1 Introduction

The Gloucester house aims to provide a safeguarding culture and environment where pupils feel confident to raise issues and disclose incidents relating to their welfare and safety knowing that staff will respond appropriately to these.

This policy sets out how the Gloucester house will ensure this through safe recruitment practices that ensure only those suitable to work with children are recruited and from holding expectations of high standards of personal and professional conduct from staff.

2 Safer Recruitment-General Principles:

The school/college recognises safer recruitment practices are an essential part of creating a safe learning environment and will carry out the processes set out in this policy to ensure those who are not suitable to work with children are identified during recruitment processes and prevented from taking up posts.

When recruiting staff, Gloucester House and the Tavistock and Portman NHS trust will follow Part 3 of the Keeping Children Safe in Educationguidance (KCSIE) – (DfE 2023).

  • Gloucester House will carry out extensive checks and enquiries on applicants for all positions, including voluntary and support roles and Steering Group members and those involved in the management of an independent school, in accordance with statutory requirements.
  • No staff member, volunteer, Steering Group member or anyone involved in the management of an independent school will be allowed to take up posts until all checks and enquiries required for that position have been satisfactorily completed.
  • Checks with the Disclosure and Barring Service will be carried out at the level appropriate to the candidate’s role in the school (see section 4.3).
  • Staff and governors who are involved in recruitment will receive Safer Recruitment training offered through the Camden or any other accredited training provider and no interview should go ahead unless at least one member of the panel has undertaken safer recruitment training
The following staff have joint responsibility for recruitment and have received relevant Safer Recruitment Training: The Trust HR TeamGloucester House Senior LeadershipIntegrated Schools Operations ManagerSchool Admin ManagerSally Hodges – Chair of Steering Group.
  • Although the head teacher and head of service will have day-to-day responsibility for the recruitment of staff, the Steering group will ensure that they maintain an overview of recruitment systems in order to scrutinise practise and ensure all statutory checks are carried out.
  • Gloucester House and Tavistock Human Resources staff with responsibility for carrying out recruitment checks should ensure they have a copy of any relevant documents or take relevant issue numbers from documents as proof that the document has been seen.
  • Checks will be taken out on existing staff where concerns arise regarding their suitability to work with children or a person moves into a post that is a regulated activity.
  • The HR department and head teacher will be responsible for keeping a single central record of all staff and volunteers who work at Gloucester House and any checks taken out on Steering Group members.
  • The Single Central Records should include details of all checks carried out and the outcome of these checks or any certificates obtained in the format shown at Appendix 1.
  • For any salaried trainee teachers, the Gloucester House will ensure that all necessary checks are carried out on the trainees, including DBS checks, and that the outcome of these checks is recorded on the single central record.
  • For trainee teachers and other trainees that are fee-funded, Gloucester House will obtain written confirmation from the training provider that the necessary checks have been carried out and that the trainee has been judged to be suitable to work with children.
  • Where staff are recruited via third parties such as employment agencies, the head teacher (delegated to the admin manager) and or the Steering Group will:
  • seek written confirmation from the agency that the agency has carried out all necessary checks on the individual
  • request written confirmation of the outcome of all checks
  • request written confirmation that an enhanced DBS certificate has been received by the agency 
  • request a copy of any DBS certificate where information has been disclosed
  • Check the identity of agency staff when they first present for work       to ensure they are person against whom the checks were taken out.

3 Advertising and Recruitment

When recruiting, the Gloucester house will ensure that all advertisements for posts are clear that the role is a safeguarding role for which successful candidates should be considered suitable to work with children and that successful applicants will be expected to agree to undergo DBS and other checks as part of safer recruitment practices.

The Gloucester house will accept applications from the Trusts workforce recruitment platform TRAC Jobs alongside applications via the Times Educational Supplement (TES) platform for teaching staff. Both applications capture important information about the candidate to enable Gloucester house to make informed decisions about their suitability for the role.

3.1 Advertisements

The Gloucester house will ensure the following information is included in any advertisement:

  • a statement of the Gloucester house’s commitment to safeguarding and that all applicants will be subject to checks
  • information about the role (job description/person specification) and the safeguarding responsibilities that are part of the role
  • the skills, experience, knowledge, abilities, attitudes and behaviours required
  • the safeguarding requirements of the role, including level of contact with children and whether the post involves regulated activity
  • whether the post is exempt from the Rehabilitation of Offenders Act 1974 (where specific spent convictions must be disclosed);

For further guidance on exemptions please see:

https://www.gov.uk/government/publications/dbs-filtering-guidance

3.2 Application forms

The Gloucester House and the Trust HR team will ensure all candidates for posts are able to access the Gloucester House child protection policy online so that they are aware of the school/college approach to safeguarding and safer recruitment and the expectations on staff in implementing these. The information will include a clear statement that it is an offence to apply for posts involving regulated activity when barred.

Application forms will ask for the following information:

  • personal details of the candidate including current and former names, current address and national insurance number;
  • details of their present (or last) employment and reason for leaving;
  • full employment history, (since leaving school, including education, employment and voluntary work) including reasons for any gaps in employment;
  • qualifications, the awarding body and date of award;
  • details of referees/references (see section 4.2 for further information);
  • a statement of the personal qualities and experience that the candidate believes are relevant to their suitability for the post and how they meet the person specification.

3.3 Interview and selection

The Gloucester House and the Tavistock HR team will expect candidates who are shortlisted for interview to complete a self-declaration form as shown in Appendix 2. Gloucester House will inform shortlisted candidates that it is likely an online search will be conducted as part of due diligence checks.

One of the key purposes of the interview is to establish whether the candidate is suitable to work with children. For this reason, Gloucester House will structure interviews to enable a full exploration of the candidate’s knowledge, skills and experiences of teaching and/or working with children as well as their attitudes and motivations to safeguarding.

The interview will also explore any unexplained gaps in employment or frequent changes of employment, any information on allegations or disciplinary actions, or any other areas of concern.

4 Checks and vetting for school staff

4.1 Checks to be taken out

The Tavistock Human resources department will take out checks in order to verify the following information for all new staff:

  • The applicant’s identity must be verified from their passport, birth certificate or other photographic ID and proof of address must be provided. The Gloucester house will follow government guidance:

https://www.gov.uk/government/publications/identity-proofing-and-verification-of-an-individual

  • The applicant’s right to work in the UK must be evidenced through documentation.  Only original documentation should be accepted and its validity checked in the presence of the applicant. 
  • Gloucester House and the Trust HR team will follow government guidance:

https://www.gov.uk/government/publications/identity-proofing-and-verification-of-an-individual

  • Where the applicant will be involved in regulated activity, an enhanced DBS check will be taken out, including information from the barred list. If the applicant will begin work before an enhanced DBS check can be completed, a barred list check will be obtained.
  • In the case of teaching staff, checks will be made on the applicant’s academic and vocational qualifications (https://www.gov.uk/guidance/qualified-teacher-status-qts) and further checks made on TRA Teacher Services system  to ensure they are not prohibited from teaching under a teacher prohibition order.
  • For independent schools, free schools and academies, checks will be made to ensure any member of staff or Steering Group member involved in the management of Gloucester House is not barred from doing so under a section 128 direction.

For further information visit:

https://www.gov.uk/guidance/recruit-teachers-from-overseas

https://www.gov.uk/guidance/qualified-teacher-status-qts

  • Enquiries will be made regarding the applicant’s state of physical and mental health to the extent that it may affect their capacity to carry out their role.
  • The Human resources department will keep copies of the following documents on staff personnel files:
  • Documents used as proof of identity such as passports or driving licences.
  • A summary of the DBS certificate (but all other documents relating to the DBS check must be destroyed).
  • Documents that prove the staff member’s right to work in the UK (failure to do so can result in a fine for employing illegal workers).

4.2 References

  • Applicants will be asked to provide a full employment history and details of at least 2 referees, including previous and recent employers, and who should be a senior member of staff with the authority to provide references.  References from colleagues will not be acceptable.
  • All references will be taken up prior to interview and will be requested directly from the referee, including references for internal candidates. Referees will be contacted to resolve any issues that emerge from the references provided.
  • Any information provided by applicants as part of an application process will be verified with independent sources and any reference received electronically will be checked to verify the originating source.
  • References will be taken up from current employers only; if the applicant is not currently employed, verification of will be sought from their previous school as to the dates the applicant was employed and the reasons for leaving the post.
  • Referees will be contacted to resolve any issues that emerge from the references provided, for example to clarify and verify information provided by the applicant and explore any discrepancies from the information provided on the application form.

4.3 DBS checks

In order to ensure that people who work in Gloucester House are suitable to do so and are not barred from working with children, Tavistock with HR will apply to the Disclosure and Barring Service (DBS) for police checks and other barred list information as part of the recruitment process. 

The relevant DBS check will be taken out according to the role of the individual and their level of unsupervised contact with pupils.

Enhanced DBS checks including police information and children’s barred list information will only be taken out on individuals who are involved in regulated activity. This is defined as:

  • teaching, training, instructing, caring for or supervising children (including driving vehicles only for children)
  • working in the school/college on a regular basis giving opportunities for contact with children (for example in an administrative role)
  • engaging in intimate or personal care or healthcare within the school/college.

Full DBS checks with barred list checks will also be carried out on permanent staff members working at Gloucester House or unpaid volunteers who regularly work unsupervised at Gloucester House and whose work means they have an opportunity for regular contact with children.

Other staff, contractors and supervised volunteers who have opportunities for regular contact with children but do not carry out a regulated activity will be subject to an enhanced DBS check but not barred list checks.

Decisions on whether a person is carrying out a regulated activity or whether their role provides opportunities for regular contact with children requiring a DBS check will be made by whoever is responsible for recruitment in the school, for example the head teacher or Steering Group member, and the following will be taken into consideration when deciding on this;

  • the age of the children;
  • their level of vulnerability;
  • the numbers of children in the group;
  • the nature of the role;
  • opportunities for contact with the children.

Gloucester House has robust procedures for day to day staff management and supervision and clear procedures for reporting and acting on concerns.  Staff carrying out roles involving regulated activity will be suitably supervised on a regular basis by senior staff carrying out a similar role.

Gloucester House requests all successful candidates to provide a DBS certificate as soon as practicable following appointment so that information on the disclosure can be considered.

The school/college will consider any disclosures to decide if the candidate is suitable to work with children and will take into account the number and nature of disclosures, their seriousness and when offences occurred. Decisions not to appoint following DBS disclosure will be carefully recorded giving details of how the decision was reached.

The school/college will follow the DBS code of practice available at:

https://www.gov.uk/guidance/dbs-check-requests-guidance-for-employers

The HR department will ensure that all DBS checks carried out on staff are renewed after 3 years of the original DBS disclosure or via the DBS update service where the employee has subscribed to this.

4.4 Checks for Volunteers

The head teacher will ensure that the following are carried out in relation to unpaid volunteers such as parents/carers who accompany pupils on school outings or provide help in the classroom:

  • All volunteers will be required to undergo a recruitment process, with references, DBS and other checks and interviews that is appropriate and proportional to the duties assigned to them.
  • The headteacher will carry out a risk assessment to establish whether a volunteer will be carrying out a regulated activity and decide what level of checks are needed in relation to their proposed role.
  • Volunteers who are carrying out a regulated activity, for example being left unsupervised with children or providing personal care to children should be subject to an enhanced DBS check, including barred list information.
  • New volunteers who are not carrying out regulated activity but who have an opportunity for regular contact with children will be subject to an enhanced DBS check but this may not include a barred list check.
  • For other volunteers who are not carrying out regulated activity and do not have regular contact with children, the head teacher/principal will carry out a risk assessment to decide whether an enhanced DBS check should be carried out depending on:
  • The nature of the role
  • What information is already known about the volunteer
  • What references from work or volunteering activity the volunteer has provided regarding suitability
  • Whether the role is eligible for an enhanced DBS check.
  • Gloucester House will ensure that all volunteers are competent to carry out the duties assigned to them and are only assigned duties that are suitable to their qualification and experience.
  • Volunteers carrying out regulated activity but for whom a DBS check has not been carried out will be suitably supervised by teaching staff at all times at a level that  ensures the safety of pupils.
  • All volunteers will be fully inducted in relation to all school policies and procedures.

4.5 The Steering Group and independent school management

Gloucester House, through the Human Resources department, will take out an enhanced DBS check on Steering Group members but a barred list check will only be taken out if the individual Steering Group Member will be carrying out a regulated activity within the school.

Gloucester House will also check with the Teaching Regulation Agency Teacher Services system to establish whether any individual seeking to become a Steering Group member has been disqualified and therefore unable to do so.

Additional policies

As an independent school we are aware of the need to take out checks on school management or trustees under section 128 of the Education and Skills Act to establish if the individual has been barred from being involved in the management of schools.

5 Staff practice and conduct

5.1 Induction and training

  • The head teacher/principal will ensure that all staff are fully inducted so that they are aware of the school/college commitment to the safety and welfare of pupils and have a full understanding of their safeguarding role.
  • As part of their induction, staff will be expected to read and be aware of their role in implementing the following:
  • Part 1 or Annexe A of the statutory guidance Keeping children safe in education (2022)
    • “What to do if you are worried a child is being abused” guidance (DfE 2015)
    • the safeguarding and child protection policy and procedures

the school/college behaviour policy

  • the staff code of conduct
    • the Children missing or absent from education policy.
  • Staff will be expected to follow Camden’s online safety policy and model social media policy for schools in terms of their online behaviour and use of social media, particularly in relation to professional standards and relationships with pupils. All staff and volunteers will sign an acceptable use agreement before being given access to the school/college computer system. (http://ccfl.camden.sch.uk/wp-content/uploads/2015/09/Social-Media-Policy-2014.pdf)
  • The designated safeguarding lead will ensure that all staff are fully inducted with regard to Gloucester House child protection procedures and that they receive safeguarding and child protection training on a two-yearly basis.
  • The Human Resources department will keep a central record of all statutory and other training undertaken by staff members, Steering Group Members and volunteers. This is regularly shared with the headteacher.
  • School staff and Steering Group members will receive multi-agency safeguarding training provided by Camden Safeguarding Children Board /Tavistock Safeguarding team at the relevant level.
  • As well as basic safeguarding training, the designated safeguarding lead and their deputy will receive specific training on their role and other relevant multi-agency training courses provided by Camden SCP.
  • School staff will also receive training on the use of the referral process as part of their safeguarding training as appropriate.
  • School staff will receive regular and timely updates on child protection and safeguarding issues via the designated safeguarding lead in order to ensure they remain up to date with new legislation.
  • The head teacher/principal and governors will ensure that all teaching staff receive appropriate training on behaviour management in line with the expectations set out in Teaching Standards.

5.2 Conduct and safe teaching practice

  • Gloucester House expects staff and volunteers to set a good example to pupils through their own conduct and behaviour and aims to protect them from the risk of allegations being made against them by ensuring they maintain high standards of professionalism and appropriate boundaries.

Gloucester House expects staff to:

  • put the welfare of the pupil first at all times
  • take any complaints or disclosures by pupils seriously and act on them accordingly
  • take advice from the designated safeguarding lead when deciding on what action to take
  • challenge inappropriate or discriminatory language and behaviour by pupils
  • be aware of the increased risk to vulnerable pupils such as those with SEND
  • be vigilant to:
    • bullying and abuse between pupils (peer on peer abuse) and take the view that it may be happening even though it is not reported
    • any bullying or peer abuse taking place online or out of school
    • any risks to pupils from extra-familial harm, criminal or sexual exploitation or serious violence.
  • The head teacher will ensure that there is a written code of conduct in place and that each member of staff, including volunteers, signs a code of conduct agreement on appointment that sets out Gloucester Houses expectations with regards to standards of professional behaviour and that all staff receive copies of relevant policies.
  • The code of conduct will include information on how allegations and low-level concerns will be dealt with and school/college policies around whistleblowing.
  • Staff and volunteers should be aware of current guidance on safe teaching practice “Guidance for safer working practice for those working with children and young people in education settings’

https://cscp.org.uk/wp-content/uploads/2019/06/Safer-working-guidance-for-education-settings.pdf

  • Staff will be expected to follow The Tavistock and Portman’s and Camden’s online safety policy and model social media policy for schools in terms of their online behaviour and use of social media, particularly in relation to professional standards and relationships with pupils. All staff and volunteers will sign an acceptable use agreement before being given access to the school/college computer system.

Link to online safety policy

https://cscp.org.uk/wp-content/uploads/2021/08/Model-Schools-Social-Media-Policy-2020.docx

5.3 Dealing with concerns and allegations regarding staff

School/college staff conduct policies will set out what action is to be taken where concerns arise or an allegation is reported in relation to members of staff, agency staff, volunteers and contractors.

Dealing with low level concerns

A low-level concern involves incidents that do not reach the threshold of harm but which may indicate inappropriate behaviour that is inconsistent with expected standards of staff conduct.

Where staff conduct falls below expected standards giving rise to low-level concerns about appropriate boundaries and professional conduct, these should be reported to the designated safeguarding lead and head teacher (the current DSL) or other relevant members of staff to take appropriate action under safeguarding and staff conduct policies in order to help the staff member address issues and improve conduct. It is for the headteacher/principal to decide on what action will be taken in consultation with the designated safeguarding lead or any other relevant member of staff.

Concerns about supply teachers or contractors will also be reported to the designated safeguarding lead who will liaise with their agency so that any patterns of behaviour may be identified and appropriate action taken.

Examples of behaviour and conduct that may be dealt with under these procedures include being over-friendly with pupils, using inappropriate language, contacting pupils via their social media sites or other behaviour that could be misinterpreted and lead to allegations against the staff member.

In the interests of openness and transparency, Gloucester House will also encourage staff members to raise incidents where they felt their actions may have fallen below expected standards and may have been misinterpreted or compromising so that they have an opportunity to reflect on their behaviour. 

The designated safeguarding lead will keep a record of all low level concerns about staff members in order to identify patterns of behaviour so that appropriate action can be taken in a timely manner, for example referral to the LADO.

Records will include the nature of any complaint or concern, the name of the person raising the concern (unless they request anonymity) and the action taken. The records will be confidential and information may be included in any reference.

Where it is unclear whether the threshold of harm has been reached with regard to an incident, the designated safeguarding lead may contact the LADO for advice on a “no names” basis in order to decide if concerns meet the harm threshold and should be referred to the LADO and dealt with under the allegations procedures (see below).

Managing Allegations Against Staff and Volunteers & LADO – Camden Safeguarding Children Partnership — CSCP

Schools/colleges may also refer to the LADO network thresholds document for guidance on what incidents may require a referral to the LADO.

LADO Threshold Document – national-lado-network.co.uk

Dealing with allegations

An allegation involves incidents that may have met the threshold of harm where the person has:

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

In the event that an allegation is made against a member of staff or volunteer, including a member of staff who is not directly employed by the school/college such as a supply teacher, and the allegation involves possible harm to a pupil or raises questions about the suitability of the staff member to work with children, the school/college will follow Camden’s “Guidance for the management of an allegation against a member of staff”. Managing Allegations Against Staff and Volunteers & LADO – Camden Safeguarding Children Partnership — CSCP

The Steering Group will appoint the head teacher as the school representative for the purposes of the allegations procedures and who will link with the Local Authority Designated Officer (LADO) for all allegations raised. A further staff member will be identified as their deputy to act in their absence or if allegations are made against the responsible staff member.

All allegations in relation to staff members will be referred to the head teacher; allegations against the head teacher will be referred to the Steering Group.

5.4 Providing intimate or personal care to pupils

Staff may occasionally need to provide intimate or personal care to younger pupils, for example helping a child who has soiled themselves or supervising pupils who are changing for P.E.

In order to promote safe working practices for staff and to ensure children’s privacy the following guidelines need to be followed. Children should be encouraged to carry out self-care tasks for themselves where appropriate, but where adult intervention is needed, the following should be observed;

  1. When taking pupils to the toilet, staff should make colleagues aware of the task to be undertaken and explain to the child what will happen.
  2. Parents/carers should always be notified if intimate care has been provided.
  3. When providing intimate care, staff should carefully and sensitively observe the child’s emotional response and report any concerns to the designated member of staff.
  4. Any intimate care should be written up on an Incident report form (IRF) and where possible should be managed by 2 staff.
  5. When children are changing, levels of supervision should be appropriate to the pupil’s age.
  6. Staff should avoid any physical contact unless a child needs help.
  7. Staff should ensure that changing areas are private and that others are not able to enter whilst children are changing.

5.5 Behaviour management, physical intervention and restraint

It is Gloucester House’s policy to use physical intervention and restraint in accordance with our Care and Control policy and Team teach training.

Guidance from the Department of Education provides schools with the powers to intervene in a variety of ways in order to manage behaviour within and outside the school. Details of these may be found at:

https://www.gov.uk/government/publications/behaviour-and-discipline-in-schools

Physical intervention and restraint on pupils should only be used as a last resort, normally  when de-escalation strategies have failed, and when there is a clear risk of serious harm to the pupil or others or serious damage to property.

Decisions on when to use physical intervention is a matter of professional judgement, and any intervention or restraint should be proportionate, reasonable and necessary to the perceived risk and should continue only for as long as the risk remains.

Use of physical intervention and restraint is carefully monitored as all Gloucester House pupils are vulnerable pupils and some have learning and other disabilities, autism and mental health difficulties. These pupils are more susceptible to experience physical intervention and restraint due to their circumstances. Gloucester House has incorporated the Department of Education guidance on reducing use of restraint available at: https://www.gov.uk/government/publications/reducing-the-need-for-restraint-and-restrictive-intervention

Further information can also be found in our Care & Control policy and our Behaviour policy.

5.6 Lone Working:

For the purposes of Lone Working Staff follow the Trust guidelines – please refer to The Tavistock and Portman Lone Working Procedures for further guidance: https://intranet.tavistockandportman.nhs.uk/contentobject/29150/Lone-working-procedure s

5.7 Whistleblowing

Gloucester House fosters a culture of openness in line with the “Freedom to speak up” review and will put in place strategies and procedures to ensure that staff feel enabled to raise concerns relating to the safeguarding of children or poor practice within the school that may cause a risk to children.

Gloucester House recognises that there may be circumstances where staff and pupils feel unable to raise concerns or incidents of malpractice within the school environment as there is reasonable doubt that these would be dealt with adequately.

All staff and volunteers have a legal duty to raise concerns where they feel individuals or the school are failing to safeguard and promote the welfare of children. Where it is not possible to raise concerns within the school, or the Tavistock, staff and volunteers may report concerns to the following;

  • Camden’s lead officers for child protection or safeguarding where there are issues regarding the welfare of a pupil.
  • The following numbers can be used where there are issues regarding Gloucester House’s overall procedures around safeguarding:
  • Camden Council’s confidential and independent help-line for protected disclosure on 0800 734199
  • the Ofsted whistle-blowing line on 0300 123 3155
  • The NSPCC whistleblowing helpline on 0800 028 0285.
  • The head teacher is responsible for ensuring that these numbers are advertised on the school premises and made available to staff and pupils.

5.8 Additional Policies/Procedure guidance:

  • The Tavistock and Portman Whistleblowing procedure
  • Relationships with pupils/positions of power and trust for the purposes of the Sexual Offences Act 2003
  • expected guidance on professional and personal standards of conduct and behaviour (Tavi)
  • confidentiality (Tavi)
  • duty of care
  • contact and communications with pupils and parents, including appropriate physical contact, home visits, email and other electronic communications (Online Safety)
  • behaviour management and use of restraint (Behaviour policy and Care & Control policy)
  • dealing with allegations
  • first aid and administering medicines
  • providing intimate or personal care
  • photography and videos