have regular reviews of their own practice to ensure they improve over time. 

Any member of staff affected by issues arising from concerns for children’s welfare or safety can seek support from the DSL and wider Trust resources. 

The DSL will also put staff in touch with outside agencies for professional support if they so wish. Staff can also approach organisations such as their Union, the Education Support Partnership or other similar organisations directly.

16) Safer Recruitment 

Hartley Primary Academy is committed to ensure that we develop a safe culture and that all steps are taken to recruit staff and volunteers who are safe to work with our learners and staff. 

  • Hartley Primary Academy will follow relevant guidance in Keeping Children Safe in Education 2023 (Part 3 ‘Safer Recruitment’) and from The Disclosure and Barring Service (DBS). 
  • The LAT Executive Team and leadership team are responsible for ensuring that the academy follows safe recruitment processes outlined within guidance. 
  • The Principal and LAT Executive Team will ensure that at least one person on an interview panel has completed safer recruitment training and that the dedicated safeguarding questions are included in all interview processes. 

The academy, in association with the LAT People Services Team, maintains an accurate Single Central Record (SCR) in line with statutory guidance. 

Hartley Primary Academy is committed to supporting the statutory guidance from the Department for Education on the application of the Childcare (Disqualification) Regulations 2009 and related obligations under the Childcare Act 2006 in schools. 

Staff must disclose any reason that may affect their suitability to work with children including convictions, cautions, court orders, cautions, reprimands and warnings.

17) Allegations Against Members of Staff and Volunteers 

Hartley Primary Academy recognises that it is possible for any member of staff, including volunteers, governors, contractors, agency and third-party staff (including supply teachers) and visitors to behave in a way that: 

  • indicates they have harmed a child, or may have harmed a child 
  • means they have committed a criminal offence against or related to a child 
  • behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children, or
  • behaved or may have behaved in a way that indicates they may not be suitable to work with children. 

In depth information regarding staff allegations can be found within our Procedures for Managing Allegations against Staff policy. This can be found on the academy website. 

All staff and volunteers should feel able to raise concerns about poor or unsafe practice and potential failures in the academy safeguarding processes. The academy leadership team and the LAT Trust Executive take all concerns or allegations received seriously. 

Allegations against staff will be referred immediately to the DSL and or Principal who will contact the Local Authority Designated Officer (LADO) to agree further action to be taken in respect of the child and staff member. 

Low Level Concerns (also outlined in the Allegations Against Staff Policy) must be reported directly to the DSL and Principal. 

In the event of allegations of abuse being made against the Principal, staff are advised that allegations should be reported to the LAT Safeguarding Lead or People Services Director who will contact the LADO. 

All staff and volunteers should feel able to raise concerns about poor or unsafe practice and such concerns will always be taken seriously by the leadership team. All members of staff are made aware of the LAT Whistleblowing procedure which is included in the Managing Allegations Against Staff Policy. It is a disciplinary offence not to report concerns about the conduct of a colleague that could place a child at risk. 

Staff can also access the NSPCC whistleblowing helpline if they do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285 (8:00 AM to 8:00 PM Monday to Friday) or email 

Hartley Primary Academy and LAT has a legal duty to refer to the Disclosure and Barring Service (DBS) anyone who has harmed, or poses a risk of harm, to a child, or if there is reason to believe the member of staff has committed one of a number of listed offences, and who has been removed from working (paid or unpaid) in regulated activity or would have been removed had they not left. The DBS will consider whether to bar the person. 

If these circumstances arise in relation to a member of staff at our academy a referral will be made as soon as possible after the resignation or removal of the individual in accordance with advice from the LADO and LAT People Services Director.

18) Safeguarding Children with Special Educational Needs and Disabilities 

Hartley Primary Academy acknowledges that children with special educational needs (SEN) and disabilities can face additional safeguarding challenges as they may have an impaired capacity to resist or avoid abuse. The DSL will work closely with the SENCO to plan support as required.

The academy will ensure that children with SEN and disabilities, specifically those with communication difficulties will be supported to ensure that their voice is heard and acted upon. 

Members of staff are encouraged to be aware that children with SEN and disabilities can be disproportionately impacted by safeguarding concerns, such as bullying and exploitation. Members of staff must be aware that children with SEN and disabilities may not feel ready or know how to tell someone they are being abused. 

All members of staff will be encouraged to appropriately explore possible indicators of abuse such as behaviour/ mood change or injuries and not to assume that they are related to the child’s disability and be aware that children with SEN and disabilities may not always outwardly display indicators of abuse. To address these additional challenges, our academy will always consider extra pastoral support for children with SEN and disabilities.

19) Safeguarding Children who are Lesbian, Gay, Bi or Trans (LGBT) 

Children who may be LGBT is not itself an inherent risk factor for harm, however the Hartley Primary Academy recognises that children who are LGBT can be targeted by other children. In some cases a child who is perceived to be LGBT by other children (whether they are or not) can be just as vulnerable as those who identify as LGBT. 

These risks can be made worse when children who are LGBT lack a trusted adult. Therefore members of staff must be aware and endeavour to reduce the additional barriers faced, providing a safe place for children to speak out or share their concerns. As part of our PSHE curriculum, differences and different types of relationships are taught about.

20) Child on Child Abuse 

All members of staff at Hartley Primary Academy recognise that children are capable of abusing their peers. The academy believes that abuse is abuse and it will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up” and takes a zero tolerance approach to abuse. All victims will be taken seriously and offered appropriate support, regardless of where the abuse takes place. 

Hartley Primary Academy recognises that child on child abuse can take many forms, including but not limited to: 

  • bullying, including cyberbullying; 
  • physical abuse which can include hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; 
  • sexual violence and sexual harassment; 
  • ‘upskirting’, which typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm; 
  • nude or semi-nude image or video sharing (also known as ‘sexting’ or youth produced/involved sexual imagery); 
  • initiation/hazing type violence and rituals;
  • abuse in intimate personal relationships between peers. 

Staff and leadership recognise that that some child on child abuse issues may be affected by gender, age, ability and culture of those involved, (i.e. for gender based abuse, girls are more likely to be victims and boys more likely to be perpetrators) however, all Child on Child abuse is unacceptable and all reports will be taken seriously. 

In order to minimise the risk of child on child abuse, the academy will: 

  • Implement a robust anti-bullying policy 
  • Provide an age/ability appropriate PSHE and RSE curriculum 
  • Provide a range of reporting mechanisms e.g. worry boxes, dedicated reporting emails monitored by DSLs, online report forms. 
  • All allegations of child on child abuse will be recorded, investigated, and dealt with in line with associated academy policies, including child protection, anti-bullying and behaviour. 

Alleged victims, perpetrators and any other child affected by child on child abuse may be supported by: 

  • Staff at the Academy taking reports seriously, listening carefully, avoiding victim blaming, providing appropriate pastoral support, working with parents/carers, reviewing educational approaches, and in cases of sexual assault, informing the police and/or Front Door

20.1) Child on Child Sexual Violence or Sexual Harassment 

When responding to concerns relating to child on child sexual violence or harassment, the academy will follow the guidance outlined in part five of KCSIE 2023 and the DfE guidance Sexual Violence and Sexual Harassment Between Children in Schools and Colleges (2021) 

It is essential that all victims of sexual violence or sexual harassment are reassured that they are being taken seriously and that they will be supported and kept safe. A victim will never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment or be made to feel ashamed for making a report. 

Immediate consideration will be given as to how best to support and protect the victim and the alleged perpetrator (and any other children involved/impacted). 

When there has been a report of sexual violence or harassment, the DSL will make an immediate risk and needs assessment which will be considered on a case-by-case basis. The risk and needs assessment will be recorded and kept under review and will consider the victim (especially their protection and support), the alleged perpetrator, and all other children, adult students and staff and any actions that are required to protect them. 

Reports will initially be managed internally by the academy and where necessary will be referred to Front door and/or the Police. The decision making and required action taken will vary on a case by case basis, but will be informed by the wishes of the victim; the nature of the alleged incident (including whether a crime may have been committed); the ages and developmental stages of the children involved; any power imbalance between the children; if the alleged incident is a one-off or a sustained pattern of abuse; if there are any ongoing risks to the victim, other children, adult students or academy staff; and, any other related issues or wider context. 

The Principal will provide data relating to sexual violence and sexual harassment in the annual safeguarding report to the safeguarding link governors and the Academy Board. It will also provide information to the LAT safeguarding lead.

20.2 Nude and/or Semi-Nude Image Sharing by Children 

Hartley Primary Academy recognises that nude and semi-nude image sharing (also known as youth produced/involved sexual imagery or “sexting”) is a safeguarding issue; all concerns will be reported to and dealt with by the DSL (or deputy). 

When made aware of concerns involving nude or semi-nude image taking/sharing involving children, staff are advised to: 

  • Report any concerns involving nude or semi-nude image sharing involving children to the DSL immediately.
  • Never view, copy, print, share, store or save the imagery, or ask a child to share or download it – this may be illegal. If staff have already viewed the imagery by accident (e.g. if a child has shown it to them), this will be immediately reported to the DSL.
  • Not delete the imagery or ask the young person to delete it.
  • Not say or do anything to blame or shame any children involved.
  • Explain to the child(ren) involved that they will report the issue to the DSL and reassure them that they will receive appropriate support and help.
  • Not ask the child or children involved in the incident to disclose information regarding the imagery and not share information about the incident with other members of staff, the child(ren) involved or their, or other, parents and/or carers. This is the responsibility of the DSL.

DSLs will respond to concerns as set out in the non-statutory UKICS guidance ‘Sharing nudes and semi nudes: advice for education settings working with young people (2020)’: 

  • The DSL will hold an initial review meeting with appropriate staff and will speak with the children involved if appropriate. 
  • Parents and carers will be informed at an early stage and involved in the process to best support children, unless there is good reason to believe that involving them would put a child at risk of harm. 
  • A referral will be made to ICS and/or the police immediately if:
    • the incident involves an adult (over 18);
    • there is reason to believe that a child has been coerced, blackmailed or groomed, or there are concerns about their capacity to consent (for example, age of SEND);
    • the image/videos involve sexual acts and a child under the age of 13, depict sexual acts which are unusual for the child’s developmental stage, or are violent;
    • a child is at immediate risk of harm owing to the sharing of nudes and semi-nudes. 

All decisions will be recorded in line with our child protection procedures and will be based on the consideration of the best interests of any child involved. The DSL may choose to involve other agencies at any time if further information/concerns are disclosed at a later date. 

21) Gangs, County Lines, Serious Violence, Crime and Exploitation 

Hartley Primary Academy recognises the impact of gangs, county lines, serious violence, crime and exploitation. Any concerns regarding gangs, county lines, serious violence, crime and exploitation will be reported and responded to in line with other child protection concerns.

The initial response to child victims is important and staff will take any allegations seriously and work in ways that support children and keep them safe. 

All staff have been trained and recognise the need to be vigilant for the signs that may include, but not exclusively: 

  • Unexplained gifts/new possessions – these can indicate children have been approached by/involved with individuals associated with criminal networks/gangs. 
  • Children who go missing for periods of time or regularly come home late 
  • Children who regularly miss school or education or do not take part in education 
  • Change in friendships/relationships with others/groups 
  • Children who associate with other young people involved in exploitation 
  • Children who suffer from changes in emotional well-being 
  • Significant decline in performance 
  • Signs of self-harm/significant change in wellbeing 
  • Signs of assault/unexplained injuries

22) Mental Health 

All staff will be made aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation. Staff are aware of how children’s experiences can impact on their mental health, behaviour and education. 

Staff are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. 

If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken by speaking to the DSL or a deputy.

23) Online Safety 

The following is only outlying information, for more detail about this area please see the Online Safety Policy. 

It is recognised by Hartley Primary Academy that the use of technology presents challenges and risks to children and adults both inside and outside of the academy. It will empower, protect and educate the community in their use of technology and establish mechanisms to identify, intervene in, and escalate any incident where appropriate. The DSL has overall responsibility for online safeguarding within the academy but will liaise as necessary with other members of staff. 

Hartley Primary Academy identifies that the breadth of issues classified within online safety is considerable, but can be categorised into four areas of risk (the 4 C’s): 

  • Content – being exposed to illegal, inappropriate or harmful material, for example, pornography, fake news, racist or radical and extremist views 
  • Contact – being subjected to harmful online interaction with other users, for example, commercial advertising as well as adults posing as children or young people
  • Conduct – personal online behaviour that increases the likelihood of, or causes, harm, for example, making, sending and receiving explicit images, or online bullying.
  • Commerce risks such as online gambling, inappropriate advertising, phishing and or financial scams 

Hartley Primary Academy recognises the specific risks that can be posed by mobile technology, including mobile phones and cameras. In accordance with KCSIE 2023 and EYFS 2023 the Academy has appropriate policies in place that are shared and understood by all members of the community. 

23.1) Filtering and Monitoring 

The academy will do all we reasonably can to limit children’s exposure to online risks through the Trust’s IT systems and will ensure that appropriate filtering and monitoring systems are in place and will regularly review their effectiveness: 

  • All users will be informed that use of our systems can be monitored, and that monitoring will be in line with data protection, human rights and privacy legislation. 
  • When implementing appropriate filtering and monitoring, the academy will ensure that “over blocking” does not lead to unreasonable restrictions as to what children can be taught with regards to online teaching and safeguarding. 
  • If learners or staff discover unsuitable sites or material, they are required to inform their class teacher immediately who will inform DSL and IT technician. 
  • Filtering breaches or concerns identified through our monitoring approaches will be recorded and reported to the Principal and Trust IT Services team. 
  • Any access to material believed to be illegal will be reported immediately to the appropriate agencies, including the police. 

23.2) Whole Academy Approach to Online Safety 

Hartley Primary Academy acknowledges that whilst filtering and monitoring is an important part of academy online safety responsibilities, it is only one part of our approach to online safety. 

  • Learners will be supported to use appropriate search tools, apps and online resources as identified following the Trust processes regarding risk assessment. 
  • Learners will be directed to use age appropriate online resources and tools by staff. 

Hartley Primary Academy will ensure a comprehensive whole academy curriculum response is in place to enable all learners to learn about, identify and manage online risks effectively as part of providing a broad and balanced curriculum. These will include: 

  • celebrating Safer Internet Day. 
  • safeguarding assemblies led by the DSL. 
  • through the computing curriculum. 
  • through computing clubs. 
  • membership of National Online Safety – including staff, parents and governors. The academy will build a partnership approach to online safety and will support parents/carers to become aware and alert by: 
    • including online safety resources and updates on our school website. 
    • celebrating Safer Internet Day. 
    • Utilising online webinars and courses on National Online Safety. 

The academy will ensure that online safety training for all staff is integrated, aligned and delivered as part of our overarching safeguarding approach. All staff will receive training, along with annual refresher relating to online safety alongside the safeguarding training they receive. 

The DSL will respond to online safety concerns in line with the child protection and other associated policies such as anti-bullying and behaviour. Internal sanctions and/or support will be implemented as appropriate. Where necessary, concerns will be escalated and reported to relevant partner agencies in line with local policies and procedures.

23.3) Remote Education – Where children are asked to learn online at home in response to a full or partial closure 

Hartley Primary Academy will ensure any remote sharing of information, communication and use of online learning tools and systems will be in line with privacy and data protection requirements: 

  • All communication with learners and parents/carers will take place using academy provided or approved communication channels. See the Online Safety Policy and Acceptable Use Templates. 
  • Staff and learners will engage with remote teaching and learning in line with existing behaviour principles as set out in Acceptable Use Policy for Remote Learning and Online Communication. 
  • Staff and learners will be encouraged to report issues experienced at home and concerns will be responded to in line with our child protection and other relevant policies.
  • When delivering remote learning, staff will follow the academy’s Acceptable Use expectations for Remote Learning and Online Communication. 
  • Parents/carers will be made aware of what their children are being asked to do online, including the sites they will be asked to access. The academy will continue to be clear who from the academy their child is going to be interacting with online. 
  • Parents/carers will be encouraged to ensure children are appropriately supervised online and that appropriate parent controls are implemented at home.

24) Curriculum and Staying Safe 

Hartley Primary Academy will ensure that children are taught about safeguarding, including online safety, as part of providing a broad and balanced curriculum. We recognise that the academy plays an essential role in helping children to understand and identify the parameters of what is appropriate child and adult behaviour; what is ‘safe’; to recognise when they and others close to them are not safe; and how to seek advice and support when they are concerned. 

Our curriculum provides opportunities for increasing self-awareness, self-esteem, social and emotional understanding, assertiveness and decision making so that learners have a range of age appropriate contacts and strategies to ensure their own protection and that of others. 

The academy is aware of the most recent communication from the DfE on the mandatory implementation of Relationships Education, Relationships and Sex and Health Education and has ensured that this is embedded into the curriculum. 

Our academy systems support children to talk to a range of staff. Children will be listened to and heard, and their concerns will be taken seriously and acted upon as appropriate.

25) The Use of Premises by Other Organisations 

Where services or activities are provided separately by another body using the academy premises, LAT Enterprises, or its appointed representatives, will seek written assurance that the organisation concerned has appropriate policies and procedures in place with regard to safeguarding children and child protection, and that relevant safeguarding checks have been made in respect of staff and volunteers. 

If this assurance is not achieved, an application to use premises will be refused.

26) Security 

All members of staff have a responsibility for maintaining awareness of buildings and grounds security and for reporting concerns that may come to light. Staff will be expected to adhere to any safety arrangements implemented for a specific reason. 

Appropriate checks will be undertaken in respect of visitors and volunteers coming into the academy as outlined within guidance. Visitors will be expected to register in and out via the academy reception. Visitors to the site will display either their LAT badge or a visitor’s badge whilst on site. 

Any individual who is not known or identifiable on site should be challenged for clarification and reassurance. 

The academy will not accept the behaviour of any individual (parent or other) that threatens academy security or leads others (child or adult) to feel unsafe. Such behaviour will be treated as a serious concern and may result in a decision to refuse access for that individual to the academy site. If necessary support and advice will be sought from the Police and the academy will assist them as required.

27) Local Support 

All members of staff in the academy are made aware of local support available via the 

Kent Area Safeguarding Advisor: 

  • West Kent: Worrall House, 30 Kings Hill Avenue, West Malling, Kent ME19 4AE
  • Tel: 03000 41 22 84 

Contact details for Online Safety in the Education Safeguarding Service

  • 03000 415797 

Contact details for the LADO 

Integrated Children’s Services 

  • Front door: 03000 411111 
  • Out of Hours Number: 03000 419191 

Kent Police 

  • 101 or 999 if there is an immediate risk of harm 

Kent Safeguarding Children Multi-Agency Partnership (KSCMP) 

Appendix 1: Categories of Abuse 

All staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another. 

Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. They may be abused by an adult or adults or another child or children. It should be noted that abuse can be carried out both on and offline and be perpetrated by men, women and children. 

Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. 

Signs that MAY INDICATE Sexual Abuse 

  • Sudden changes in behaviour and performance 
  • Displays of affection which are sexual and age inappropriate 
  • Self-harm, self-mutilation or attempts at suicide 
  • Alluding to secrets which they cannot reveal 
  • Tendency to cling or need constant reassurance 
  • Regression to younger behaviour for example thumb sucking, playing with discarded toys, acting like a baby 
  • Distrust of familiar adults e.g. anxiety of being left with relatives, a childminder or lodger
  • Unexplained gifts or money 
  • Depression and withdrawal 
  • Fear of undressing for PE
  • Sexually transmitted disease 
  • Fire setting 

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. 

Signs that MAY INDICATE physical abuse 

  • Bruises and abrasions around the face 
  • Damage or injury around the mouth 
  • Bi-lateral injuries such as two bruised eyes 
  • Bruising to soft area of the face such as the cheeks 
  • Fingertip bruising to the front or back of torso 
  • Bite marks 
  • Burns or scalds (unusual patterns and spread of injuries) 
  • Deep contact burns such as cigarette burns 
  • Injuries suggesting beatings (strap marks, welts) 
  • Covering arms and legs even when hot 
  • Aggressive behaviour or severe temper outbursts. 
  • Injuries need to be accounted for. Inadequate, inconsistent or excessively plausible explanations or a delay in seeking treatment should signal concern. 

Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone. 

Signs that MAY INDICATE emotional abuse 

  • Over reaction to mistakes 
  • Lack of self-confidence/esteem 
  • Sudden speech disorders 
  • Self-harming 
  • Eating Disorders 
  • Extremes of passivity and/or aggression 
  • Compulsive stealing 
  • Drug, alcohol, solvent abuse 
  • Fear of parents being contacted 
  • Unwillingness or inability to play 
  • Excessive need for approval, attention and affection 

Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely

to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. 

Signs that MAY INDICATE neglect. 

  • Constant hunger 
  • Poor personal hygiene 
  • Constant tiredness 
  • Inadequate clothing 
  • Frequent lateness or non-attendance 
  • Untreated medical problems 
  • Poor relationship with peers 
  • Compulsive stealing and scavenging 
  • Rocking, hair twisting and thumb sucking 
  • Running away 
  • Loss of weight or being constantly underweight 
  • Low self esteem

Appendix 2: National Support Organisations 

NSPCC ‘Report Abuse in Education’ Helpline 

Support for staff 

Support for learners 

Support for adults 

Support for Learning Disabilities

Domestic Abuse 

Honour Based Abuse 

Contextual Safeguarding, Peer on Peer abuse, Sexual Exploitation and Criminal Exploitation: 

Substance Misuse 

Mental Health 

Online Safety 

Radicalisation and hate