Safeguarding and Prevent Policy

Policy Overview

Train Together Limited is deeply committed to the safety of our apprentices and adult learners. We have a statutory and moral obligation to protect and promote the welfare of children, young people, and adults who are in danger of harm. This policy incorporates our PREVENT duty to protect apprentices against radicalisation. It addresses how we recruit and train our trainers and support team to support our apprentices and effectively deal with all safeguarding concerns and incidents.

The Train Together Limited Safeguarding and Prevent Policy underlines the importance of our obligation to safeguard and promote the welfare of all our apprentices and staff by safeguarding them from physical, sexual, or emotional abuse, neglect, and bullying. We are dedicated to creating a nurturing, approachable, and safe environment for our apprentices, allowing them to learn comfortably and securely. Every apprentice and adult learner should be able to engage in all learning and social activities in a fun and safe atmosphere while being safe from harm. We desire to empower all stakeholders and operate from a paradigm of power to, power with and power within:

‘Power to’ is our fundamental belief that everyone is unique, valued and appreciated. We want to ensure that our learners are treated equally and in line with our Equality, Diversity, and Inclusion Policy.

‘Power with’ is underlined by our ethos that our learners are the shapers of their learning journey. We desire to build collaborative, deeply respectful relationships between stakeholders that ensure we see positive action through collective action.

‘Power within’ is our goal to ensure in all that we do, we support our learners to their sense of self-worth and build a catalogue of knowledge that will keep them safe, unafraid to take on new challenges and belief that they can make a difference to the world around them.

This policy applies to all staff, apprentices, visitors, contractors, volunteers, service providers, and subcontractors who may be working with children (those under the age of 16), young adults (those aged 16-24), and vulnerable adults (as defined in section 59 of the Safeguarding Vulnerable Groups Act 2006 and/or those persons aged 18 and over who require help with day-to-day living.

This policy’s objectives are as follows:

  • Agree and set staff expectations around safeguarding.
  • Ensure that appropriate and effective safeguarding practices are in place.
  • Ensure that every applicant and apprentice has the right to learn in a safe environment.
  • Raise staff understanding of the importance of protecting children, vulnerable adults, and all individuals and recognise that safeguarding is everyone’s duty.
  • Ensure that our applicants’ and apprentices’ fundamental rights and requirements are met.
  • Prevent abuse by providing pastoral support to all applicants and apprentices.
  • Raise awareness of various sorts of abuse and concerns affecting children young people anm adults in need.
  • Provide staff with procedures and information, advice and guidance for dealing with actual or suspected abuse.
  • Ensure that employees conduct themselves professionally at all times.
  • Dissuade prospective inappropriate applicants by having competent, consistent and compelling safeguarding practices and procedures in place at all times and in all parts of the organisation.
  • Demonstrate of awareness and attentiveness to safeguarding through our website and job adverts.
  • Reject at the interview stage anyone we have reservations about.
  • Reduce the danger of abuse by implementing processes and standards.

Throughout this policy, the terms:

‘Children and young people’ is used.
1. Protecting and promoting the welfare of children is defined as protecting children from maltreatment, preventing impairment of children’s health or development, ensuring that children grow up in circumstances consistent with the provision of safe and effective care, and maintaining action to enable all children to have the best outcomes (Keeping Children Safe in Education 2023).

‘Adults at danger of harm’ is used.
2. Adults at risk of harm are defined as people aged 18 and up who may require or receive community care services due to mental health or other disability, age, or illness and who may be unable to care for themselves or protect themselves from significant harm or exploitation (No Secrets, Department of Health, March 2000). The approach will be followed, with appropriate adjustments made for all apprentices.

This policy was developed following the ‘Working Together to Safeguard Children’ initiative (2020), the SET Procedures 2015, the Counterterrorism and Security Act (2015), and the Keeping Children Safe in Education Act (2023).

Section 1- Introduction – An Overview of Safeguarding Legislation

Since the first legislation was established in 1945 to protect children, the UK has continued to strengthen its legislation, knowledge and application of best practices in safeguarding children, young people and vulnerable adults. In 2014, Keeping Children Safe in Education (KCSIE) specifically looked at safeguarding practice applications in our sector. KCSIE is a document produced by the Department for Education. It contains thorough instructions and recommendations for schools, universities, and other educational institutions, including Independent Training Providers, to safeguard children’s safety and welfare. The guidelines include a wide range of themes, such as recognising and responding to child abuse, establishing safeguarding processes, completing background checks on employees, creating a safe online environment, and promoting a culture of awareness and accountability. The document aims to provide educators with the knowledge and tools to protect children and establish a safe learning environment. It emphasises the importance of teamwork among employees, parents, and outside agencies to protect children properly, young people, and vulnerable adults. It is important that Train Together employees have read the KCSIE guidance as part of their induction and when the guidance is reviewed. To access the KCSIE 2023 guidance, please click here.

The latest KSCIE 2023 was implemented in September 2023 and breaks down safeguarding responsibilities for education providers into five categories:

  1. Safeguarding information for all staff
  2. The management of safeguarding
  3. Safer recruitment
  4. Safeguarding concerns raised about and allegations made against staff (including supply teachers, volunteers, and contractors)
  5. Child-on-child sexual violence and sexual harassment

Key updates for KCSIE 2023:

  1. Clarification of education staff roles and responsibilities in terms of filtering and monitoring
  2. Confirmation that being absent and missing from education can be a warning sign of a variety of safeguarding concerns, such as sexual abuse, sexual exploitation, or child criminal exploitation.
  3. Additional information on online pre-recruitment checks for shortlisted candidates.
  4. Information on responding to claims linked to organisations or individuals employed in education.

In addition to KCSIE 2023, Train Together adheres to the Six Principles of Safeguarding Adults. Developed by the Care and Support Statutory Guidance, the principles were designed to provide a framework for protecting vulnerable adults’ safety and well-being but can also be applied to safeguarding children and young people. Alongside KCSIE, the six principles goal is to increase awareness and help individuals make informed decisions, that can reduce the risk of abuse, exploitation, and harm.The Six Principles of Safeguarding Adults are:

  1. Fundamentally, all people have the right to make their own decisions and control their lives, referred to as empowerment. For Train Together, our objective is to support and assist our staff, learners, employers, and guardians (applicable to 16-18yr learners and learners with an Education and Health Care Plan aged 25yrs or younger) in making sound decisions.
  2. Prevention entails avoiding injury or abuse before it occurs. This entails identifying potential dangers and aggressively addressing them.
  3. Proportionality is the goal that any intervention or action should be proportionate to the individual’s risk and circumstances. The least intrusive alternative while efficiently managing the risk should be chosen.
  4. Implement safeguarding procedures to protect individuals from abuse, harm, or neglect. This involves having clear reporting channels and responding to issues as soon as possible.
  5. Effective security requires collaboration and partnership among various agencies, professions, and individuals. This encourages a comprehensive approach to protection and support.
  6. Holding people accountable for their actions and decisions when caring for and supporting vulnerable adults is critical. This includes preserving transparent records, learning from mistakes, and honouring people’s rights.

These principles guide our professionals, our organisation, and the communities and individuals we support in their efforts to protect adults who may be vulnerable to abuse, violence, or neglect.

Section 2 – Code of Conduct

Employee Code of Conduct

Staff, contractors, associates, and volunteers at Train Together Limited receive proper training to ensure they understand their work and the limitations of their responsibilities, including their statutory safeguarding requirements. Train Together ensures that its employees are completely informed of the concerns, risks, and vulnerabilities associated with radicalisation, as well as the process of radicalisation and how it can be detected early on. To ensure that employees are enabled to deliver upon their safeguarding responsibilities, Train Together Limited will do the following:

  • Create a safe learning environment for children, young people, and adults at risk of harm.
  • Determine those who are suffering or are anticipated to suffer in the near future and those who are in danger of radicalisation.
  • Have a mechanism for identifying concerns about adult abuse and effective techniques for responding to disclosures.
  • Report to the relevant referral agents any concerns that a child, young person, or adult is at risk of major harm or may be at risk of significant harm.
  • Collaborate successfully with others as the ‘Working Together to Safeguard Children (2022)’ initiative requires.
  • Consider local Safeguarding Children’s Board’s interagency safeguarding processes.

The following policies and procedures will be approved and reviewed by Train Together Limited:

  • Ensuring that systems for identifying children, young people, and adults at risk of harm are in place and effective and that procedures for reporting concerns are generally known.
  • Ensuring appropriate reporting and response processes for complaints of abuse by members of staff or anyone who comes into contact with learners.
  • Ensuring safe staff recruitment
  • Ensuring that employees are properly taught to carry out their safeguarding and Prevent responsibilities.

Train Together Limited will consider guidance published by the Department for Education, Ofsted, and other relevant agencies and groups, including local Safeguarding Children Boards, when formulating policies and procedures.

Learner Code of Conduct

Learners are required to adhere to the Learner Code of Conduct, which can be found in the Learner Handbook. Many of the requirements are linked to or support good safeguarding practices. These include:

  1. Treat Train Together staff and fellow learners with respect and be mindful of your responsibility to promote equality and diversity in the workplace. Train Together has a zero-tolerance policy for any form of abuse.
  2. Behave in a way which respects the needs of others to learn, teach and work.
  3. Be on time for scheduled sessions and bring the resources you need to the sessions.
  4. If circumstances impact your learning or require additional guidance or learning support, please inform your TC and/or Tutor.
  5. Always respond swiftly to emails and phone calls from your TC and/or Tutor and give 48 hours ‘ notice if you need to cancel a session.
  6. Attend scheduled sessions and achieve a minimum attendance record of 95%.
  7. Take part in the review process and update your employer on progress towards your framework/qualification.
  8. Act safely and responsibly within the requirements of Health and Safety legislation.
  9. You have a duty of care. Follow your workplace Health and Safety policy and behave in a way that does not endanger you or others.
  10. Adhere to the policies and procedures outlined in Section 3 of this Learner Handbook.
  11. Help keep the learning environment clean and safe.

Learner-on-learner abuse will not be tolerated. Learner-on-learner abuse occurs when one learner acts abusively, harmfully, or inappropriately towards another in an educational or training situation. Bullying, harassment, discrimination, physical assault, verbal abuse, and internet harassment are all examples of abuse. Train Together take actions to limit the possibility of learner-on-learner abuse occurring or going unreported:

  1. Develop and explain clear and thorough policies describing anticipated behaviour and the repercussions of abusive behaviour. Ensure learners, staff, and parents/guardians know these policies.
  2. Teach and train learners and employees to recognise and report abusive behaviour. Raise awareness about the various types of abuse and their consequences while creating a culture of respect and empathy.
  3. Review and ensure reporting is easily accessible to allow learners to report instances of abuse confidently.
  4. Foster a supportive environment in which students feel safe and supported. Encourage learners, instructors, and mentors to communicate openly so that victims of abuse are more inclined to come forward.
  5. Maintain appropriate levels of supervision in shared spaces and during activities to reduce the potential for abusive behaviour. Monitor learner interactions regularly to discover potential difficulties early.
  6. Diverse and inclusive curriculum that fosters diversity, inclusion, and respect for people of all cultures and origins.
  7. Opportunities for peer support exist in which learners can seek advice and assistance from mentors, older learners, or designated individuals in dealing with abusive situations.
  8. Take all reported instances seriously and investigate thoroughly. Address cases of abuse as soon as possible.
  9. Regular review with learners to give opportunities to raise or identify concerns.

Section 3 – Definitions of Abuse – Signs and Indicators

Train Together Limited defines abuse as follows for children, young people, and adults at risk of damage, and Train Together Limited has a zero-tolerance policy for each of the following:

Types of Abuse

Abuse is a type of maltreatment. Abuse or neglect can occur when someone causes harm or fails to act to prevent harm. They could be abused by an adult or adults, as well as a youngster or children. Bodily abuse might include beating, shaking, tossing, poisoning, burning or scorching, drowning, choking, or other bodily injury. Physical injury can also occur when a parent or carer fabricates disease symptoms or purposefully produces illness.

Emotional abuse is the repeated emotional maltreatment of a child or adult at risk of injury, resulting in severe and long-term negative impacts on their emotional development. It may imply that they are worthless or unwanted, insufficient or respected solely to the extent that they meet another person’s wants. It could involve not allowing someone to express their opinions, purposely suppressing them, or ‘making fun’ of what they say or how they communicate. It may include the imposition of age or developmentally inappropriate expectations. Interactions beyond the developmental capability, as well as overprotection and limitations on exploration and learning, or restricting participation in regular social interaction, are examples. It could include witnessing or hearing about another person’s mistreatment. It may involve extreme bullying (including cyberbullying), which causes victims to feel scared or in danger regularly, or it may affect the exploitation or corruption of others. Furthermore, ‘revenge porn’ has been designated a distinct criminal offence (Criminal Justice and Courts Act 2015). The Act makes it a crime to reveal private sexual images and films without the consent of the person who appears in them and intends to cause that person pain. All sorts of maltreatment involve emotional abuse, which may occur alone.
Sexual abuse and harassment: Sexual abuse is the act of compelling or seducing a child, adolescent, or an adult at danger of damage to engage in sexual acts. It may or may not involve a high level of violence, depending on whether the child or adult knows what is happening. Physical contact, such as rape or oral sex, or non-penetrative behaviours such as masturbating, kissing, stroking, and touching outside of clothing, may be involved. Non-contact activities may include involving children in the viewing or creating sexual imagery, witnessing sexual acts, encouraging children to engage in sexually improper ways, or grooming a child in preparation for abuse (even over the internet). Adult males are not the only ones who commit sexual abuse. Women, like other children, are capable of sexual abuse.
Peer on Peer/Child on Child Abuse can be physical and sexual abuse, sexual harassment and violence, emotional harm, online and offline bullying, and teen relationship abuse. Perceived differences like race, religion, gender, sexual orientation, handicap, or other factors can drive peer-on-peer and child-on-child abuse. It can cause considerable, long-term, traumatic isolation, intimidation, or violence against the victim.
Up skirting: Under the Voyeurism (Offences) Act 2019, up skirting is a specific criminal offence. It usually entails secretly photographing a person’s genitals or buttocks for sexual enjoyment or to cause humiliation, anguish, or anxiety. Skirting is listed as an example of peer-on-peer abuse in the revised version of Keeping Children Safe in Education.
Consent to engage in sexual activity: Consent is an agreement between two people to engage in sexual activity. Consent is the free choice to say ‘yes’ to a sexual activity. It is required for all sexual activities, including touching, kissing, and intercourse. It is always communicated clearly – there should be no mystery or doubt. There are rules governing who can and cannot consent. Any sexual activity without consent is illegal and can be hazardous.
Neglect is the chronic failure to address basic physical and/or psychological needs, likely harming health or development. Pregnancy neglect can arise because of maternal substance misuse. After a child is born, neglect can occur when a parent or caretaker fails to: – Provide enough food, clothing, and shelter (including exclusion or desertion from home)- Safeguard against physical and mental injury or danger- Provide proper supervision (including the deployment of insufficient carers) or- Provide appropriate medical care or treatment- It may also include ignoring or being inattentive to basic emotional needs. This also applies to adults at risk of harm, for whom neglect is frequently unreported or contested.
Forced Marriage: A young person or adult at risk of damage is coerced into marrying against their will. Child Sexual Exploitation (CSE) is a type of sexual abuse involving the manipulation and/or compulsion of young people under 18 into sexual activities in return for money, gifts, lodging, affection, or status. Before the abuse begins, the manipulation or ‘grooming’ process entails befriending children, earning their trust, and frequently providing them with drugs and alcohol, sometimes over a lengthy period. The abusive connection between the victim and the perpetrator involves a power imbalance that limits the victim’s alternatives. It is a type of abuse that victims and others frequently misinterpret as voluntary. Although victims can be duped into thinking they are in a love relationship, no child under 18yrs can ever consent to being mistreated or exploited (Barnardo’s 2012).
Children who run away or go missing from home: There are no specific data for the number of children who go missing or run away each year, although estimates place the total in the 100,000 range. Children may flee from difficulty at home, such as abuse or neglect, or to somewhere they wish to go. Someone else may have compelled them to flee. Whatever the reason, it is estimated that roughly 25% of missing children and young people face substantial damage. Particularly concerning are the links between minors fleeing and the risks of sexual exploitation. Children who go missing may be subject to other forms of exploitation, such as violent criminality, gang exploitation, or drug and alcohol abuse. Although looked-after children are especially vulnerable when they go missing, the vast majority of missing children are not looked after and go missing from their family home. They may suffer the same dangers as a child absent from the local authority’s care.
County lines are criminal exploitation in which urban gangs persuade, coerce, or force minors and young people to store drugs and money and/or move them to suburban areas, market towns, and coastal towns (Home Office, 2018). It is illegal and constitutes child abuse in any part of the United Kingdom. Children and adolescents can be criminally exploited in a variety of ways. Child sexual exploitation, trafficking, gang and knife violence are all examples of criminal exploitation.

Child Abuse

Child trafficking is a type of abuse. Child trafficking is a type of contemporary slavery that entails recruiting, transferring, receiving, and harbouring children to exploit them (HH Department for Education, 2011). Children are trafficked for the following reasons:

  • Sexual predation
  • Illegal activity
  • Transporting medications
  • Welfare fraud
  • Selling counterfeit goods
  • Forcible marriage
  • Household servitude
  • Compulsory labour
  • Unlawful adoption
  • Private fostering that has gone unreported

Domestic Violence: According to the Home Office, domestic violence is “any incident or pattern of controlling, coercive, or threatening behaviour, violence, or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality.”

  • Psychiatric
  • The physical
  • Sexuality
  • Economic
  • Psychological

Controlling behaviour is defined as “a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance, and escape, and regulating their everyday behaviour.” Coercive behaviour is defined as “an act or a pattern of acts of assault, threats, humiliation, intimidation, or other abuse that is used to harm, punish, or

Female Genital Mutilation: All treatments that include partial or entire removal of the external female genitalia or other injuries to the female genital organs for non-medical reasons are classified as female genital mutilation.

Radicalisation: Some young people and adults at risk of harm may be vulnerable to radicalisation for violent extremism. Concerns about radicalisation will be referred to Channel, a multi-agency panel that will offer guidance and support to prevent potential criminal activity.

Financial or Material Abuse: This refers to situations in which trust in financial matters is abused and includes theft, fraud, exploitation, pressure in connection with wills, property or inheritance, financial transactions, or the misuse or misappropriation of property, possessions, or benefits.

Bullying: Bullying someone because of their age, race, gender, sexual orientation, disability, and/or transgender will not be tolerated as Train Together Limited operates on a zero-tolerance policy, and it is also against the law.

  • Emotional: Isolation, torture (e.g., hiding items, threatening gestures)
  • Physical: shoving, kicking, punching, or any other form of aggression or intimidation
  • Racial slurs, racial symbols, graffiti, gestures
  • Sexual: Unwanted physical contact, sexually abusive remarks (including homophobic remarks), and graffiti
  • Verbal: yelling, creating rumours, and teasing
  • Cyber: All areas of the internet, such as email and the internet, chat room misuse, mobile threats via text messages and phone calls, abuse of linked technologies, such as camera and video facilities, and sexting.
  • Online: Online abuse refers to any abuse that occurs online, whether through social networks, online games, or mobile phones and includes cyberbullying, grooming, sexual abuse, sexual exploitation, emotional abuse, financial abuse, or identity fraud.

Cyberbullying is the use of electronic communication devices to bully people, such as mobile phones, tablets, iPods, laptops, and PCs. Cyberbullies use social media platforms such as Facebook, Instagram, Twitter, and WhatsApp to spread their communications. Who is most at risk? Children who use social media unsupervised. Vulnerable adults who use social media who may be more emotionally and mentally susceptible to cyberbullying:

  • Flaming Online conflicts typically take place over emails, instant messaging, or chat rooms, when furious and unpleasant comments are exchanged.
  • Denigration Sending hurtful online communications via email, instant messaging, chat rooms, or websites designed to mock someone.
  • Exclusion The deliberate exclusion of someone from a group, such as instant messaging, buddy sites, or other online group activities.
  • Outing Online sharing of secrets about someone, such as private information, images, and videos.
  • Impersonation: duping someone into disclosing personal information and then disclosing it to others.
  • Harassment Sending nasty messages to someone repeatedly online.

Cyberstalking is the continuous harassment and denigration of another person, including threats of physical damage.

Section 4 – Safeguarding Processes, Procedures and Systems at Train Together

In Response to Disclosure:

  • Abused children, adolescents, and vulnerable adults are likelier to disclose abuse information to someone they trust and feel safe with.
  • You are already helping the issue by listening to and taking seriously what the child, young person, or vulnerable adult is saying; the following suggestions are a guide to help you respond appropriately.

Actions to be performed by the person to whom the information has been disclosed:

  1. React calmly to avoid frightening them.
  2. Avoid asking direct questions not intended to clarify your understanding of the person’s words. The appropriate authority may formally interview them, and they should not be required to repeat their account on multiple occasions. (Inappropriate and excessive questioning at an early stage may also impede the conduct of a criminal investigation.)
  3. Take what the individual is saying seriously, acknowledging the difficulty in deciphering what a person with a speech disability or language issues is saying.
  4. Alert them they were not at fault and that they were correct to alert someone.
  5. Assure the child, young person, or vulnerable adult, but do not make pledges of confidentiality that will be impossible to keep in light of the developments; instead, explain that you must discuss your concerns with the Designated Safeguarding Lead, who can act.
  6. Immediately write down on the Safeguarding Incident Report Form in MyConcern all the details you know and what was stated in the child, young adult, or vulnerable adult’s own words.

Confidentiality: Every effort should be made to maintain confidentiality for all parties involved in safeguarding children, young adults, and vulnerable adults. Information should be handled and communicated only to those with a need-to-know basis, which includes the following individuals:

  • A Child and Adult Safeguarding Officer
  • The parents or carers of the suspected victim of abuse
  • Police/Social Services
    • As needed, senior management
  • The person making the claim.
  • The alleged abuser (as well as the abuser’s parents or carers if the abuser is a child or adolescent)

Reporting FGM Female genital mutilation (FGM) is a form of child abuse and violence against women that is prohibited in England and Wales under the FGM Act 2003 (“the 2003 Act”). FGM includes all treatments involving partial or whole removal of the external female genitalia for non-medical reasons.

The FGM Act 2003 (as amended by the Serious Crime Act 2015) establishes the FGM mandatory reporting duty, which obligates regulated health and social care professionals and teachers in England and Wales to report to police incidents in which they either:

  • Are informed by a girl under the age of 18 that an act of FGM has been performed on her; or
  • Look for physical signs that indicate an act of FGM was performed on a girl under 18yrs and have no reason to believe that the act was necessary for the girl’s physical or mental health or objectives related to labour or birth.

The relevant age for the duty is the girl’s age at the time of the disclosure/identification of FGM (i.e., 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 violate any confidentiality requirement or other disclosure restrictions that might otherwise apply. Reports under the duty should be made as soon as possible after a case is discovered, and the best practise is to create reports by the end of the next working day unless any of the factors described below are present; you should act with at least the same urgency as your local safeguarding processes require.

Train Together collaborates with local and relevant organisations, allowing us to make immediate referrals when needed. A longer timeframe than the next working day may be appropriate in exceptional cases, such as when a professional believes that reporting to the police will result in an immediate safeguarding risk to the child (or another child, such as a sibling) and believes that consultation with colleagues or other agencies is required before reporting. If you believe you are dealing with such a case, you are strongly advised to consult colleagues, including colleagues from other agencies.

Concerns concerning those who are not Professional Apprentices 

Apprenticeships for young people who are not apprentices at Train Together Limited, the referral must go back to the head of the organisation to which they are attached, either directly or through the Safeguarding Lead if they are on site. The referral will be made directly to Children’s Services if no organisational contact is available. The processes apply to all staff, consultants, and trainers, whether teaching, administrative, management, or support. Allegations of abuse against a member of staff can be described as:

  • Behaved in a way that has injured or may have damaged a child, adolescent, or adult at risk of injury.
  • May have committed a criminal offence against or about a child, young person, or adult in danger of harm.
  • Behaved in such a way towards a child, young person, or adult at risk of harm that she/he is unsuited to work with children, young people, or persons at risk of harm.

Following a report of abuse against a staff person, consultant, or trainer, the DSL would notify the proper authority (LADO, Police, etc.), and the member of staff, consultant, or trainer would be suspended or refused further work until the outcome of the complaint was established.

Non-Attendance of Learners

Trainer Coaches and Tutors must act immediately if an apprentice fails to appear for a scheduled session, workshop, one-to-one, or review. We require the trainer coach to:

  1. Contact the learner by telephone within 30 minutes of the non-attendance.
    • If the non-attendance is during a face-to-face or remote workshop, the contact will be made within 30 minutes of the workshop ending.
  2. If the learner does not respond, they must call the learner’s line manager.
  3. If the line manager does not respond or is unavailable, an email confirming non-attendance should be sent requesting further information about the non-attendance. Provide a response period of 48 hours.
  4. If a response to the email is not received within 48hrs, please refer the concern to ‘Team Around Learner’. If concerns persist, we request that a MyConcern is raised and the DSL contacted (see below process).

If a learner does not attend three planned sessions within a three-month period or persistently cancels or notifies the trainer coach that they cannot attend at short notice, the DSL should be notified and MyConcern raised. The DSL will then contact the apprentice to understand their reason for absence. If unsuccessful in contacting the apprentice, the DSL may contact their emergency contact to ensure their safety and well-being.


Levels of Concern

Train Together categorises levels of safeguarding need in MyConcern by applying the following principles:


  • Learners who have identified as having a learning support difficulty or disability.
  • Low-level cases will not be active but remain part of the Safeguarding Team’s broader awareness.


  • All safeguarding concerns are initially triaged as medium level before being reviewed by the DSL.
    • Medium concerns may be lowered if the case moves to a monitoring phase.
  • Medium-level cases will be active and reviewed by the Safeguarding Team as part of their review process.
  • Medium-level cases can still require intensive intervention support, but the individual is not regarded as being at immediate risk.


  • All urgent safeguarding concerns are initially categorised as high-level and require immediate action.
  • If the learner or staff member is at risk, the case will remain high. These could include:
    • Suicidal thoughts.
    • Sever mental or physical health issues.
    • Domestic violence.
    • Modern slavery.
    • Forced marriage.
    • Prevent issues including radicalisation and extremism.
    • Individuals with acute needs.
  • High-level cases will be active and require daily attention by the safeguarding team.

All staff are responsible and responsible for reporting and recording any incident or concern related to any safeguarding issue.

Reporting a Safeguarding Concern

It should be reported if there is any doubt about whether to escalate a safeguarding issue to the LADO.

Serious case reviews have highlighted that missed opportunities to record, understand the significance and share information promptly can have severe consequences for the safety and welfare of children, young people, and vulnerable adults. We require stakeholders to proactively share information to help identify, assess and record risks or concerns and identify emerging patterns and rumblings.

We use the term rumblings where potential concerns have been raised, and they represent ‘a continuous deep, resonant sound’; for example, if a learner shares information that causes concern, this should be recorded as it may form a pattern or be part of a series of events. All rumblings should be recorded using MyConcern and a conversation with the DSL. GDPR does not prevent or limit information sharing to keep children, young people, and vulnerable adults safe. Fears about information sharing should not be allowed to stand in the way of promoting the welfare and protection of our learners and staff.

All Heads of Delivery, Trainer Coach and Internal Quality Assurers have access to MyConcern as a trusted user. This means they can update MyConcern with any actions or support they have given to the learner/staff about meetings, reviews or contact they have had.

If a staff member suspects that abuse may have occurred, they should inform the DSL, who is responsible for protecting young people and vulnerable adults.  This information should be shared using MyConcern. The DSL will then investigate and may require further information. It may be necessary to contact the Local Authority Designated Officer (LADO) or refer to the Prevent Team and Channel.

If a learner makes a disclosure to their Trainer Coach, they should be reassured and be informed that we have a duty of care to record, report and store the information securely as part of the organisation’s safeguarding procedures.  This information should be sent securely to the DSL using MyConcern. Depending on the severity of the disclosure, it would be prudent for the Trainer Coach to follow up the concern with a confidential phone call or email reminder to the DSL to advise of the incoming MyConcern.  This will be suitably acknowledged and triaged, followed by an investigation/planning meeting with relevant parties internally and externally if appropriate. If the concern relates to a person being radicalised or sharing extremist views verbally, on social media, or other a Prevent Referral will be made, and this will be reported and recorded on our safeguarding system following a referral to the local Prevent Team.

In emergencies (for example, where there is a risk of recurrence or severe physical injury) where immediate action is needed to safeguard the health and safety of the individual or anyone else who may be at risk, the emergency services must be contacted by calling 999.


This policy ensures you have the knowledge to follow the Train Together Limited and Together Partnership Safeguarding and Prevent Policy. All Staff are responsible for being aware of this policy and reporting any suspicions they might have concerning abuse of young people and vulnerable adults. Train Together Limited has an appointed DSL, Bridgette Cheetham-Jones. In her absence, Charles Dall’Omo (CEO) will deputise this role.  The DSL is responsible for “championing” this issue at all levels within the company. To contact either Bridgette or Charles, call 0116 2358000. If neither are available, please ask to speak to the Safeguarding Team and you will be put through to an alternative Safeguarding Team member.

Section 5 – Employer Responsibilities

All employers must follow the guidance below:

  • Employers must ensure that all learners have access to welfare services, take breaks, and are compensated following Employment Law.
  • The employer will adequately supervise the trainee. All businesses shall ensure that their employees have an appropriately qualified workplace mentor who will engage in tripartite meetings, assist the End Point Assessment (EPA) Process, and attend the Gateway Meeting
  • Employers must follow all current and future UK guidance and legislation. All companies are responsible for protecting and promoting the well-being of all their employees in the workplace.
  • All employers collaborating with us must have strong applicable Policies, Procedures, and Risk Assessments in place. Train Together will help fill gaps in knowledge, assistance, and guidance. Customised training is provided.
  • Off-the-job training possibilities will be provided by the company, equating to 6 hours of off-the-job training per week. Furthermore, provide supervision and assistance for personal development up to appraisal.

It is well acknowledged that complete support and cooperation from companies reduce academic pressure and promote learner engagement and accomplishment.

The employer is responsible for guaranteeing that all personnel working with children, young people, and vulnerable adults are free of convictions and do not pose a threat or danger to them. All companies must make trainees aware of the need to report concerns and the procedures in place to do so.

Section 6 – Prevent and Radicalisation

Radicalisation and Preventing Radicalisation is the act or process of making a person more radical or favouring severe or fundamental changes in political, economic, or social situations, institutions, or mental habits. Extremism is described as extreme political or religious beliefs. Train Together Limited is entirely committed to protecting and supporting the welfare of all apprentices and employees. We acknowledge that preventing radicalisation is no different from preventing any other risk.

The primary goals of this policy are as follows: All personnel will understand what radicalisation and extremism are and why we must be watchful. All apprentices and employees will be aware that Train Together Limited has policies in place to keep them safe, and that Train Together Limited checks its procedures regularly to ensure they are appropriate and effective.

According to paragraph 114 of the Counter-terrorism Strategy (CONTEST) 2018, Train Together Limited strongly believes in and adheres to the government’s prevention strategy outlined in the 2015 Counter-Terrorism and Security Act and the duty it places on training providers.

All apprentices who engage with Train Together Limited in any way will attend an induction session at our academy, including, but not limited to, health and safety in the workplace, awareness of safeguarding, and British values and prevention. Our goal is to set core values for all stakeholders; the SLT have our set parameters embedded into our expectations for staff.

We actively promote all forms of equality and foster greater understanding and respect for people of all faiths (or those of no faith), races, genders, ages, disabilities, and sexual orientations. Leaders and managers champion ‘Prevent’ and ‘Safeguarding,’ leading strongly to ensure that these points are discussed in various forums and that relevant communication & promotions are a regular feature.

The Prevent Strategy will primarily:

  • Respond to the ideological challenge of terrorism and the threat posed by those who advocate it.
  • Prevent people from becoming dragged into terrorism by providing appropriate guidance and support and collaborating with sectors and institutions where there are dangers of radicalisation that must be addressed.
  • CONTEST is the Government’s Counter Terrorism Strategy, first published in July 2006 and updated in March 2009. The strategy aims to reduce the risk from international terrorism so that people can go about their lives freely and with confidence.’ CONTEST has four strands, which are often referred to as the four Ps.
  • PREVENT – to prevent people from becoming terrorists or supporting violent extremism.
  • STRIVE FOR – the prevention of terrorist attacks by interruption, inquiry, and detection
  • PREPARE – if an assault cannot be prevented, prepare to lessen its impact.
  • PROTECT – to fortify against terrorist attacks, including borders, utilities, transportation infrastructure, and densely populated areas.
What is Extremism?

According to the government, extremism is “vocal or active opposition to fundamental British values such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs,” including calls for the death of members of the British armed forces.

Terrorism is an action that endangers or causes serious violence to a person or people causes serious property damage, or seriously interferes with or disrupts an electronic system. The use of threat must be intended to influence the government or intimidate the public and must be made to advance a political, religious, or ideological cause.

What is Radicalisation?

People can be drawn into violence or exposed to extremist groups’ messages through various means. Identifying this risk requires staff to exercise professional judgment and seek additional advice. It may be combined with other vulnerabilities or be the only risk identified. Potential indicators include:

  • Use of derogatory language
  • Possession of extremist literature
  • Changes in behaviour
  • The expressing of extreme viewpoints
  • Supporting violent actions and methods
  • Collaboration with known radicals
  • Attempting to enlist others in an extremist worldview.

The government defines extremism as “vocal or active opposition to fundamental British values,” which include:

  • Personal liberty
  • The rule of law
  • Democracy
  • Tolerance and mutual respect for different faiths and beliefs.
Train Together’s Responsibilities

Train Together Limited and The Together Partnership have a legal responsibility under the Prevent Duty to make sure that:

  • Staff have undertaken training in the Prevent Duty as directed by management
  • Staff are aware of when it is appropriate to refer concerns about individuals to MyConcern/DSL
  • All parties promote and embed British Values. Democracy, Law, Liberty, Respect and Tolerance in their practice, training programmes and delivery models

Prevent is no different from any other form of safeguarding.

Staff should apply their safeguarding training and the policies outlined in this document when they become aware of a situation or incident that Prevent applies to. Our staff will use their professional judgement, training and experience decide when concerns should be referred. If in doubt, report your concerns.

Key Prevent Contacts for Train Together

Train Together are a national training provider based in Leicestershire. We keep up to date with national policy and regional updates where learners are based. However, we maintain a close connection to the local Prevent team here in the East Midlands. Here are the contact details:

Leicestershire Police Prevent Team – 0116 2486726

Leicester, Leicestershire, and Rutland Prevent Co-ordinator 0116 2733459

Website: Click here

Prevent Team Officers will liaise to discuss concerns.  They would complete a vulnerability assessment for the individual (either by engaging directly with them or based on the information given by the referrer, depending on the circumstances).

Raising a Prevent Concern

Where there are concerns of extremist activity or radicalisation, staff are encouraged to confidently raise their issues with senior management. The lead person for Prevent is the Designated Safeguarding Lead (DSL) who would normally be the first point of contact should there be concerns. Once a concern has been raised, a Prevent referral form will be completed and sent to:

Section 7 – British Values

Train Together staff are expected to preserve and promote core British values such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of those of other religions and beliefs. As such, the staff at Train Together emphasise respect, tolerance, and diversity. All learners and staff are encouraged to express their opinions and acknowledge their right to hold differing beliefs that should not be used to influence others. It is understood that apprentices or workers with low aspirations are more vulnerable to radicalism; therefore, we seek to instill confidence, self-belief, respect, and tolerance in our apprentices and staff, as well as high standards and expectations for themselves.

Section 8  – The Role of the Designated Safeguarding Lead

Responsibilities and Roles 

Our Designated Safeguarding Lead (DSL) is Bridgette Cheetham-Jones, who is fully supported by our experienced safeguarding team comprising of Board and Staff members. The safeguarding team is ready to support all individuals having safeguarding or preventing concerns. The DSL has a critical obligation to promote awareness among all employees about the welfare of children, young people and vulnerable adults and manage the referral of incidents of suspected abuse or claims.

Employees must be aware of the risk of abusive behaviour to clients from a variety of sources, including members of their family, other clients, and employees, and any suspicion, allegation, or incident of abuse must be reported to a line manager (or another manager if appropriate) for a thorough investigation. Suppose the alleged perpetrator of abuse is another employee. In that case, the circumstances will be thoroughly investigated under the Company’s Disciplinary Procedure, and a written record of the date and time of the report, including the name of the person to whom the matter is reported, will be made and sent to the DSL within 24 hours.

Concerns about the safety and well-being of children, young people, or vulnerable adults can arise in a variety of ways and in a variety of settings, such as when a child reports or exhibits signs of abuse, when someone suggests that a child is at risk or that a colleague is an abuser, or when an individual witnesses or hears about abuse in another organisation. Act quickly and professionally in all cases of suspected abuse is critical:

Any allegation made by a child, young person, or vulnerable adult against a member of staff, another student, or volunteer should be immediately reported to the DSL (who has responsibility under this policy); Train Together has a duty of care to the individual and staff member, student, or volunteer against whom the allegation has been made.

Designated Staff with Responsibility for Abuse Protection

When allegations are made against anyone who may be part of the children or young person’s employment, Train Together Limited will retrospectively confer with the Local Authority Designated Officer (LADO) in their area. They will provide guidance on appropriate next steps for referral and investigation and ensure that all situations are handled in compliance with safeguarding procedures.

Train Together Limited Team in charge of Safeguarding:

Designated Safeguarding Lead and Head of Quality

Bridgette Cheetham-Jones


T: 07300 825919

CEO and Deputy Safeguarding Officer

Charles Dall’Omo

E :

T: 07856 747179


All employees are trained in Safeguarding and Prevent.

Among the responsibilities are:

  • Ensuring that concerns about safeguarding and well-being are documented using the Safeguarding and Wellbeing Form
  • Ensuring that incidents of suspected abuse or allegations are properly referred to appropriate agencies.
  • Advice and help on safeguarding problems are provided to personnel, consultants, and training.
  • Keeping all records of any safeguarding referral, complaint, or concern (even if the concern does not result in a referral)
  • Ensuring that the Safeguarding and Prevent Policy is available to all employees, consultants, trainers, and apprentices.
  • Putting in place safer recruitment practices
  • Ensuring that Safer Recruitment rules are followed by apprentices applying to programmes that allow them to work with children, young people, and adults at risk of harm.
  • Ensuring that identity badges are supplied to employees, consultants, and trainees.

Section 9  – Safer Recruitment

Train Together Limited aims to recruit and develop skilled and motivated employees who will provide exceptional service to the local community, and an effective recruitment and selection process is a major contributor to this goal. Train Together Limited is committed to safeguarding and promoting the welfare of children and adults at risk of harm and expects its employees to share this commitment.  The Disclosure and Barring Service (DBS) was established on December 1, 2012, by the Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedom Act 2012. Its purpose is to reduce the risk of harm to children and vulnerable adults. All members of staff, consultants, and trainers working in settings with children, young people, or vulnerable adults must have a current DBS (within three years) and submit a copy to the Designated Safeguarding Lead.  The Safeguarding Children and Safer Recruitment in Education guidance, which went into effect on January 1, 2011, recommends that Train Together Limited keep and maintain a single central record of recruitment and vetting checks and the various staff records kept as part of normal business. (Last updated 26 April 2012). The employer’s/workplace’s responsibility is to ensure their staff and volunteers have the necessary DBS disclosures.

Train Together Limited will not conduct DBS checks for apprentices. All staff who participate in the recruitment process must receive recruitment and selection process training, and every interview panel must include at least one member who has received Safer Recruitment training.  While it is criminal to knowingly employ someone barred from working with children or adults at risk of harm in regulated activity, it is possible to allow such a person to work in controlled activity, subject to specific safeguards. The Directors of Train Together Limited will decide whether to employ someone barred from working with children or adults at risk of harm in regulated activity. For further information, request to see the Safer Recruitment and Selection Policy by emailing includes not discriminating against people who have protected characteristics (Equality Act 2010), which are as follows:

  • Age
  • Disabilities
  • Gender reversal
  • Civil partnership and marriage
  • Maternity and pregnancy
  • Race
  • Belief and religion
  • Sex
  • Sexual preference

Section 10  – Staying Safe Online

Apprentices and employees are provided information, advice, and guidance on keeping safe when using the internet during induction and as part of ongoing standards and training. They are urged to appreciate that people are only sometimes who they say they are online. If they are unhappy or concerned about what they read or see online, they are instructed to seek help immediately. We advise apprentices and employees of the 4Cs of online safety:


Content encompasses any material that is published on the internet, including text, images, and videos. When using the internet, you may encounter illicit, inappropriate, or harmful material. This includes radicalisation, extremism, pornography, false news, racism, misogyny, self-harm, and suicide, as well as anti-Semitism and radicalisation.


The subject of contact is the potential damage that you may encounter while interacting with other users online. This includes exposure to inappropriate commercial advertising and peer pressure. With the intent of manipulating or exploiting a child, young person or vulnerable adults for sexual, criminal, financial, or other reasons, adults may pose as children, young people or vulnerable adults on occasion.


Conduct refers to the online behaviour of individuals. Online conduct such as cyberbullying, for instance, can heighten the probability of injury or even induce it. Conduct also encompasses activities such as sending or receiving pornography or sharing nude and semi-naked images.


Risks associated with online gambling, inappropriate advertising, phishing, and financial scams are discussed. Young people and children may be directly exposed to these hazards.

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