Safeguarding Policy

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Safeguarding Policy

1. Aim of the Policy

Express English College is a Manchester-based International School located at 130 Princess Road, Manchester, an area with an excellent transport network and easily accessible. Express English College offers quality teaching and tutoring services to international students wanting to study in the UK. Our college accepts international students aged 16 and over. We implement a duty of care to those below the age of 18, and to vulnerable adults who attend the college. Our safeguarding policy aims to ensure that processes are designed to keep all the above protected against any form of harm. All students and visitors under the age of 18 and those who fall into the category of vulnerable adult are entitled to be protected under this policy regardless of their race, nationality, age, gender, gender identity, sexual orientation or religious beliefs.

2. Terminology used

The following language is used throughout this policy. It is important that all are familiar with the terms used, and where a term refers to a named person, they know who that person is and how they can be contacted.


Any student or visitor who is under the age of 18.

What is a Vulnerable Adult?

Any student or visitor to the school whose personal circumstances may make them more vulnerable than many other adults. Important factors that may classify someone to be a ‘vulnerable adult’ may include: level of English (students with a low level of English may not fully understand instructions or be able to effectively express a concern); physical disability (e.g., sight/hearing impairment, mobility impairment, speaking impairment); special needs (e.g., learning difficulties such as dyslexia); lack of local knowledge (unfamiliar with the local vicinity or customs).

What is an allegation?

Claim of unlawful act committed against a child or vulnerable that can create harm, or may pose a threat, to a child or vulnerable adult.


Mistreatment towards a child or vulnerable adult. Abuse includes physical, emotional, sexual and neglect.


Any form of abuse by physical, mental or any spoken actions perpetuated by a single person, or by more than one individual, which intimidate others, or which may be seen as unacceptable behaviour towards others.

Designated Safeguarding Lead (DSL)

A named member of staff, trained to an Advanced Safeguarding (Specialist) level for the purposes of undertaking the role of DSL, who has the responsibility to make sure that our policy and procedures are fit for purpose, enabling all college participants to feel safe and secure.

Local Safeguarding Children’s Board (LSCB)

Main mechanism for agreeing how the relevant agencies in each local area will collaborate to safeguard and encourage the welfare of children, and for ensuring the efficiency of what they do.

The Children Act (2004) requires each local Children’s Board authority to establish a Safeguarding Board.

English Express college English comes under the Manchester City Council safeguarding board.

3. Duty of Care

The college’s responsibility to look after the well-being of all students, particularly vulnerable adults and children and help them to reach their potential.

Responsible adult

This is any adult over the age of 18, who works at the college and is expected to follow this policy and all procedures within it.

Designated safeguarding leads

The designated safeguarding officer for the college is: Ayub

The deputy designated safeguarding person is: Edward

Roles and responsibility

The DSL has the overall responsibility of ensuring this policy is followed by all relevant individuals, and that the policy remains up-to-date and fit for purpose. All responsible adults have a duty to report any safeguarding concerns they have, to the DSL or DDSL.

Under 18’s

This policy applies to all students under the age of 18, regardless of their, race, ethnicity, religion, gender, sexual orientation and background.

Adult responsibilities

All staff who have contact with those under the age of 18 have responsibilities to safeguard them. They must have a secure and up-to-date understanding of safeguarding and how to protect those under 18. They must know who to contact and be able to recognise signs of harmful behaviour. To do this, they must undertake relevant training.

Other policies that contain reference to taking care of those under 18’

• Prevent Policy

• Abusive Behaviour Policy

• Attendance Policy

• Safer Recruitment Policy (Recruitment policy)

• Student Handbook/Under 18 Student Handbook

• Homestay Agreement

Documents/legal frameworks

• The Children Act 1989

• Local Government Act 2000

• The Sexual Offences Act 2003

• Children Act 2004

• Protection of Freedoms Act 2012

• Counterterrorism and Security Act 2015

• Children & Social Work Act 2017

The following publications were used in the drafting of this policy:

• Working Together to Safeguard Children (December 2020)

• What to do if you’re worried a child is being abused (March 2015)

• Keeping Children Safe in Education, Statutory guidance for schools and colleges (September 2020 – January 2021)

• Information Sharing, Advice for practitioners providing safeguarding services to children, young people, parents and carers (July 2018)

4. Code of conduct

The code of conduct is there for all responsible adults to follow. A separate student code of conduct should be given to students at their induction, which includes all learners including those under 18.

The purpose of the code of conduct is to facilitate a safe environment for all, and especially for those under the age of 18, for them to feel safe and so can build trust with adults. Equally, it protects vulnerable adults and enables them to trust us and safely enjoy their time in college.

Respecting your position of trust

The Sexual Offences Act (2003) states that any person in a Position of Trust who engages in sexual activity of any sort with students under the age of 18 is breaking the law: therefore, all responsible adult staff who encounter under 18’s are in a position of trust.

Setting standards

All responsible members of staff should be set, and set for themselves and their peers, clear standards of appropriate behaviour when working with children, vulnerable adults, and of course students in general. These expectations are:

– To always act in a professional manner (see ‘language and behaviour’ below; appropriate dress code, attitude, and demeanour, etc)

– To promote healthy and appropriate behaviour when seen as a ‘role model’.

– Ensure British Values (respect; safety; trust; tolerance; care and kindness)

– Keep language and behaviour appropriate (i.e., no swearing, no use of offensive or potentially offensive language, no use of inappropriate or potentially inappropriate images or other materials in class/in college, etc)

5. Interacting with children (under the age of 18)

Whilst interacting with under-18 students, all college staff should;

– Ensure that we treat each student with dignity and upmost respect.

– Be kind, positive and always encouraging.

– Treat everyone equally.

– Not allow any inappropriate touching.

– Not to engage in any sexually provocative games, activities or studies of any kind

– Avoid socialising with those under the age of 18, outside of college, unless the college has a planned trip or activity that involves being outdoors.

For one-to-one contact, such as one-to-one classes, tutorials, or meetings, all staff should:

– Arrange the room and seating so that meetings are open and visible, unless required to be private. All room numbers, times and names should be made known to appropriate managerial staff, such as the Academic Manager.

– Staff SHOULD NOT meet a child alone in a closed space, under any circumstances.

Appropriate appearance

All students and staff should wear suitable (and appropriate) clothing. This should be clothing that DOES NOT offend anyone in any way (e.g., those displaying offensive slogans or images.)

Students in the classroom

While all students are normally expected to attend classes and be on time every day, this is particularly important for under-18s and vulnerable adults, as it is our responsibility to know where they are during college hours. For this reason, if an under-18 or vulnerable adult is absent, teachers must report this fact to reception by 9:30 so that the student or student’s home-stay host can be called.

Teachers must check that the materials they use in the classroom will not be harmful in any way to under-18s. This should not normally be an issue, assuming materials are chosen so as not to cause offence to any student. However, there may be some under-18s who are not as mature for their age as we might expect, or as they seem to be: care and consideration when selecting images or other lesson resources remains a key value here. If a teacher is unsure, they can contact the Academic Manager or Assistant Academic Manager.

While bullying is clearly against college rules, staff should be particularly sensitive to the possibility of under-18s being bullied. Ensure that all students treat others with respect and don’t allow students to talk to one another in an inappropriate way – even if they intimate that said language/behaviour was a joke or not to be taken seriously.


EEC homestay is provided by Host Internationals. Please refer to their policies and procedures for safeguarding.


The college will usually send a member of staff out to meet the student if they are arriving by airport transfer. They will have a sign with them with the student’s name and the EEC logo. This member of staff is DBS checked and will take the student to their enlisted accommodation before coming to the college, so that they can settle in.


If any instance arises where a staff member is worried that a fellow member of staff may be engaging  

in, or may have engaged in, any inappropriate or illegal activity with students, including the use of inappropriate language or materials in or out of class, they are required by law to report such concerns to the DSL. This may also include concerns about actions, language or attitudes that could potentially be inappropriate or result in harm/offence.

Confidentiality and support will be given to any staff member who raises such concerns.

6. Child protection

The Child Protection Policy relates specifically to the protection of children (students under the age of 18) from abuse. Abuse can include physical, emotional, sexual or psychological abuse, as well as neglect.

Nominated Designated Safeguarding Lead (DSL) for Express English College is Ayub

The deputy DSL (DDSL) is Edward

TEL: 0161 232 0302

Adult duty:

All responsible adults have a duty to respond to and report any child protection concern or allegation. This includes:

– Being aware of something yourself – from your own conversations or according to your own interpretation of events/actions (+ see ‘whistleblowing,’’ above)

– Being told about something by another person. In all cases, it is important that the concern or allegation is taken seriously and reported immediately to the DSL/DDSL in confidence. Specific procedures must be followed if an under 18 discloses something.

Recognising Different Forms of Abuse

Our duty of care to young people and vulnerable adults extends to watching out for signs of potential abuse.

Here are some signs to look out for that may indicate a child or vulnerable adult is suffering from abuse.

These are just some of the recognisable signs:

– Physical abuse

– Unexplained bruises, burns etc

– Wearing clothes to cover their injuries

– Refusal to get changed for different activities

Sexual Abuse

• Changes in behaviour – being aggressive, withdrawn, clingy or having difficulties sleeping (this may be obvious from the student’s attitude or level of alertness)

• Avoiding the abuser – afraid of a specific person.

• Sexually inappropriate behaviour – using sexually explicit language, inappropriate tone in class, etc

• Physical problems – developing health problems.

• Personality changes, seeming insecure.

• Displaying difficulty concentrating and learning.

• Giving clues – hinting that the abuse is happening without revealing it outright.

Emotional abuse

• Seeming overly affectionate towards strangers

• Demonstrating a lack of confidence

• Not appearing to have a close relationship

• Being aggressive or nasty towards others

• Acting in a way or knowing about things that you wouldn’t expect them to know

• Displaying difficulty controlling strong emotions/having extreme outbursts

• Being isolated

• Lacking social skills


Displaying poor appearance and personal hygiene.

Having unwashed clothes

Having inadequate clothing, e.g., not having a winter coat

Seeming hungry

Showing untreated injuries, medical and dental issues

Having repeated injuries described or implied as being accidental

Having recurring illnesses or infections

Missing medical appointments

Displaying tiredness/exhaustion

Specific Areas

In addition to the types of abuse mentioned above, four other specific types of abuse that staff must be aware of are:

Child Sexual Exploitation (CSE);

Female Genital Mutilation (FGM);

Peer-on-Peer Abuse (which includes bullying, cyberbullying, sexual violence and sexual harassment);

Honour-based Violence (HBV).

Notes on Child Sexual Exploitation.

Child Sexual Exploitation (CSE) is a type of sexual abuse. Children in exploitative situations and relationships receive implied or explicit ‘rewards’ such as gifts, money or affection as a result of

performing sexual activities or others performing sexual activities on them.

CSE does not always mean a physical contact as it can happen online: through peer pressure or as a form of cyber bullying.

Notes on Female Genital Mutilation (FGM)

Definition: A procedure where the female genitals are deliberately cut, injured or changed, but where there is no medical reason/justification for this procedure to be done.

FGM is sometimes referred to as “female circumcision” or “cutting”. FGM is usually carried out on young girls between infancy and the age of 15, most commonly before puberty starts. It is illegal in the UK and is considered child abuse in Law.

FGM is recognised as a painful procedure and can seriously harm the health of women and girls. It can also cause long-term problems with having sexual intercourse, giving childbirth and can negatively affect mental health. Responsible adults should be aware that a person who has suffered FGM should ask for help without embarrassment or fear and be encouraged to do so where possible. Any causes for concern must be reported to the DSL. FGM is now illegal in the UK and investigations into alleged FGM abuse can escalate, involving the expertise of specialist police officers.

7. Procedure for reporting allegations or suspicions of abuse

It is the responsibility of each staff member at Express English College to report disclosures of abuse, allegations of abuse, or interpretations of conversations, actions, or attitudes that may be indicative of abuse to the Designated Safeguarding Lead (or DDSL) without delay. If you have a real concern, do not leave reporting it for fear of getting involved in something that is not your business, nor to avoid getting someone into trouble.

It is NOT for staff to decide whether a suspicion or allegation is true. All suspicions as well as allegations or disclosures of abuse must be taken seriously. Reporting it to the DSL or DDSL will enable staff to know that they have acted according to the law. The DSL or DDSL is trained to deal appropriately with any information or suspicions reported.

What to do if abuse is suspected or disclosed.

• Listen to the child, rather than questioning, or ‘putting words into their mouth’.

• Offer him / her reassurance; but do not make promises (including of confidentiality)

• Take all the information that the student says seriously, allowing them to speak without interruption. You can invite them to talk (more) using encouraging or soothing sounds or expressions of sincerity, understanding, etc

• Accept what is heard without investigating or questioning.

• Do not overreact. This includes alleviating feelings of guilt and isolation. (This means that you should try to balance empathy with professionalism – do not react with worry, fear, suspicion, emotional responses, offers of physical comfort, etc). You are aiming to communicate that you believe the child/take them seriously, and you are a person to be trusted, but you will not offer inappropriate levels of affection/support.

• Advise that you will give full support, but you must pass the information on, explaining what you intend to do.

Record the conversation precisely, as soon as possible.

Record keeping:

In any situation where an allegation has been raised, all records, information and confidential notes should be kept by the Designated Safeguarding Lead in separate files in a locked room

or in secure electronic files. The staff member referring on the disclosure to the DSL/DDSL must, if possible/feasible, have made notes during or directly after the disclosure. If they cannot, they must aim to make comprehensive notes as soon as possible. The college can supply relevant documentation for the recording of information.

The DSL must also compile a report. Details can be transferred from the staff member who has reported the disclosure or allegation. Both the staff member reporting the disclosure/allegation and the DSL must include the following information:

• The name of the vulnerable child, adult or person(s) in general.

• Home address/accommodation address.

• Age/Date of Birth.

• Name of parent or guardian.

• Telephone numbers.

• Details of what has prompted concern.

• Include the date and time of any specific incidents, as accurately as possible.

• If the adult, child or vulnerable person(s) has spoken to someone about such things, what was said should be recorded as accurately as possible.

• The name of any individual who may been identified in the allegation. Further details must include their relationship to the child/vulnerable person, etc.

• Any additional details – as closely as possible retaining the child or vulnerable person’s original wording/gist (don’t guess or overdramatize, etc)

• Any action taken must be kept and recorded. The records are likely to be updated further, upon completion of said actions.


The DSL/DDSL will collect a statement from the student.

Any further questioning should be avoided, apart from important clarification of factual detail.

The DSL should contact the local authorities within 24 hours by completing the MCC Designated Officer Referral form and sending it to: [email protected] or by phone: 0161 234 1214

No decisions must be made without referring the case to the local authorities There will be initial discussion between the DSL and the relevant local authorities, during which some actions will be agreed, which will include: immediate actions to protect the child (or vulnerable adult); when and what parents should be told (as appropriate); how to proceed regarding the adult facing the allegation (such as possible suspension pending investigation).  

Procedure if the DSL or a senior manager is accused

If an accusation is made against the DSL, the matter must be reported to the deputy DSL or to the Operation Manager immediately.


All staff receive training in basic safeguarding awareness and refresher training, both face-to-face and online, on an annual basis. The online training has a test component that helps to check that staff have understood the content, before a certificate is generated.

Members of the Designated Safeguarding Team are trained to the level of Advanced Safeguarding for the Designated Safeguarding Lead (Specialist Level 3) and this training is refreshed for the Designated Safeguarding Team every two years.

Records of training that staff have attended are kept in the SCR.

8. Safer Recruitment

• Staff members handling learners aged below 18 should sign a declaration affirming that they do not have prior convictions and are eligible to work with under-18 students/vulnerable adults.

• Staff members working with under-18 students must agree to the college applying for an enhanced DBS check on their behalf once appointed, and the start date of their role is dependent upon a satisfactory outcome (‘none recorded’). If they have an existing enhanced DBS, it must be in-date or registered on the updates service and the certificate number seen and noted by the college’s interviewing panel.

• As part of our recruitment procedure, references confirming the applicant’s suitability to work with under 18s must be provided.

• All staff appointed to work with under 18 students must undergo at least Level 1 safeguarding training upon their appointment and all staff must read the safeguarding policy of the college. It is also a requirement for new staff members to read and sign receipt/understanding of all college procedures and policies governing staff conduct, child protection, and health and safety, before starting their work. Staff induction will include reference to safeguarding under-18s and vulnerable adults, reviewing the key points made in this policy document.

Staff Recruitment and Safety Procedure/Timeline

1. Job descriptions and person specification documents:

Clearly defined safeguarding responsibilities relating to the role must be stated.

2. Advertising:

All jobs advertised outline the commitment of the college towards promoting student welfare and safeguarding children. The advertisement states that enhanced DBS checks will be conducted, and references will be requested and checked.

Candidate Shortlisting and Interviews for Employment:

• Candidates are selected from CVs and covering letters sent in response to a job advertisement, based on role requirements, right to work, etc

• Candidates attend a face-to-face or online interview (if for an online role or for health reasons). Interviewees receive the job description and our safeguarding policy.

• All applicants are notified that their references will be followed up, in the event of a successful interview, and enhanced DBS application will commence, if the applicant does not already possess an in-date enhanced DBS. Applicants must also provide proof of their qualifications and supply suitable photo identification, with additional proof of address x2.

• EECs store the copies of the original certificate and passport with the permission of the applicant. All copies are dated and signed by the interviewer. A secure HR file will be created for the successful applicant. Completed references and enhanced DBS results will be kept on file.

• The school discards all notes and details of unsuccessful interviewees within one month.

Pre-appointment Clearance: Summary:

Applicants should undergo an enhanced DBS check (OR police officer check if overseas) or before the start of employment.

Records of checks are stored in the HR system

The College must obtain the DBS certificate number for checking purposes. Usually the College applies for the staff DBS (the College covers the application fees/renewal fees)

Where applications do not have an in-date DBS (or current) the college will administer this, using:

9. Welfare Provision

Welfare is the responsibility of all members of staff. Students meet the Welfare Officer at their induction and pictures of all staff are on display and pointed out to all students, so that they are aware of who to approach with any concerns they may have. However, students can become confused or forgetful. Therefore, if you think a student is upset, uncomfortable or distressed in any way, and do not know who to go to, or if they approach you to say they are unhappy, please speak to them yourself. Once you have spoken to them, please inform the DSL or Deputy DSL of the incident.

In addition, weekly welfare meetings are arranged with all under 18s to ensure that there are no issues with any aspect of their stay. The Welfare Manager conducts these meetings with under 18 students

All students are given the college reception and emergency phone numbers, and the emergency phone bearer has access to full student contact details, including emergency contact details

(24/7): 0044 (0)7483911770

Missing Students

Student missing from class

If a child has not arrived to their lesson within ten minutes of it starting (or ten minutes after the break), the academic manager or reception staff will endeavour to contact the student by phone, or by contacting the homestay host/group leader.

Group Leaders

Closed groups of students under the age of 18 come with at least one group leader, with no more than 15 students per leader. Any safeguarding concerns regarding this arrangement should be reported to the DSL.

Student Missing from Social Activity

Should an under 18 go missing from an activity, the activity leader must endeavour to contact the missing student and immediately inform the college (or emergency phone bearer if outside office hours). If no contact is made with the student within one hour, the DSL or Deputy DSL will consider further action, including contacting the police and the child’s parents/guardian.

Use of Risk Assessments

In addition to general risk assessments (building, fire, prevent), the College has separate risk assessments for each activity type taking place within and outside the school. Each risk assessment contains a section that focuses specifically on care of under 18s. Risk assessments are reviewed every six months and may be updated as and when necessary (for example in case of roadworks or changes to the layout of a building to be visited). General risk assessments must be read and signed following each review or update. For activity-based risk assessments, the leader of the activity is required to read and sign the RA each time they run an activity. This ensures that they are aware of any updates and of any information that needs to be passed on to students.

Supervision ratios and social activities

• The maximum ratio of students to adults in an activity including under 18s is 5 to 1. The following applies to all out-of-school social activities:

• The activity leader must read and sign the relevant risk assessment prior to the activity.

• Under 18s must be given clear instructions on what to do if they get separated from the group.

• The activity leader must have a list of names and phone numbers (where possible) of all under 18s in the group.

• Under 18s should have the College reception phone number and the College emergency phone number.

• When using public transport (train, bus or tram), or walking from one location to another, the students should stay together with the activity leader.

• It is common practice to take photographs of social activities. However, the activity leader must be aware that parental consent is required before using photographs of under 18s for publicity.

10. First Aid

Express English College maintains a First Aid Policy and ensures that it has appropriately trained first aiders on staff: their identities will be made clear to students and staff via the use of posters/pictures, and this information will be given to students on their induction day. The first aid lead is Gabi/Ayub.

First Aid kits are kept in the reception area, and excursion and sports group leaders always bring a first aid kit with them.

11. Online safety for students

All staff, and teachers, must periodically remind students of the potential dangers of sharing personal information on the internet, uploading photographs, online harassment and the potential for scams.

Inappropriate websites are automatically restricted at college. Please see the college’s E Safety Policy on our website.

12. Behaviour & discipline

All students are made aware of the standards of behaviour expected of them while at the college. This is outlined in the student handbook and emphasised at induction. Please refer to the handbook for details.

Instances of inappropriate behaviour, observed by staff or students, will be discussed with the relevant individual by an appropriate member of staff. If this persists and could be considered a safeguarding issue, then it will be fully investigated as per safeguarding policy and procedure.

13. Fire safety

The College has fire safety procedures in place and full details of what to do in the event of an evacuation can be found on notices throughout the building. All students are informed of the fire evacuation procedure during their first-day induction. In the event of an evacuation, teachers must take their registers and check that all students are present at the relevant assembly point, paying attention to Under 18s.

The fire marshal is Gabi/Ayub.

Please see the fire safety policy and the signage around the school for more information.

14. Radicalisation and prevent

The College Prevent Duty Policy applies to all staff and students at the college, including Under 18s. The College recognises that Under 18s may be particularly vulnerable to radicalisation. All staff members receive PREVENT training and are made aware of the following:

• What Prevent is and the importance of understanding its contexts

• How the College is meeting its Prevent duty

• How to recognise vulnerable students

• What to do if concerned

• The need to exemplify core British values and to challenge extremist views.

All students and group leaders are made aware, through induction and pre-arrival information, of the following:

– ‘Prevent’ Terminology and relevant core British Values

-The importance of maintaining and supporting a supportive and tolerant society within the school

-Any changes in college rules, particularly relating to IT and to the need to avoid extremist websites

That they must report any concerns they have (about anyone) and be aware of who to report to: Ayub, DSL, or Edward, DDSL.

15. Emergency Contact

Students are supplied with, and reminded about, the Emergency Phone number which is printed on their student cards. Students are advised to use this number or to call 999 for the most serious/extreme emergency issues) if they get into difficulty. This also extends to the reporting of grievances.

The Welfare Officer/Academic Manager and Assistant Academic Manager are trained to deal with all issues involving grievance, emergencies and safeguarding counselling. The role is always DBS checked and they obtain necessary training to deal with welfare issues relating to students below the age of 18.

Students find the above information in their student handbook; it is also placed in their welcome pack when they join the College. The welcome pack is given to students on the first day of their academic year/first day in college (induction).

Emergency Phone Number: 07483911770

This number is also used, in the event of an emergency, by accommodation providers.

Review: Reviewed December 2023 (AA). This document to be reviewed by the Management Team not less than every six months. Next review due June 2024. It will also be subject to any changes based on UK law.