Safeguarding Policy

Although predominately an adult environment, the University and University staff engage with children and vulnerable adults across a range of settings. This policy applies to all members of the University community including [2]:

• staff employed directly by the University;
• individuals holding honorary and / or secondment contracts;
• individuals undertaking work experience or placements;
• students;
• contractors
• students studying an apprenticeship with Manchester Met;
• self-employed undertaking work on behalf of the University;
• volunteers working with or on behalf of the University;
• those engaged on behalf of the University in widening participation activities.

[2] Students includes undergraduate and postgraduate students working as, but not limited to, Associate Lecturers, Graduate Teaching Assistants, Interns, Invigilators and Student Workers for example PAL leaders and Student Ambassadors.  This policy applies to all activities that take place on campus and in University locations that are not located on the main campus as well as online activity.

Governance 

The Board of Governors has overall responsibility for ensuring that institutional safeguarding policies and procedures comply with the law and all relevant national guidance; and are effective. The University Executive Group (UEG), through a Safeguarding Group, oversees the implementation of safeguarding policies and procedures, and any adjustments that are required arising from changes to the law and/or national guidance. The specific responsibilities of the Safeguarding Group are:

• to ensure robust safeguarding procedures are in place in relation to staff and students;
• to determine the approaches that should be taken to safeguarding across the full range of the University’s activities. This will include ensuring that where appropriate, safer recruitment procedures are in place and the necessary checks are carried out on newly appointed staff and other adults working on the University’s premises;
• to ensure procedures are in place for dealing with allegations of abuse against a member of staff or adult on site;
• To ensure procedures are in place for dealing with allegations of peer-on-peer abuse and children with special educational needs and disabilities or health issues.
• to ensure there is a senior member of staff who is designated to take the lead responsibility for safeguarding and child protection;
• to take steps to remedy any deficiencies or weaknesses in safeguarding arrangements;
• to ensure all relevant staff undergo safeguarding and child protection training;
• to carry out an annual review of the safeguarding Policy and procedures;
• to ensure adherence to this policy and procedures in the event of a safeguarding concern emerging.

The Safeguarding Lead Officer will liaise with the University’s Professional Services Leadership Team (PSLT) (which has a designated safeguarding lead), Executive Group (UEG) and the Board of Governors where required. The UEG and the Board of Governors receive an annual report on safeguarding within the University. In addition, members of UEG and the Board of Governors receive regular appropriate briefing and training on safeguarding 

Management, Roles and Responsibilities

It is the role of every member of staff and volunteer who works with children and vulnerable adults to familiarise themselves with this Policy and accompanying guidance documentation; and to work in a way that safeguards the welfare of all students, staff and visitors.

The University has a Safeguarding Lead Officer and other key roles. The responsibilities of these roles are set out below.

Safeguarding Lead Officer

The Safeguarding Lead Officer is the Director of Student Services. The Safeguarding Lead Officer (SLO) is responsible for:

• promoting, implementing, monitoring and reviewing this policy in accordance with legislation and guidance on the safeguarding of children and vulnerable adults;
• annually bringing this policy to the Safeguarding Group for review and providing them with a report on the application of the policy during that year;
• acting as the main contact within the University for the safeguarding of children and vulnerable adults;
• providing University members with information, advice and training on the safeguarding of children and vulnerable adults;
• ensuring this policy is easily accessible to staff and students;
• establishing and maintaining contacts with internal and external key stakeholders; including the police, LADO, local authority.

Deputy Safeguarding Lead Officers

The Deputy Safeguarding Lead Officers (DSOs) are the Head of Inclusion and Pastoral Support Services, the Head of Counselling, Mental Health and Wellbeing and the Head of Apprenticeship programmes. Deputy Safeguarding Lead Officer(s) (DSOs) are responsible for:

• overseeing the referral of cases of suspected abuse or allegations to the appropriate agencies;
• maintaining and recommending updates to  Safeguarding policies and procedures;
• keeping up to date with current policy and legislation and updating the University accordingly;
• reporting to the Safeguarding Lead Officer information/data of safeguarding referrals and themes;
• Liaising with internal and external key stakeholders; including the police, local authority, and LADO in the absence of the Safeguarding Lead Officer
• overseeing risk assessments that are undertaken prior to any activity involving children or vulnerable adults;
• providing University members with information, advice and training on the safeguarding of children and vulnerable adults;
• maintaining confidential records of reported child or vulnerable adult abuse or welfare cases and the action taken in relation to the University member [3].

Senior Manager for Compliance Delivery

The Senior Manager for Compliance Delivery is responsible for:

• Liaising with relevant academic Heads of Department and Directors of Professional Services to co-ordinate staff safeguarding training appropriate to role and function [4]. A record will be kept of this by the  Senior Manager for Compliance Deliver.
• Establishing and maintaining a single central record for FE and Skills Ofsted inspected provision, where required.
• Working with the Head of Department and Professional Service Managers to ensure that students undertake the level of safeguarding training appropriate to their age and course. A record of this will be kept by the Senior Manager for Compliance Delivery.

Academic Heads of Department and Senior Managers in Professional Services

Academic Heads of Department and Senior Managers in Professional Services are responsible for:

• ensuring adherence to the relevant professional standards;
• providing a point of contact within the department for any safeguarding issues that might emerge;

NB: The Guidance Document that should be read alongside this Policy provides further information about safeguarding procedures for Initial Teacher Training provision.

[3] The University has a duty of care and legal obligation, to safeguard our students under the Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012 and the Counter Terrorism and Security Act 2015. Art 6(1)c - the processing is necessary for compliance with a legal obligation. Art 6(1)e of the GDPR - the processing is necessary for the performance of a task carried out in the public interest. Substantial public interests include fulfilment of an enactment or rule of law, and the safeguarding of children and of individuals at risk.

[4] Safeguarding training for students aged under 18 will be incorporated within general training on Prevent and British Values as applicable.

Safer Recruitment 

The University will have regard to the Keeping Children Safe in Education guidance when considering the recruitment and selection of those in contact with children. Detailed arrangements are determined by the University Safeguarding Group.

Disclosure and Barring (DBS (Disclosure and Barring Service)) checks

The University is registered with the Disclosure and Barring Service (DBS) and has responsibility for ensuring that any member of staff , volunteer, individuals holding honorary and/or secondment contracts, individuals undertaking work experience or placements, students, contractors, apprentices, self-employed and volunteers (including anyone in those categories who is engaged in widening participation activities) who will be undertaking regulated activity with under 18 year olds, and vulnerable adults, will be required to undertake an enhanced DBS check.

A person will engage in regulated activity if, as a result their work, they:

• will be responsible on a regular basis for teaching, training, instructing, caring for or supervision of children;
• will be working on a regular basis in a specified establishment where the work gives opportunity for contact with children;
• will be engaging in intimate or personal care or health care or any overnight activity, even if this happens only once.

For further information, please refer to Appendix 5 and read Keeping Children Safe in Education Part One Annex A.

In addition, where a student engages in regulated activity relating to children or vulnerable adults, through the University as part of a placement, paid work via Jobs for Students, or a volunteer position, or is otherwise working with children or vulnerable adults, the relevant department or Jobs for Students will ensure that an enhanced DBS check is available, before they commence the activity.

Training 

From the academic year 2022-2023 all new staff, who are appointed to relevant roles, that involve working directly with children and vulnerable adults will undertake a comprehensive induction on safeguarding. This will include:

• University safeguarding services and where to go to in the event of a concern;
• Part One and Annex A ‘Keeping Children Safe in Education 2022’;
• Peer on Peer abuse;
• Students with special educational needs and medical conditions;
• Harmful sexual behaviour towards or between children and or vulnerable adults;
• Student Code of Conduct; 
• Staff disciplinary procedures;
• Prevent, Freedom of Speech and Online Safety policy;
• Staff Guidance on Responding to Inappropriate Social Media Posts and Other Inappropriate Behaviour;
• Whistle Blowing.

Where staff do not work directly with children, the university’s Safeguarding Policy will be brought to their attention as part of their induction and as part of the university’s suite of documents on the intranet, which staff are obliged to comply with. Further details are contained in the Safeguarding Guidance notes that support this policy.

Further training opportunities will also be provided throughout the academic year, by the Head of Inclusion and Pastoral Support, for academic and professional service staff.

It is a criminal offence under the Sexual Offences Act 2003 for an adult in a position of trust to engage in sexual activity with a child under the age of 18 years. All staff should take steps to ensure that they do not put themselves in a position where an allegation of abuse can be made against them. Such steps include, but are not limited to:

• always working in an open environment with children;
• avoiding unnecessary physical contact with children;
• avoiding inappropriate familiarity with children;
• not inviting or allowing children to socialise with them and/or to visit them at home;
• never engaging with a child via social media and on-line platforms other than those formally authorised within the context of the project/activity;
• always acting upon and recording allegations/reports of abuse made by children;
• always reporting potential concerns/allegations/reports of abuse made by children to the Safeguarding Lead Officer, or in their absence the Deputy Safeguarding Officer;
• reporting any potential concerns to their Head of Department.

All recorded information relating to safeguarding concerns and disclosures are kept in secure files separate from all other student files. Responsibility for maintaining these files lies with the Head of Inclusion and Pastoral Support Services. Access to these files is restricted to:

• the Academic Registrar;
• the Assistant Academic Registrar;
• the Director of Student Services;
• the Head of Inclusion and Pastoral Support Services;
• the Head of Counselling, Mental Health, and Wellbeing;
• the Head of Student Welfare;
• the Senior Executive Officer Student Services.

Safeguarding files will be reviewed and deleted after seven years after the most recent safeguarding file for the student has been closed.

Safeguarding concerns should be raised with the Safeguarding Lead Officer or Deputy Safeguarding Lead Officer at the earliest opportunity [5].

An overview of the process for reporting a safeguarding concern is provided in the flowchart in Appendix 2.  This should be considered in conjunction with the specific guidance set out in the supporting Safeguarding Guidance Notes.

Please note that where the person reporting feels that the Safeguarding Officer has not addressed their concerns, or the person reporting the safeguarding concern prefers not to raise it with the Safeguarding Officer or Deputy Safeguarding Officer for any reason, the disclosure can be made, ideally in writing, via the University’s Whistleblowing Policy.

[5] The SLO is the Director of Student Services.  The DSOs are Head of Inclusion and Pastoral Support Services; Head of Counselling, Mental Health and Wellbeing Service; Head of Apprenticeship Programmes.

If the activity did not occur on university premises, contact the host organisation’s SLO or DSO.

All members of the University community who are representing the University on non-University premises and who expect to be engaging with children, vulnerable adults, and young people as part of their University activity must familiarise themselves with, and abide by, the host organisation’s safeguarding procedures.

The University will ensure that appropriate arrangements are in place to keep children and vulnerable adults safe where premises are hired or rented out to organisations or individuals e.g., community groups. Where activities involve University staff, the University’s safeguarding procedures will apply. Where services are provided separately by another provider, the University will seek assurance from that provider’s governing body or proprietor that appropriate safeguarding and child protection policies and procedures are in place (including inspecting these as needed).

Where the University uses contractors to provide services, it will set out the relevant safeguarding requirements in the contract between the University and the provider.

Students are expected to abide by the Student Regulations for the use of University Computing Resources. Failure to do so will be regarded as a breach of conduct under the Student Code of Conduct. 

This control procedure defines the University’s approach to acceptable use of its IT systems, and directly supports the following policy statements from the Information Security Policy:

The University’s security policies and expectations for acceptable use will be communicated to all users to ensure that they understand their responsibilities. Information security education and training will be made available to all staff and poor and inappropriate behaviour will be addressed.

Students must not use computing facilities to access, create, store or transmit offensive, indecent, obscene, discriminatory, or extremist material. They must not use the computing facilities in a way that has the potential to create an environment that is offensive or threatening, or that may constitute harassment. Threatening, abusive, obscene, or otherwise offensive communications must not be sent; this includes the sharing of nude or semi-nude images, videos, or live streams online by children under the age of 18 years and / or vulnerable adults. Students must not undertake any online activity that could be considered to be harmful sexual behaviour towards or between children or vulnerable adults. Harmful sexual behaviour towards or amongst children or vulnerable adults will be investigated under the Student Code of Conduct. Students will be supported as per the safeguarding policy.

If a member of staff or others become aware of the sharing of such imagery this should be reported to the SLO immediately.

Guidance on the University’s approach to research ethics as they apply to children and vulnerable adults is provided on the Research Ethics and Governance webpage. Of particular note in the context of this policy are references to research involving children under the age of 16 (a higher level of authorisation is required) and adults lacking the capacity to give consent (particular legislation may apply).

The Counterterrorism and Security Act (2015) places a duty on ‘specified authorities’, including universities, to have due regard to the need to prevent people being drawn into terrorism in the exercise of their functions.  The focus of the University’s Prevent duty responsibility is on safeguarding students and other members of the University community from being drawn into terrorism, ensuring that those who are vulnerable to extremist and terrorist narratives are given appropriate advice and support at an early stage. Prevent is therefore a specific instance of the University’s wider safeguarding responsibilities.

All staff should be alert to the possibility of a member of the University community being drawn into extremism. All staff are expected to undertake the on-line training on arrival at the University and to refresh this mandatory training every two years. In addition, the University adopts a tiered approach to more enhanced training on the Prevent duty, depending on the staff role. This includes face to face training of particular staff groups as appropriate. All staff have a duty to respond should concerns arise in this arena. 

The University provides guidance on how to respond in the event of a concern emerging in this regard but, in summary, an immediate referral should be made to one of those listed in Appendix 1, i.e., the Assistant Academic Registrar, the Director of Student Services or the Head of Campus Security. 

Information about the Prevent duty is available for students on the University’s webpages, and students are provided with a link to the webpage in the University’s induction materials. Information for staff can be found on the University’s intranet site.