Everything Apprenticeships (EA), is committed to safeguarding all learners while they participate in learning programs. This document outlines EA’s commitment to collaborate with all parties to uphold the highest standards of safeguarding practices throughout the learning journey.  It articulates the proactive measures we will implement, alongside the expectations placed on all individuals to ensure compliance with safeguarding principles and regulations. 

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PURPOSE

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The purpose of this policy is to: 

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• Teach learners how to keep safe and recognise behaviour that is unacceptable. 

• Identify the expectations of all staff and to promote their understanding and responsibilities relating to safeguarding legislation and statutory guidance. 

• Ensure relevant and effective safeguarding practices are in place and staff are appropriately trained to carry out practices. 

• Promote awareness to staff of the need to safeguard children, vulnerable adults, and all people and to raise awareness of different types of abuse and indicators of safeguarding concerns. 

• Ensure the fundamental rights and needs of apprentices are observed. 

• Ensure staff and apprentices are protected from abuse regardless of sex, race, disability, age, sexual orientation, religion or belief, and gender. 

• Take suspicions and allegations of abuse including risks of radicalisation extremely seriously and respond to concerns in a timely manner and with consideration. 

• Provide guidelines for staff in handling matters relating to actual or suspected child abuse. 

• Prevent the risk of abuse by ensuring procedures and standards are in place and that staff act professionally. 

• Ensure that the fundamental rights and needs of apprentices, staff and other stakeholders affected by safeguarding issues are observed and that staff are supported when dealing with a safeguarding issue. 

• Deter potential, unsuitable individuals from applying to EA by demonstrating our attentiveness and vigilance in relation to safeguarding through our website, job advertisements, and our Safer Recruitment Process. 

• Reject anyone who applies to work with us or supply us with services where we have doubts about their suitability. 

• Work in partnership and in accordance with external organisations. 

• Have an appropriately trained Designated Safeguarding Lead (DSL) in place at all times to advise on and manage any concerns and referrals. 

• Have an appropriately trained Deputy DSL in place wherever possible. 

• Ensure sensitive personal data is processed in accordance with the requirements of GDPR. 

• Implement a procedure which provides a way to respond promptly and fairly to allegations of bullying, threat, harassment and intimidation. 

• Allow for complaints to be properly considered and for conclusion to be reached. 

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LEGISLATIVE / QUALITY FRAMEWORK

 

This Policy integrates the key principles of Safeguarding, the Prevent Duty, Equality, Diversity and Inclusion, and Health and Safety. It has been created with reference to 'Working Together to Safeguard Children (2018)' and 'Keeping Children Safe in Education (2023)’. EA also has a specific Bullying and Harassment Policy which underpins and strengthens this broader Safeguarding Policy and relies on the active participation and adherence of all stakeholders. 

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It should be read in conjunction with our other EA Policy documents including but not limited to: 

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• Absence Policy 

• Whistleblowing Policy 

• Professional Development Policy 

• IT and Software Management Policy 

• Information Security Policy 

• Recruitment Policy 

• Bullying and Harassment Policy 

• Compliments, Comments & Complaints Policy 

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SCOPE

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This policy applies to everyone at Everything Apprenticeships including all learners, staff and subcontractors (including those of Rubitek Solutions Limited) and it should be read and understood by all. It provides staff with a clear framework for ensuring the safety, welfare, and protection of all individuals involved in EA’s learning programs and activities.

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DEFINITIONS

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The following are commonly agreed safeguarding definitions:

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• Children and Young Adults are individuals who are under the age of 18. 

• Vulnerable Adults are as defined in section 59 of the Safeguarding Vulnerable Groups Act 2006 and / or those individuals aged 18 and over who by reason of mental or any other disability, age, or illness, are or may be, unable to look after or to protect themselves against harm or exploitation. They are considered vulnerable if they are:

  • substantially dependent upon others in performing basic physical functions, or their ability to communicate with other providing services, or to communicate with others, is severely impaired

  • living in sheltered housing or residential accommodation; receiving any form of health care or domiciliary care in their own home

  • detained in a prison, remand centre, young offender institution, secure training centre or attendance centre or under the powers of the Immigration and Asylum Act

  • in contact with probation services; receiving a welfare service; receiving a service or participating in an activity which is specifically targeted at people with age-related needs, disabilities or prescribed physical or mental health conditions

  • receiving direct payments from a local authority in lieu of social care services

  • or in need of assistance in the conduct of their own affairs. 

• Adults at Risk of Harm are individuals aged 18 years or over who may need or receive community care services by reason of mental health or other disability, age, or illness and who may be unable to take care of themselves or protect themselves against significant harm or exploitation (No Secrets, Department of Health. March 2000). 

• The 5 Rs of Safeguarding refer to the steps which should be followed if a safeguarding concern arises – these are Recognise, Respond, Report, Record and Refer. 

• It is important that people are protected from all forms of abuse or potential harm. Abuse may take many forms including (but not necessarily limited to) the following: 

  • Sexual abuse either from inappropriate behaviour or relationships, including rape, indecent exposure, sexual harassment, teasing or innuendo, or sexual acts to which the adult has not consented or was pressured into consenting. 

  • Physical abuse including assault, hitting, slapping, pushing, restraint, or inappropriate physical sanctions.

  • Emotional abuse including threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation.

  • Neglect including ignoring medical, emotional, or physical care needs. 

  • Female Genital Mutilation (FGM). 

  • Exploitation including theft, fraud, sexual (including sexploitation), forced marriage, forced labour through modern slavery and/or human trafficking. 

  • Grooming for example, for a sexual, criminal, or radicalisation intent. 

  • Domestic violence. 

  • Bullying including cyber bullying. This is further defined and addressed in the Bullying and Harassment Policy. 

  • Victimisation. 

  • Self-harm such as neglecting to care for personal hygiene, health, or surroundings. 

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RESPONSIBILITIES

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The effective implementation of this Policy relies on the active participation and adherence of all stakeholders.

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The Directors are responsible for ensuring that robust safeguarding policies and procedures are in place, that they are regularly reviewed, and effectively communicated to all learners, staff, contractors, partners, and employers. They must lead by example, demonstrating a commitment to prioritising the safety and welfare of all individuals involved in EA’s activities. The Directors are accountable for providing adequate resources and support to enable staff to fulfil their responsibilities effectively and must stay informed about relevant legislation and best practices, ensuring EA remains compliant and responsive to emerging concerns. 

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All Staff including those who are not directly employed by EA but who act on behalf of EA are responsible for ensuring the practical implementation of this Safeguarding Policy, and that all processes and procedures are robust, up-to-date, and consistently applied.  They will also ensure there are appropriate safeguarding policies in place in the organisations where our apprentices work. 

 

Designated Safeguarding Lead (DSL) or the Deputy DSL (if in post and where the DSL is not available), is responsible for the management of safeguarding issues, including concerns for learner welfare, and reports to the Directors on any issues that arise.  The DSL carries out investigations where appropriate and coordinates escalation processes, liaising with external bodies such as local multi-agency safeguarding partnerships where cases of suspected abuse or allegations are raised. The DSL is not entitled to give formal legal advice but is able to obtain such advice from experts and maintains links with local multi-agency safeguarding partners, informing and advising on legislation changes and current safeguarding themes. 

 

The DSL monitors the safeguarding@everythingapprenticeships.com inbox and ensures all concerns are dealt with in a timely and appropriate manner. The DSL is responsible for making a barring referral and has responsibility for raising awareness across all staff relating to the welfare of children, young people, and adults.  

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The contact details for the DSL are: 

 

Name:  Kerry Linley 
Email: safeguarding@everythingapprenticeships.com 
Telephone: 0330 133 0540 

 

The contact details for the DDSL are: 

Name:  
Email:  
Telephone: 0330 133 0540 
Mobile:  

 

Learners, employers and other stakeholders have a responsibility to report any concerns in line with this Policy. 

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EA is part of Leicestershire County Council and has identified and established contact with the Local Authority Designated Officer (LADO). In all cases where allegations are made against people who are in contact with EA learners, the DSL will consult with the LADO. EA also maintains a list of all LADO contact details in each of the Local Authority areas where learners live and are employed. Allegations of abuse made against a member of staff, or any other person employed by EA to deliver support or services to any of its learners, will be reported immediately to the appropriate authorities, including the Leicestershire County Council LADO and Leicestershire Police. The individual concerned will be suspended/removed from their duties pending further investigation.

 

The Leicestershire County Council LADO Allegations Team can be contacted at: 

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Email: cfs-lado@leics.gov.uk 

Telephone: 0116 305 4141

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GUIDANCE FOR STAFF

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All staff have a responsibility to remain vigilant for signs that a person may be in danger. The 5Rs of Safeguarding are designed to help people remember and understand how they can do this in the best possible way:

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• RECOGNISE: You must have a clear understanding of the different signs and symptoms of potential abuse, harm, and neglect. 

• RESPOND: If you do have a have a safeguarding concern, you must respond appropriately and not ignore the situation. 

• REPORT: Safeguarding concerns must be reported without delay, and with full consideration of the need for confidentiality. 

• RECORD: Take precise, comprehensive notes that detail the facts about the safeguarding concern, including who, what, why, when, and where. 

• REFER: The DSL is responsible for passing on concerns of safeguarding to the appropriate authorities. 

 

Full training is provided to all staff and wider stakeholders to help them recognise the signs and symptoms of potential abuse, and respond, report, and record the information in a way that complies with this policy, ensuring EA protects those who engage with its services. This training is provided as part of induction and periodically as part of mandatory training, along with access to relevant training resources and ongoing legislative updates. All staff will undergo annual refresher training. 

 

Reporting a Safeguarding Concern: In all instances, staff must record details of a safeguarding concern raised or witnessed on the Safeguarding Disclosure Form.

 

Individuals who do not have access to this form directly must telephone the DSL or, if the DSL (and Deputy DSL is appointed) are not available, send an email to safeguarding@everythingapprenticeships.com with a brief explanation of the safeguarding concern. The DSL or the Directors (if the DSL is not available) will contact the member of staff and record the details of the concern and complete the Safeguarding Disclosure Form on their behalf. The DSL must be informed immediately when a learner does not attend a pre-arranged training session, one-to-one, or review. The DSL will follow the procedure outlined in the Absence Policy, and if the absence gives rise to a safeguarding concern, the DSL will complete a Safeguarding Disclosure Form. 

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Peer-on-Peer Abuse: Staff must remain vigilant to the signs of peer-on-peer abuse, which may include physical and sexual abuse, sexual harassment and violence, emotional harm, on and offline bullying, and relationship abuse. It can even include grooming for sexual and criminal exploitation. Where a member of staff believes a learner is being subjected to peer-on-peer abuse, they must take immediate action to ensure the safety and wellbeing of the individuals involved and report the incident to the DSL immediately. Any instance of abuse by a learner of another learner will be reported to the employer of the learner(s) perpetrating the abuse. Peer-on-peer abuse involving staff will be dealt with via EA's internal disciplinary and grievance procedures. 

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If a Learner Raises a Concern or Makes an Allegation: Staff must record all information on the Safeguarding Disclosure Form. Details must be recorded accurately, and staff should not make any judgements or assumptions about the information given by the learner. Guidance is given on the form about the actions required to secure the immediate safety of the learner. Staff must request the learner’s consent to refer the concern to the DSL. If the learner’s safety and/or wellbeing is at risk, the matter must be referred to the DSL even if the learner withholds consent. Staff should advise the learner that they have a duty of care to refer the concern. The DSL will decide the appropriate course of action and update the Safeguarding Incident Log with details of this. 

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If a Third Party Raises a Concern or Makes an Allegation: Staff must record all information on the Safeguarding Disclosure Form (as above), including contact details of the third party. Staff should be mindful of confidentiality. Learners who are aged 16 and above and of employed status are deemed adults49. Do not pass on any follow up information to any third party without the consent of the learner that the concern relates to18. 

 

If a Concern Relates to a Member of Staff: If any individual wishes to raise a concern regarding a member of staff, they must contact the DSL. If any member of staff becomes aware of a concern regarding another member of staff, they must refer the person raising the concern immediately to the DSL. The DSL will follow the protocol outlined in the Whistleblowing Policy. 

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Observation of a Concern in the Employer’s Setting: If any member of staff becomes aware of, or observes a concern, whilst on an employer’s premises, they should stop the activity they or the learners are currently engaged in and inform the individual involved of the concern and ask them to remove themselves from the area and report the concern to their designated manager. Staff must take action to secure the safety of themselves and any learners at risk. Staff must be mindful of the differences between poor practices and safeguarding issues and apply any actions appropriately, including recording the safeguarding concern on the Safeguarding Disclosure Form and referring this to the DSL who will decide the appropriate course of action and record this on the Safeguarding Disclosure Form. 

 

Learner Report of a Concern in the Employer’s Setting: If a learner reports a safeguarding concern that they are aware of in their employer setting, advise the learner to follow the employer’s in-house reporting or whistleblowing procedures, and offer support and intervention if required. 

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Reporting FGM: Female Genital Mutilation (FGM) is illegal in England and Wales under the FGM Act 2003 (“the 2003 Act”). It is a form of child abuse and violence against women. FGM comprises all procedures involving partial or total removal of the external female genitalia for non-medical reasons. The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crime Act 2015)52. This legislation requires regulated health and social care professionals and teachers in England and Wales to make a report to the police where, in the course of their professional duties, they are either informed by a girl under 18 that an act of FGM has been carried out on her, or observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth. For the purposes of the duty, the relevant age is the girl’s age at the time of the disclosure/identification of FGM (it does not apply where a woman aged 18 or over discloses she had FGM when she was under 18). Complying with the duty does not breach any confidentiality requirement or other restriction on disclosure which might otherwise apply. The duty is a personal duty which requires the individual who becomes aware of the case to make a report; the responsibility cannot be transferred, unless another individual from your profession has already made a report. Reports under the duty should be made as soon as possible after a case is discovered, and best practice is for reports to be made by the close of the next working day, unless exceptional cases require a longer timeframe, for example, if there is an immediate safeguarding risk to the child. Staff who think they are dealing with a case of FGM are strongly advised to consult with the DSL as soon as practicable, and to record and maintain clear and factual records which may be used as supporting evidence. 

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Supporting Staff: Staff who become involved with a learner or vulnerable person who has suffered harm, or appears to be at risk of harm, may find the situation stressful and upsetting. EA will support all individuals by providing them with opportunities to discuss their anxieties with a suitable qualified mental health first aider, or a member from the senior management team or directors. Time off will be provided to staff to access external support. 

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Protecting Ourselves: Staff should take all reasonable precautions to protect themselves against allegations of abuse. They must avoid personal and social contact with learners and take steps to minimise the risk of any situation arising in which misunderstandings can occur. 

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Staff must not:

 

• Engage in flirting, innuendo, suggestive remarks, discriminatory comments, or make suggestions. 

• Issue or threaten any form of physical punishment. 

• Engage in any sort of sexual relationship with a learner. 

• Photograph or film learners without prior consent or where the photograph or film does not relate to evidencing off-the-job learning relevant to the apprenticeship or retain photographs or film on personal devices. 

• Send any audio and/or visual material that has inappropriate content to learners. 

• Invite or allow a learner to their home, or any other location where the purpose is one of friendship or an intimate relationship. 

• Do things of a personal nature for learners that they can do for themselves. 

• Dismiss an allegation of any sort relating to a learner's welfare or delay the reporting of an allegation. 

• Withhold any disclosure should they suspect abuse. 

• Spend excessive amounts of time alone with learners away from others. 

• Make unnecessary physical contact with learners. Where physical contact is unavoidable, staff should make every effort to ensure contact only takes place with consent and be mindful that some individuals practice non-contact. 

• Meet/arrange to meet a learner outside of working hours unless it is with consent of the senior managers or directors. 

• Befriend or chat to learners/apprentices on private social network sites. 

• Give or receive gifts and/or substances such as drugs, alcohol, cigarettes, e-cigarettes from or to a learner. 

 

Staff must:

 

• Work in rooms and locations with learners where they can be visibly seen by others. 

• Plan in-person activities that involve more than one other person or that are within sight and hearing of others. If unavoidable, always ensure your line manager knows where you are, with whom, and why. 

• All email communication should be sent to learners using the email pseudonyms provided within the Rubitek platform. Comprehensive training has been provided to ensure pseudonyms are used correctly, ensuring emails are securely recorded and easily monitored within the platform. 

• Be aware of the procedures for reporting concerns or incidents and be familiar with the contact details of the DSL. 

• Treat all learners equally and with respect. 

• Ensure allegations or disclosures by a learner are taken seriously and reported. 

• Use professional language when writing, phoning, emailing, or using social media to communicate with learners. 

• Be aware that learners can develop infatuations (crushes) towards those working with them. If suspected, tell the DSL who will respond in a way that maintains the dignity of all concerned. 

• Act as a role model. 

• Set and monitor appropriate boundaries and relationships when working with learners based on openness, honesty, and respect for them. 

• Respect a learner’s right to personal privacy but never agree to keep any information relating to the harm of a learner confidential. 

• Provide support to a learner making a complaint. 

• Report any concerns without delay and record all the facts. 

• Staff who do not comply with this Policy and those who are the subject of a safeguarding allegation may be subject to EA's internal disciplinary and grievance procedures. 

 

GUIDANCE FOR LEARNERS

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EA programs provide a broad and balanced curriculum, delivered by skilled professionals, which includes awareness of safeguarding issues. EA integrates safeguarding and wellbeing into its sessions for learners who are provided with an opportunity to discuss confidential issues and concerns with an appropriately trained member of staff. EA also provides regular communications to staff, learners, and their employers about safeguarding and related issues. Learners have a responsibility to report any concerns in line with this Policy.

 

Recognising the paramount importance of online safety education, EA is committed to educating both staff and learners on how to remain safe online and the responsible use of technology and the internet. This is covered during learner inductions at the start of their apprenticeship training and at regular intervals throughout. EA shares information with learners about the proactive measures taken to shield them from cyberbullying, exposure to unsuitable online content (e.g., content that includes references to or depiction of self-harm and / or suicide), and other potential risks. EA also encourages open discussion about the potential of online risks during interactive learning sessions. 

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EA ensures learners understand what a DBS check is and whether it is required for their job role. While employers are ultimately responsible for necessary checks, EA supports employers in understanding their role and responsibility with the Disclosure and Barring Service. 

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SAFE RECRUITMENT AND SELECTION

 

EA will comply with best practice in the recruitment and training of its staff, in line with legislative requirements. The EA Recruitment Policy supports this document. EA will ensure safeguarding considerations are incorporated into every stage of the recruitment process.  Applicant identities are checked at interview, and all job offers are subject to appropriate references being supplied. Individual’s criminal convictions are checked on appointment, as appropriate to the job role, via Enhanced DBS Disclosure and used in the interim with additional supervision and monitoring in place. 

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Where DBS checks are necessary, EA maintains a central DBS register. 

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RECORDS AND CONFIDENTIALITY

 

EA will maintain clear, comprehensive records of any safeguarding concerns. The company will comply with the requirements of the Data Protection Act 1998, which allows for disclosure of personal data where this is necessary to protect an individual. It is vital that all records include precise and detailed information using the words of the individual making the disclosure or raising the concern. Information will be accessible only to those who need to access it as part of further investigation or any action necessary. 

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The DSL monitors safeguarding incidents to identify emerging trends or patterns, enabling proactive intervention and the implementation of relevant preventive measures or further training to minimise the likelihood of further recurrence. 

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All matters relating to welfare and safeguarding are highly confidential. EA will only disclose information, both internally and externally, on a ‘need to know’ basis. Records and referral details will be made and stored on electronic systems accessible by the DSL and Deputy DSL and classified as Confidential. 

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For details of how to make a referral to the local safeguarding team, see Appendix I (Professional Safeguarding Referral (leics.gov.uk). 

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IT USAGE AND ONLINE SAFETY

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Recognising the paramount importance of online safety education, EA is committed to educating both staff and learners on how to remain safe online and the responsible use of technology and the internet. Staff members are responsible for ensuring that learners are well-informed about best practices in online safety and acceptable behaviour and usage of EA equipment. 

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This is covered during learner inductions at the start of their apprenticeship training and at regular intervals throughout. EA shares information with learners about the proactive measures taken to shield learners from cyberbullying, exposure to unsuitable online content (e.g. content that includes references to or depiction of self-harm and / or suicide), and other potential risks. EA also encourages open discussion about the potential of online risks during interactive learning sessions. 

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All EA computing equipment and / or devices which access the internet are protected by a firewall which is configured to filter out inappropriate content or block access to specific websites as detailed in our IT and Software Management Policy, and our Information Security Policy. However, we recognise that sometimes content can be accessed inadvertently. To ensure responsible usage and in line with these policies, internet activity may be checked at regular intervals. This monitoring serves to not only track the frequency of internet usage but also to assess the nature of the accessed content and ensure the suitability of firewalls to ensure we are providing the necessary protection for staff and learners. Material, which is deemed inappropriate, whether accessed via the internet or stored on electronic devices, will result in disciplinary action in accordance with the disciplinary and grievance procedures.

 

APPROVAL AND REVIEW

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​This policy shall be reviewed by the Directors and updated where necessary before being re-approved at least annually to ensure that it (and any subsidiary policies and procedures) remains appropriate considering any relevant changes to the law, organisational policies, or contractual obligations. 

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This version 1.4 of the policy was last updated and approved by the Directors on 29th May 2025. ​