Safeguarding for Students Aged Under 18
Policy Statement
Provision Overview
Relevant to Safeguarding of persons under the age of 18, Avanti Language Institute operates the following courses and programmes:
— Year round EFL courses to 16 and 17 year olds enrolled on adult courses at Avanti Language Institute
— Year round closed junior groups junior individuals on our Junior Programmes at our school at 1A South Main Street.
As a result of accepting students under the age of 18, Avanti Language Institute must:
— Have child protection policies in place
— Operate safe recruitment procedures and carry out appropriate checks on staff and volunteers
— Have procedures dealing with allegations of abuse against staff and volunteers
— Designate senior members of staff to take lead responsibility on child protection issues
— Ensure that all staff that work with children receive training in child protection issues and that such training is updated at no less than three yearly intervals
— Carry out annual reviews of our policies and procedures.
Entitlement for Students aged under 18
Avanti Language Institute has a legal duty of care to all of our students, especially those who are under 18 years of age. In Ireland the law states that people who work with children have to keep them safe. This safeguarding legislation is set out in legislation prepared by the Department of Children and Youth Affairs in Ireland. The relevant legislation includes The Child Care (Amendment) Act 2015; The Children First Act 2015 and The Children (Amendment) Act 2015.
As such, all of our students aged under 18 have an entitlement to be protected, and our safeguarding policy and procedures apply to all of our students aged under 18, irrespective of race or gender.
Avanti Language Institute is guided in its safeguarding procedures by:
— Best practice and our commitment to excellence in the care of students aged under 18
— Legal responsibilities under laws in the Republic of Ireland in the care of students under 18
— Information and advice from the national Child Protection Agency TUSLA (www.tusla.ie).
Avanti Language Institute has overall responsibility for the introduction of, review and monitoring of safeguarding policies and procedures. In addition, every member of Avanti Language Institute’s staff is responsible for ensuring that the process of ensuring the safety and well-being of students is an ongoing process. Safeguarding should be considered regularly in relation to issues such as: student welfare, health, hygiene and safety.
Terminology
Child Protection: means protecting children from harm and abuse.
Safeguarding: means caring for children appropriately and ensuring they are protected from things and actions that are not in their best interest.
Abuse: all forms of physical or emotional ill treatment resulting in potential or actual harm to a child’s health or well-being.
Adults: all adults working with persons under 18.
Safer Recruitment: recruitment procedures and practices the purpose of which is to prevent the appointment of people who may pose a risk to children; this is an essential part of safeguarding. The robust screening of applicants is proven to act as a deterrent for offenders seeking employment with access to children in order to harm them.
Suitability Checks: checks made to identify any known reasons a person would be considered unsuitable to work with students aged under 18.
Students aged under 18: this policy refers to ‘students aged under 18’ or ‘under 18s’ rather than ‘juniors’ or ‘children’ to make it clear that these requirements apply to all students who have not yet reached their 18th birthday, irrespective of the age of majority in their home country.
Designated Safeguarding Person: On site staff member responsible for daily concerns regarding safeguarding and child welfare.
Designated Safeguarding Lead: Staff member with overall responsibility in the school for safeguarding and child protection.
Statement of Commitment
At Avanti Language Institute, we understand and recognize that:
— The welfare of the child is of paramount importance
— All children and young people under 18, irrespective of age, gender, racial heritage, religious belief or sexual orientation, have the right to equal protection from all types of harm or abuse
— Working in partnership with persons aged under 18, their parents, homestay providers, agencies, group leaders and teachers is essential in promoting the welfare of young people.
Adults’ Responsibilities
All adults are expected to read and follow the policy and procedures as set out in this document. The said policy applies to all members of staff at Avanti Language Institute including those members of staff who are directly employed and also anyone working on behalf of Avanti Language Institute, such as host families, transport and accommodation providers, volunteers, interns and so on.
Policy review
We ensure that this policy is communicated and understood. The key relevant points of the policy are explained to all students upon arrival. Key staff members and details of important safeguarding contacts are also displayed throughout the centres. Our policy and procedures are reviewed annually by the Designated Safeguarding Lead (DSL) and reported to and signed off by a Director of the Institute.
Roles and responsibilities
Responsibilities for the implementation of this policy are as follows:
Persons under 18: Responsible for understanding the policy, looking out for each other and raising any concerns with adults if necessary.
Adults: Responsible for understanding the policy and engaging with its requirements.
Designated persons: A Designated Safeguarding Lead’s role it is to oversee the standards and practices of the Safeguarding Policy, and to provide support for the DSPs. At Avanti Language Institute, there is only one year-round centre at 1A South Main Street, Naas, Co. Kildare is one Designated Safeguarding Person (DSPs) responsible for the implementation of the policies and procedures. They are responsible for the implementation of all procedures as laid out in this document. Their contact details are made known to all staff and students and are also available on the website.
Policy Availability
Avanti Language Institute’s safeguarding policy is available on our website, with a hard copy also available within each centre’s office.
Code of Conduct
This code of conduct must be followed by all Avanti Language Institute’s staff, clients, contractors and so on.
Overview
Avanti Language Institute recognises the importance of creating a safe school culture where trust is built between staff and persons under 18 and both are protected from any harmful behaviour. We proactively work to provide a genuine environment of care fostered by robust procedures and recruitment and training activities.
Do’s and Don’ts of Working with Persons Under the Age of 18
Do:
— Remember the safety and well-being of persons under 18 is of paramount importance
— Behave professionally at all times
— Treat everyone with respect
— Listen to children
— Be aware of policies and procedures
— Report any suspicious activity that relates to any potential or actual harm to a person under 18.
Do Not:
— Make inappropriate physical contact
— Use offensive language or language that may be deemed otherwise inappropriate
— Be alone with a person under 18, unless it is unavoidable
— Threaten, raise your voice, be aggressive or intimidating
— Undermine, insult, ignore or make fun of a person under 18
— Allow or let persons under 18 expose themselves to danger
— Take photographs or videos of persons under 18, without the prior knowledge and consent of the senior management of Avanti Language Institute.
Incidents that must be Reported / Recorded
If any of the following occur you should report this immediately to an appropriate member of the Avanti Language Institute staff and have the incident recorded in the school’s Accidents & Incidents record the incident.
— If you accidentally hurt or harm a person under 18 or witness another person hurting or harming a person under 18
— If they seem distressed in any manner
— If a person under 18 misunderstands or misinterprets something you have done.
If a person under 18 has an accident which does not require hospital treatment:
— Management should be notified and monitor the individual
— The under 18’s parent(s) should be notified of the incident at an appropriate time
— A member of Avanti Language Institute staff should be informed immediately. The accident or incident should then be recorded in the Institute’s Accident & Incidents book which is kept in the Institute’s reception.
Responding to Allegations or Suspicions
It is not the responsibility of anyone working in Avanti Language Institute in a paid or unpaid capacity to decide or make a judgement whether or not abuse of a person aged under 18 has taken place. Nevertheless, there is a responsibility to act on any concerns through contact with the appropriate authorities.
Avanti Language Institute assures all staff that it will fully support and protect anyone who reports in good faith, their concern that a colleague is, or may be, harming or abusing a person under 18.
If you do notice anything suspicious, you should report this to the Designated Student Lead (DSL) or a Designated Student Person (DSP) at the Institute.
Do’s and Don’t’s of Responding to Allegations and Suspicions of abuse concerning Persons under 18
Do:
— Stay calm
— Listen carefully to the Person aged under 18 and focus on what they are telling you
— Allow the person the time to express themselves and say what they want to say; use the TED technique – Tell me, Explain to me, Describe to me.
Do Not:
— Panic
— Ask leading questions
— Interrupt, Assume or Paraphrase
— Promise to keep secrets or assure the person under 18 that everything will be OK, as you are in no position to guarantee this.
Internal enquiries and suspension
Should a complaint be made against someone employed directly or indirectly by Avanti Language Institute, the senior management of the Institute will immediately remove the adult from contact with students pending further Garda and TUSLA inquiries. In accordance with the findings of those inquiries the senior management of Avanti Language Institute will assess all individual cases to decide whether a member of staff or volunteer can be reinstated and how this can be sensitively handled. The welfare of the person aged under 18 should remain of paramount importance.
Setting standards
The key elements of our code of conduct are interaction, appearance, intoxicants, IT and social networks, accommodation and transport. We expect all adults working on behalf of Avanti Language Institute to provide an excellent role model for all students in their care and to cultivate a respectful, safe and secure environment for members of staff and students.
Interaction
— All employees of Avanti Language Institute, be they direct or indirect employees, should maintain professional physical and relationship boundaries, and act in a way appropriate to your Duty of Care
— Do not make suggestive or inappropriate remarks to or about any adult or Person under the age of 18. Inappropriate remarks include innuendo, swearing and discussing their or your own intimate relationships
— Other than in exceptional circumstances, do not communicate directly with persons under the age of 18 via email or text messages and only then with the prior consent of the child’s parent(s) or guardian
— Do not engage in behaviour that may be construed as ‘grooming’ a person under the age of 18 — for example giving money, presents or favours or talking or behaving in an inappropriate or unprofessional manner
— As far as possible, avoid putting yourself in a situation where you are on your own with a person under 18
— Conduct all interactions in a calm manner, and avoid shouting at persons under the age of 18, wherever this is possible unless there is a Health and Safety risk
— Ensure any physical contact is within clear boundaries to avoid any allegations of inappropriate touching
— If you are required to be in a one-to-one setting with a person under 18, consider how this can be managed effectively i.e. Leaving a door open, using a room that has a window in the door, positioning yourself within sight of the door and considering if the one-to-one setting is really necessary
— Do not socialise with students under 18 outside of school-organised events.
Appropriate appearance
Adults should present an appearance which:
— Promotes a positive and professional image
— Is appropriate to their role
— Is not likely to be viewed as offensive, revealing or sexually provocative — does not distract, cause embarrassment or give rise to misunderstanding
— Is absent of any political or otherwise contentious slogans — is not considered to be discriminatory.
Alcohol, drugs and smoking
— Do not consume, or allow persons under the age of 18 to consume any alcohol, drugs, cigarettes or intoxicating substances on the school premises or during any activity organized by Avanti Language Institute
— Do not provide alcohol, drugs, cigarettes or intoxicating substances to Persons under the age of 18
— Do not work under the influence of any intoxicants or drugs including alcohol.
IT and social networks
— Do not share your personal social media details with any under persons under the age of 18
— Do not take any images or videos of persons under the age of 18 on your personal recording equipment.
Accommodation
— Understand and abide by Avanti Language Institute’s accommodation rules and guidelines
— Do not enter private areas without first gaining the student’s permission, or in the case of needing to search property, without informing them first and doing so in their presence.
Transport
— Understand and follow the specific guidelines of your centre
— All transport providers, whether staff or contractors, to have appropriate suitability checks.
Child Protection
Overview
We meet our child protection responsibilities by:
— Creating policies and procedures to comply with all regulatory requirements and guidelines
— Reviewing these policies and procedures annually
— Training all staff to an appropriate level of awareness and procedural competence with periodic reviews
— Making all policies and procedures available to all stakeholders.
Designated Safeguarding Person(s) and Lead(s)
Avanti Language Institute currently has two Designated Safeguarding Person (DSP) who works with one Avanti Language Institute Designated Lead (DSL) to ensure a safe environment for our staff and students. Nominated DSPs and DSLs for Avanti Language Institute can be contacted by email or telephone.
All DSPs and DSLs are committed to undertaking during 2016, or have undertaken safeguarding training:
DSP
Shiori McCann
E-mail: shiori@avantilanguage.com
Mobile: 086 228 7513
DSP
Jessica Sanderson
E-mail: elaine@avantilanguage.com
Mobile: 085 788 2165
DSL
Shane McCann
E-mail: shane@avantilanguage.com
Mobile: 086 223 7531
The 24-hour emergency number is 086 223 7531.
All allegations and concerns are reported by the DSP/DSL to the local child safeguarding authority. In all cases, these bodies will advise on next steps and procedures.
TUSLA (Child and Family Agency, Naas, Co. Kildare)
Telephone: 045 882400
Keeping Records
— All serious concerns communicated to the DSP or DSL will be responded to on the same day
— All information regarding allegations of abuse or safeguarding concerns is recorded in writing by the DSP or DSL. A reference is made and dated in the student’s record on the database
— Access to the safeguarding file only available to the DSP and the DSL, and any official outside agency as appropriate
— Details of allegations that are found to have been malicious should be removed from personnel records. However, for all other allegations, it is important that a clear and comprehensive summary of the allegation, details of how the allegation was followed up and resolved, and a note of any action taken and decisions reached, is kept on a person’s confidential personnel file, and a copy provided to the person concerned. The purpose of the record is to enable accurate information to be given in response to any future request for a reference, where appropriate.
It will provide clarification in cases where future disclosures reveal information from the police about an allegation that did not result in a criminal conviction and it will help to prevent unnecessary re-investigation if, as sometimes happens, an allegation resurfaces after a period of time. The record should be retained at least until the person has reached normal retirement age or for a period of 10 years from the date of the allegation if that is longer.
— The DSP/DSL will take advice from the police and local authority social care services to agree the following:
▸Who needs to know and, importantly, exactly what information can be shared
▸How to manage speculation, leaks and gossip
▸What if any information can be reasonably given to the wider community to reduce speculation
▸How to manage press interest if and when it should arise.
If a staff member is accused, the DSP or DSL will then work with the appropriate Social Work Department for advice on appropriate actions to take to ensure the safety of the child.
If a student under the age of 18 or an adult student is accused the DSP/DSL will work with the appropriate Social Work Department for advice on appropriate actions to take to ensure the safety of the child.
Responsibility and Training
The Designated Safeguarding Lead has overall responsibility for ensuring all adults have appropriate training and that this is updated annually. Additional sessions will be organised where deemed appropriate by the Designated Safeguarding Person in consultation with the DSL.
— All adults employed by Avanti Language Institute must attend a Safeguarding training session organised or recommended by MEI (Marketing English in Ireland) and be fully aware of the Avanti Language Institute Safeguarding Policy.
— Staff with access to persons aged under the age of 18 must also be in possession of a recent Garda Vetting check or the Garda Vetting procedure must be in action and the result pending.
— DSP(s) and DSL – at least two members of staff at Avanti Language Institute are expected to complete Safeguarding training coordinated by MEI.
Recruitment
Overview
Every adult who is recruited by the school (including Homestay Hosts, Group Leaders and outside agencies) undergoes a process of suitability checking for work persons under the age of 18, as appropriate to their role and status both through documentation check and the interview and selection process.
Recruitment materials
All Job Descriptions and publicity for vacancies contain a statement that members of staff need to actively engage in looking after U18s safely, that they must follow the safeguarding policy and procedures, and provide appropriate suitability documents.
Recruitment stages
Recruitment stages for all roles with substantial access to persons under the age of 18 will include questions checking the applicant’s awareness of safeguarding. Garda Vetting is necessary for all people recruited by Avanti Language Institute.
Applicants are informed that:
— References will be followed up
— All gaps in CVs must be explained satisfactorily
— Proof of identity and (where applicable) qualifications will be required. Reference requests will ask specifically whether there is any reason that they should not be engaged in situations where they have responsibility for, or substantial access to persons under the age of 18.
Appropriate suitability checks are required before any appointment can be confirmed.
Garda Vetting
In the event that a Garda Vetting check has not been completed by a new employee’s date of commencement in a new job or position, the start date of employment can take place only with restrictions. The decision will be made by the Line Manager, with the agreement of the DSP or DSL and a rationale must be completed and signed by both parties. This judgment will be based on an assessment of the risk compared to the consequences of the decision. If the employee does start work, they must have signed a self-declaration and their interaction with persons under the age of 18 must be supervised at all times.
A Self-Declaration must be signed by all staff prior to working with persons under the age of 18 while the Garda Vetting check is being processed.
Applicants with a criminal record
In the event that a disclosure shows that a potential employee or member of staff has a criminal record, the situation will be judged by the DSP who, in consultation with the DSL will take into account the seriousness and nature of the offence, the nature of appointment, the age of the offence and the frequency of the offence. The disclosure will be discussed with the prospective employee and any decisions made must be in writing and signed by the recruiter and the DSP.
Applicants where a criminal check is not possible
For an Irish individual returning to Ireland after working overseas, a Garda vetting will be completed for their time in Ireland. Extra care will also be taken during the recruitment process to check documentation and references.
Recruitment of Homestays / Host Families
Homestay Hosts and Host Families will agree to Avanti Language Institute’s rules, policies and procedures. One of the Main Hosts, who will always be present overnight when hosting persons under the age of 18, will complete the Garda Vetting process and complete a Self Declaration Form. A self-declaration form will also be completed by all individuals aged 16 and over living in the home.
Single Central Record
A single central record is kept. This will include checks done for Avanti Language Institute.
Alcohol, Drugs & Smoking
— Do not consume, or allow persons under the age of 18 to consume any alcohol, drugs, cigarettes or intoxicating substances, while in the presence of persons under the age of 18
— Do not provide alcohol, drugs, cigarettes or intoxicating substances to persons under the age of 18.
— Do not share your personal social media details with any under 18s
— Do not take any images or videos of under 18s on your personal recording equipment.
Accommodation
— Abide by all accommodation rules
— Do not enter private areas without first gaining the student’s permission, or in the case of needing to search property, without informing them first and doing so in their presence.
Transport
— All transport providers, whether Avanti Language Institute staff or contractors, must have appropriate suitability checks.
Contact Addresses and Telephone Numbers
An Garda Síochána
Kilcullen Road, Naas, Co. Kildare
Telephone: (045) 884 300.
TUSLA (Child and Family Agency)
Social Work Department, St. Mary’s, Craddockstown Road, Naas, Co. Kildare
Telephone: (045) 882 400.
IT and social networks