Concerns about Mental Health

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Mental Health difficulties can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation. Poor or deteriorating mental health can also be a safeguarding concern in its own right. Our staff know to be alert to behavioural signs that suggest a child may be experiencing mental health or be at risk of developing one.

If a staff member has a concern about a child’s mental health, no matter the level of the child’s emotional difficulties, they must speak to the school’s DSL who will evaluate if the child is at risk of immediate harm, and if so, will escalate to the appropriate level of support which includes speaking to the school lead for Mental Health.

If a child is experiencing low moods, low self-esteem and general anxiety, our school mental health lead will be able to provide some advice about some self-accessed support through relevant approved wellbeing websites and apps. If, however, the child is presenting with a concerning level of low mood and anxiety for a period then our mental health lead in partnership with the DSL will discuss with the child and their parents/carer to explore options of support.

If someone is experiencing suicidal thoughts but they do not need physical input from A&E, then consideration will be given to accessing support from the Single Point of Access (SPA)/Crisis team. If a referral for targeted mental health support is required, then a referral through SPA will be made.

If, however, a child/young person is at immediate risk the school will recommend they need to be sent to A&E or dial 999.

More information can be found in the Mental health and behaviour in schools guidance, colleges may also wish to follow this guidance as best practice. Public Health England149 has produced a range of resources to support secondary school teachers to promote positive health, wellbeing, and resilience among children. See Better Health Every Mind Matters for links to all materials and lesson plans. youth-suicide-prevention-7-minute-briefing-may-2023.pptx

What all staff need to do to respond if Abuse, Neglect and Exploitation is suspected or been disclosed.

At Roots Federation, we adopt a whole Federation approach and safeguarding is everyone’s responsibility. Staff and volunteers, and governors must comply with our safeguarding procedures as set out below:

Concerns about child-on-child abuse

In most circumstances, incidences of pupils hurting other pupils will be dealt with under our school’s behaviour policy (which can be found here). Our child protection policy will apply to all incidents that raise safeguarding concerns where the alleged behaviour:

• Is serious, and potentially a criminal offence.

• Could put pupils in the school at risk.

• Is violent.

• Involves pupils being forced to use drugs or alcohol.

• Involves sexual exploitation, sexual abuse, or sexual harassment, such as indecent exposure, sexual assault, upskirting or sexually inappropriate pictures or videos (including the sharing of nudes and semi-nudes). If a pupil makes an allegation of abuse against another pupil:

• Staff must record the allegation on CPOMs and report to the DSL, staff should not investigate the matter.

• The DSL will assess and consider the relevant next steps which may include, speaking with the child and parents, accessing relevant consultation lines provided to schools by the Local Authority, making a request for support to Children’s Services as well as the Police if the allegation involves a potential criminal offence or the Child and Adolescent Mental Health Service (CAMHS), if appropriate.

• The DSL will consider whether a risk assessment or a safety and support plan would be beneficial for any children involved, including the victim(s), the child(ren) against whom the allegation has been made and any others affected, with a named person they can talk to if needed. This should include consideration of all aspects and areas of the school environment and beyond, for example off-site activities and school transport.

• The DSL will speak to the child and their parent/s or carers to share the concerns, gain their views and consent to liaise with other agencies if there are any identified risks and unmet needs.

• If the incident is a criminal offence school have a duty to report this and thereafter work closely with the Police (and other agencies as required) while protecting children and/or taking any measures to manage risk. For incidences which involve significant harm and/or a potential criminal offence, the DSL will endeavour to gain consent but may override this should not gaining consent increase the risk to a child.

Our DSLs are committed to ensuring that where concerns are raised about child-on-child abuse, incidences are taken seriously and dealt with fairly. DSLs will consider all information available to them and ensure that any action or decision is proportionate for all children involved, and that such decisions do not disproportionately impact on their access to education, although at times some restrictions or adaptations may be required to manage identified risk.

Reference will be made to Development Matters and Birth to Five to establish age appropriate behaviours alongside those detailed in the Behaviour Policy.

Creating a culture where children feel safe in school and minimising the risk of all forms of abuse.

We recognise the importance of taking proactive action to minimise the risk of any form of abuse, neglect, and exploitation irrespective of from whom and where this comes from, including child-on child abuse. Creating a supportive environment where children can feel confident in reporting incidents is key to our safeguarding culture in Roots Federation.

We expect all staff to:

• Challenge any form of derogatory or sexualised language or inappropriate behaviour between peers, including requesting or sending sexual images.

• Be vigilant to issues that particularly affect different genders, for example, sexualised or aggressive touching or grabbing towards female pupils, and initiation or hazing type violence with respect to boys.

• Ensure our curriculum helps to educate pupils about appropriate behaviour and consent.

• Ensure pupils can report abuse using our reporting systems easily and confidently. All children are taught ‘Zones of Regulation’ and are encouraged to talk to their adults. Adults regularly check in with all children as part of daily practice.

• Reassure victims that they are being taken seriously.

• Be alerted to reports of sexual violence and/or harassment that may point to environmental or systemic problems in the school or elsewhere that could be addressed by us updating policies, processes, and the curriculum, or could reflect wider issues in the local area that should be shared with our safeguarding partners.

• Support children who have witnessed sexual violence, especially rape or assault by penetration. We will do all we can to make sure the victim, and alleged perpetrator(s) and any witnesses are not bullied or harassed.

• Consider intra-familial harms (adults close to the child and family) and any necessary support for siblings following a report of sexual violence and/or harassment.

Our staff are trained to understand:

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• How to recognise the signs of child-on-child abuse and know how to identify it and respond to reports.

• Even if there are no reports of child-on-child abuse in school, it does not mean it is not happening – staff should maintain an open mind and attitude of “it could happen here.”

• If they have any concerns about a child’s welfare, they should act on them immediately rather than wait to be told; and always speak to the DSL should they be unclear,

• Children may not always make a direct disclosure and therefore they must be aware that:

▪ Children can show signs or act in ways they hope adults will notice and react to; it may be that their difficulties emerge from behaviour when they do not have the language to express themselves.

▪ A friend of the child may share information to a staff member or make comments; professionally curiosity is key, do not fear exploring the information and asking open ended questions.

▪ Staff may overhear a conversation between children.

▪ A child’s behaviour may change suddenly with no clear reason or precipitating event that might offer some explanation. ▪ Some children can face additional barriers to telling someone, for example they have a disability, special educational need, age gender, ethnicity, and/or sexual orientation etc. ▪ One child’s concerning/abusive behaviour towards another could be an indicator of that child having been harmed themselves.

If a child makes a disclosure to a member of staff or volunteer:

All staff are aware they should always be prepared as children can disclose spontaneously to anyone anywhere.

Roots Federation is situated within the County of Hertfordshire which has a rich and diverse population. We cannot, and do not, assume that all children and their families have the ability, understanding, language and resilience to convey any difficulties they may experience. It is key to our Federation ethos to recognise the needs of children and their families and to recognise and provide support where English may not be their first language and/or the children or family members have special educational needs; and without doing so may impede their ability to represent their voice, wishes and feelings.

All staff know that we place the voice of children at the centre of everything we do and endeavour to place their best interests at heart. We ensure we know who our children are, staff are encouraged to be curious by speaking and listening to children whilst respecting any protected characteristics. We hope our children have confidence and trust in our staff, believing they will be taken seriously and be supported with their issues or concerns sensitively.

Staff also know that children may not always feel ready or know how to tell someone that they are being abused, neglected, or exploited and do not always recognise their experiences as harmful.

We listen to children by:

• Showing patience regardless of a child’s age as we know they can find it hard to find the words to express themselves.

• Encouraging children to tell their story in their own words.

• Avoiding the use of leading questions or suggesting what may have happened, instead we maintain genuine curiosity, and only ask open-ended questions/prompts.

We reassure children by:

• Making sure a child does not feel they are in trouble and that they have done the right thing in speaking to staff

• We let a child know it is not their fault as children are often made to feel blame by those harming them

• Never promising confidentiality and being transparent about our obligations to share information if we are concerned that they are at risk of harm

• Helping children to understand how we plan to support them and their family and let them know what action we will need to take next to support them.

Recording concerns

Our staff know that reporting concerns is a procedural requirement when safeguarding and promoting the welfare of children. Our staff are clear that they must:

• Record all conversations relating to any level of concerns on CPOMs; ensuring that the record is as detailed as possible, is factual, does not contain assumptions or personal judgement and captures the child’s account in their own words.

• Inform the DSL about their concern as soon as possible; where the concern involves a disclosure or concern that the child is at risk of harm they must inform the DSL immediately.

Our staff are aware that such information is confidential and should be shared with the DSL only who may hold additional information about the child and their family and therefore can form a view on its significance and whether any action is required. Staff will not share information amongst themselves and will not share the information outside of the formal reporting process unless asked to by the DSL. This ensures that information is shared without delay enabling the DSL to carry out any necessary functions of their role whilst upholding confidentiality for the child and their family.

What school and college staff should do if they have concerns about a child

Roots Federation is committed to ensuring that all children feel safe and comfortable to share and report any concerns and/or allegations about their personal experiences at home, in the community, online or regarding a member of staff or other children in the school. As outlined above, all our staff are clear on the importance of listening to and supporting children when making disclosures, and the need to reassure them.

Our staff are aware that children can share information with anyone in our school but there are clear reporting processes when such information sharing raises concern about their welfare. Children may talk about worries and anxieties around friendships and school life which they need to support with but on other occasions they may share information about their family life which indicates that the children and their family may be in need of help and/or fear or experiences which cause staff to be concerned about whether they have been harmed or are at risk of being harmed. Where such situation arises, our staff are clear on the reporting processes.

Any member of staff, including supply teachers, contract workers, volunteers, governors/trustees, and visitors at Roots Federation who has any concerns about a child’s welfare should:

• Maintain an attitude of ‘it could happen here’ where safeguarding is concerned and always act in the best interests of the child. Never promise a child confidentiality.

• Reassure the child they have done nothing wrong and if appropriate explain to them how they will be supported and who you will need to share information with.

• Record what the child or others have disclosed using their language - or describe what you have seen or suspect and your rational for this. Also ensure you make a note of any injuries observed or described by the child (if it is the latter two).

• Consider if the child needs medical attention and if so, prioritise ensuring they receive this.

• You must never delay reporting your concerns about the welfare of a child and always act immediately by reporting/speaking to the school’s DSL/deputies. • Record what the child or other has disclosed in their language or describe what you have seen or suspect and your rational for this (if it is the latter two).

The DSL or deputy will:

• Use Hertfordshire threshold guidance to initially assess the concerns raised and consider the impact on the child’s welfare and safety. They will also review the child’s record in order to establish if there have been any previous concerns (records help to establish relevant history and risk factors for example even if a concern appears low level on the surface, a series of incidents can highlight patterns of ongoing abuse and neglect.) The DSL will use the ‘Continuum of Need’ guidance to support their analysis and rationale for any decision.

• The DSL or deputy will speak to the child to verify their wishes and feelings, contact the child’s parents or carers to either inform them of the concerns and also to gauge their view (it will be at the discretion of the DSL team to carefully consider if this action may place a child at further risk, e.g. if the child has disclosed abuse and neglect caused in the family home).

• If the child has not suffered significant harm as defined by the Children Act, DSL may also decide to seek advice through the range of Hertfordshire departmental non child protection advice lines. The purpose of these are to support DSLs to consider the best options to engage children and their families with an offer of early help support, preventing escalation where possible but also request for support via Children’s Services where necessary. Examples of this are managing any support for the child internally via the school’s or college’s own pastoral support processes and/or undertaking a Families First Assessment

• If it is immediately apparent that a child has suffered significant harm or is at risk of harm e.g. suffered abuse, neglect and/or exploitation, the school’s DSL will make a referral to Children’s Social Care to request support at the earliest opportunity; consent will be gained where appropriate. If there has been a crime committed within the circumstances of the abuse, they will also report this to the Police.

What will the Local Authority Children’s Social Care do?

Within one working day of a referral being made, a social worker should acknowledge its receipt to the school’s DSL and plan about the next steps and the type of response that is required. This will include determining whether:

• The child requires immediate protection and urgent action is required.

• Any services are required by the child and family and what type of services.

• The child is in need and should be assessed under section 17 of The Children Act 1989. Working together to safeguard children provides details of the assessment process.

• There is reasonable cause to suspect the child is suffering, or likely to suffer, significant harm, and whether enquiries must be made, and the child assessed under section 47 of the Children Act 1989. Working Together to Safeguard Children provides details of the assessment process.

• Further specialist assessments are required to help the Local Authority to decide what further action to take.

• The DSL or deputies should follow up if this information is not forthcoming.

Anyone working/volunteering with children can make a referral, if in an emergency staff are unable to locate or do not have time to inform DSL of a serious concern, the following process must be followed without delay.

Making a referral to Children’s Services and/or requesting support

Professional referrals are made using the online referral form located on Hertfordshire Safeguarding Children Partnership website (consent is needed from parents and carers, unless to do so may place a child at risk).

If someone is in danger or a crime has also been committed call the Police on 999.

Out of hours (17:30-08:00 and weekends) call 0300 123 4043.

Members of the public (non-school staff), parents, carers, children, and young people can call Children’s Services at any time of the day or night on 0300 123 4043.

This link provides leaflet for parents and carers HSCP Family Leaflet (hertfordshire.gov.uk).

What children and young people need to know and do to report safeguarding concerns (Abuse, Neglect and Exploitation).

At Roots Federation we cultivate a culture of openness and transparency and want to make it clear to all our pupils/students that we are available at any time to listen to you and will always take your concerns seriously, however small you may consider them to be. Our pledge is:

• We will ensure we provide you with the space away from public areas for you to talk. • We will listen without judgement and endeavour to respect your wishes and feelings.

• We want you to feel safe and we will be honest about our duty to prioritise your wellbeing and longer-term safety, this means, depending on the circumstances, we cannot offer you total confidentiality. We understand that this may create uncertainty, but we are confident that often when matters are dealt with as they emerge the longer-term prospects can be much improved for you and your family.

• We will respect your place but if we consider that you have suffered significant harm or are at risk of harm, we will need to share this information so that you and your family can be offered the right support. We will be clear on what information needs to be shared, with whom and how it might be used.

• When the concerns suggest you may benefit from early help support this may include considering support to your parents and carers with matters that will improve your situation.

• We will provide a named mentor for you so that you can have the confidence and trust to know that you have someone to go to at school if you are feeling vulnerable and experiencing difficulties.

• Your education and welfare is important to us and we want to reassure you that your experience at school remains positive, and you feel safe.

What you can do to report concerns:

• You can speak to any member of staff of your choice. Those staff will listen and support you, but we have a team of DSLs in our school who have a specific role to support children and therefore it is likely that the staff members will talk to them or arrange for you to. If you are being abused, neglected, or exploited you can call Children’s Services at any time of the day or night on 0300 123 4043.

If you are in immediate danger and/or think a crime has/is being committed, you can call the Police on 999.

You can contact the NSPCC Helpline by calling 0808 800 5000 or email help@nspcc.org.uk

Risk Management Plan (RAMP) and Safety and Support Plan (S&SP)

RAMP - When there has been a report of sexual violence, or and harassment, the DSL (or a deputy) will make an immediate Risk and Needs Assessment for both the alleged victim and the perpetrator. The RAMP is to enable the DSL to use their critical thinking and consider what the needs of any child/ren are, analyse what are the risks and what measures can be put in place to protect children and keep them safe from further harm. Risk assessments will be recorded (paper or electronic) and kept under review.

The school risk assessment is not intended to replace the detailed assessments of other expert specialist assessments, but the DSL will seek and share information from other agencies where required to inform the school’s understanding form a multi-agency perspective so that a holistic approach in supporting and protecting children can be strengthened.

We are aware that children who are victims of sexual violence and sexual harassment will find the experience stressful and distressing, this can also impact on the family and can cause the child adverse effect on their educational attainment and can be exacerbated if the alleged perpetrator(s) attends the same school or college. The RAMP will take this into account and plan accordingly on the gravity of a situation on treat incidents on a case-by-case situation.

Keeping Children Safe in Education, Part Five Sexual Violence and Sexual Harassment provide statutory duty for schools and colleges.

The RAMP is the responsibility of Roots Federation leadership and management team, and it is critical that parents and cares place confidence and trust in our school by working with us and supporting the plan.

All schools and colleges are at liberty to adopt any form of risk management and safety planning protocols, at Roots Federation we use the following types of risk management to not only support children presenting with Harmful Sexual Behaviour but more commonly we experience a range of specific safeguarding issues that vulnerable children and young people are faced with, examples of these cited in Part one and Annex B KCSiE.

10. Online Safety and Filtering

We recognise the importance of safeguarding children from potentially harmful and inappropriate online material, and we understand that technology is a significant component in many safeguarding and wellbeing issues. Roots Federation Governing Body ensures that our DSL takes lead responsibility for online safety and understanding the filtering and monitoring systems and processes we have in place, alongside their safeguarding and child protection duties.

To address this, our Federation aims to:

• Have robust processes (including filtering and monitoring systems) in place to ensure the online safety of pupils, staff, volunteers, and governors.

• Protect and educate the whole school community to be safe and responsibly use technology, including mobile and smart technology.

• Set clear guidelines for the use of mobile phones for the whole school community.

• Establish clear mechanisms to identify, intervene in, and escalate any incidents or concerns, where appropriate.

Our approach to online safety is based on addressing the following 4 categories of risk as identified in Keeping Children Safe in Education:

Content – being exposed to illegal, inappropriate, or harmful content, for example: pornography, misinformation, disinformation, including fake news, and conspiracy theories., racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, and extremism

Contact – being subjected to harmful online interaction with other users, for example: child-on child pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes Conduct – online behaviour that increases the likelihood of, or causes harm, for example: making, sending, and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography), sharing other explicit images and online bullying; and

Commerce – risks such as online gambling, inappropriate advertising, phishing, and/or financial scams.

To meet our aims and address the risks above, we will educate pupils about online safety as part of our curriculum. For example:

• The safe use of social media, the internet and technology.

• Keeping personal information private.

• How to recognise unacceptable behaviour online.

• Ensuring children know not to meet up with a person they have met online without a safe adult.

• How to report any incidents of cyber-bullying, ensuring pupils are encouraged to do so, including where they are a witness rather than a victim.

We will also:

▪ Train staff, as part of their induction, on how to keep themselves safe online as well as children, in line with the Federation’s online safety policy This needs to include issues for example: cyber-bullying, the risks of online radicalisation, and the roles and responsibilities around filtering and monitoring. All staff members will receive refresher training as required at least once each academic year.

▪ Educate parents/carers about online safety through letters and emails sent directly to them. We will also share clear procedures with them, so they know how to raise concerns about online safety.

▪ Make sure staff are aware of any restrictions placed on them with regards to the use of their personal mobile phone and cameras,

▪ staff are allowed to bring their personal phones to school for their own use, but will limit such use to non-contact time when pupils are not present

▪ staff will not take pictures or recordings of pupils on their personal phones or cameras.

▪ Mobile phones can only be used in rooms where children do not attend. I.E Staff rooms and offices

• Make all pupils, parents/carers, staff, volunteers, and governors aware that they are expected to sign an agreement regarding the acceptable use of the internet in school, use of the school’s ICT systems and use of their mobile and smart technology.

• Explain the sanctions we will use if a pupil is in breach of our policies on the acceptable use of the internet and mobile phones.

• Make sure all staff, pupils and parents/carers are aware that appropriate staff designated by the Headteacher or Principal, have the power to search pupil’s phones, as set out in the dfe’s guidance on searching, screening and confiscation if there is a concern regarding a child’s safety or a crime in which case the Police will be contacted.

• Put in place robust filtering and monitoring systems to limit children’s exposure to the 4 key categories of risk (described above) from the school’s IT systems.

• Carry out an annual review of our approach to online safety, supported by an annual risk assessment that considers and reflects the risks faced by our school community.

• Provide regular safeguarding and child protection updates including online safety to all staff, at least annually, to continue to provide them with the relevant skills and knowledge to safeguard effectively.

• Review the child protection and safeguarding policy, including online safety, annually and ensure the procedures and implementation are updated and reviewed regularly.

11. Managing Safeguarding Concerns or Allegations made about staff, including supply teachers, volunteers, and contractors

Roots Federation allegations policy’ is compliant with:

• KCSiE, Part four

• Hertfordshire Safeguarding Children Partnership Procedures Manual, Section 5.1.5 Managing Allegations Against People who work with Children and Young People

• Developing and implementing a low-level concerns policy (Farrer & Co), which provides detailed guidance and examples.

This section of our policy is a reflection and extension of Roots Federation’s wider staff code of conduct.

All staff and volunteers at Roots Federation hold positions of trust and are expected to uphold safe working practices outlined in our staff code of conduct.

A 'position of trust' refers to any role where an adult holds power or influence over a child due to the nature of their work (either paid or voluntary). As defined in the Sexual Offences Act 2003 (Sections.16-24) and further clarified by the Crown Prosecution Service, it is a criminal offence for anyone in a position of trust to engage in sexual activity with a child in their care – even if that child is aged 16 or 17 and legally considered to have reached the age of sexual consent (16); this includes both in-person and online interaction, within or outside of employed/voluntary hours.

A breach of trust occurs when an adult working or volunteering with children crosses established boundaries in their professional relationship with a child or young person through inappropriate behaviour that involves an abuse of their position or authority. The behaviour itself does not need to be illegal to constitute a breach of trust – even when the child or young person is over the age of consent (16). Examples include:

• A 19-year-old Youth Worker at a youth club initiating a personal relationship with a 16-year old club member.

• A teacher engaging in an intimate or sexual relationship with a Sixth-Form student.

These behaviours undermine professional integrity and breach safeguarding standards at Roots Federation regardless of legal consent due to the imbalance of power and the professional duty of care.

Section 11 of the 2004 Children’s Act states that schools and colleges should have clear policies aligned with HSCP Procedures for dealing with safeguarding concerns or allegations against those working in or on behalf of schools and colleges in a paid or unpaid capacity, i.e. members of staff, including supply teachers, volunteers and contractors. These policies must clearly distinguish between:

Allegations – a claim or assertion that someone has done something illegal or wrong, typically one made without proof. The Harm Threshold (see section Managing Allegations, below) for an allegation is when a person working or volunteering with children in a position of trust has or may have:

• Behaved in a way that has, or may have harmed a child/young person;

• Possibly committed a criminal offence against/related to a child/young person;

• Behaved toward a child/young person in a way that indicates he or she would pose a risk of harm;*

• Behaved or may have behaved in a way that indicates they may not be suitable to work with children/young people;*

*These categories can include behaviour that may have happened outside of an organisation that might make an individual unsuitable to work with children/young people.

Concerns about the quality of care/practice - is an accusation, not of a child protection nature, that the care/practice provided does not meet the expected standards. As with quality in other fields, it is an assessment of whether something is good enough and whether it is suitable for its purpose.

Complaints – an expression of dissatisfaction about actions or the lack thereof. Concerns may reflect a worry requiring reassurance, while complaints assert that something is unacceptable

Levels of Concern and Allegation

There are two levels of Concerns and Allegations relating to adults (in both paid and voluntary roles) working with children either directly and/or online:

1. Low-Level Concerns These are behaviours by one or more adults (paid or voluntary) which are inconsistent with Roots Federation staff code of conduct but do not meet the Harm Threshold (see above under definition of Allegations) and are referred to as ‘Low-Level Concerns’. Examples include repeated breaches of the staff code of conduct in relation to safeguarding.

2. Allegations These are behaviours by one or more adults (paid or voluntary) that do meet or may meet the Harm Threshold (see above under definition of Allegations). Such cases require referral within one working day to the Local Authority Designated Officer (LADO) and potentially other statutory bodies such as the police or children’s social care.

Low-Level Concerns and Allegations may emerge as a result of either observed suspicions or direct disclosures made by a child. In assessing the potential harm and impact to a child or young person, DSLs will consider the four categories of abuse – physical, emotional, sexual and neglect – as well as any safeguarding elements related to exploitation. Detailed definitions of these terms can be found in Chapters 4 and 9 on this policy.

The Harm Test is explained in the Disclosure and Barring service Guidance: Making barring referrals to the DBS and Section 31(9) of the Children Act 1989 (as amended by the Adoption and Children Act 2002).

Managing Low-Level Concerns (those that DO NOT meet the Harm Threshold for Allegation)

As part of our whole Roots Federation approach to safeguarding, we are committed to fostering an open and transparent culture where all concerns involving adults working in or on behalf of Roots Federation (including supply teachers, volunteers, and contractors) are addressed promptly and appropriately.

Creating an environment where all concerns can be shared responsibly, with the right person, recorded accurately, and handled with care is essential to keeping our children and young people safe.

We aim to:

• Enable all stake holders to identify inappropriate, problematic, or concerning behaviour early and encourage them to do so.

• Reduce the risk of abuse by acting preventatively.

• Ensure that all adults working/volunteering in or on behalf of Roots Federation understand and adhere to professional boundaries consistent with our ethos and values at Roots Federation.

A ‘Low-Level’ Concern does not imply insignificance. It refers to any behaviour – however minor – that causes a sense of unease or a ‘nagging doubt’ about whether an adult’s behaviour:

• Is inconsistent Roots Federation’s staff code of conduct, including inappropriate conduct outside of work, and

• Does not meet the harm threshold or is otherwise not serious enough to consider a referral to the LADO.

Examples may include (but are not limited to):

• Being over friendly with children

• Having favourites

• Taking photographs of children on their mobile phone, contrary to school policy

• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door, or

• Humiliating children.

Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is ultimately intended to enable abuse. Low-level concerns may arise in several ways and from a number of sources. For example: suspicion; complaint; or disclosure made by a child, parent or other adult within or outside of the organisation; or as a result of vetting checks undertaken.

The role of the Case Manager for Low-Level Concerns

In our Federation, the Case Manager is a senior leader—for example, the Headteacher, Principal, or Designated Safeguarding Lead (DSL). If concerns involve the Headteacher or Principal, the Chair of Governors or Trust, or Proprietor fulfils this role.

When a Low-Level Concern is raised (including third-party reports), the Case Manager or their nominated deputy will:

• Speak with the person who raised the concern (unless this was raised anonymously)

• Speak with the individual subject to the concern

• Identify and interview any other involved parties or witnesses

The information gathered will help us to categorise the type of behaviour and determine what further action may need to be taken. This information will be recorded in writing along with the rationale for our decisions and action taken.

The Case Manager, a nominated deputy, or Chair of Governors will respond to reports of Low-Level Concerns in-line with the schools’ internal due processes for managing safe-staffing, our response may include the following:

• Prioritise the safety and wellbeing of any alleged victim and all other pupils

• Share details only with those who need to know to maintain confidentiality

• Conduct further inquiries with relevant children, staff, parents, or witnesses

• If there are reasonable grounds, launch a formal internal investigation following the school’s internal processes

• Consult Human Resources on possible breaches of the staff code of conduct, Teachers’ Standards, or TA regulations to assess disciplinary thresholds

• Inform the subject of the concerns and outline available support during the inquiry

• Determine when to allow the subject to present their account

• Review all evidence and decide on an outcome

• If no risk of harm is found, consider additional training or monitoring for the staff member

• If new information raises serious risk or meets the harm threshold, refer the matter to the LADO

Roots Federation fosters a safeguarding culture where every staff member is professionally curious. We:

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• Clarify expected staff behaviour and help them distinguish it from concerning conduct

• Encourage prompt reporting of Low-Level Concerns

• Address unprofessional behaviour early and support corrective measures

• Handle concerns sensitively and in proportion to their nature

• Use reported concerns to identify and address any weaknesses in our safeguarding systems

Record keeping for Concerns and Allegations

It is vital that our stakeholders know how to share information about concerns for professionals and volunteers working with children. To ensure safe working practice:

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• All staff and volunteers must record the details of the Low-Level Concerns and submit them to the Headteacher/Principal

• Records are confidential, stored securely, and comply with the Data Protection Act 2018 and UK GDPR

• If a pattern of inappropriate behaviour emerges, the Case Manager will decide on disciplinary action, or if the Harm Threshold is reached, refer to the LADO (per KCSiE Part Four, Section One)

• We will review and revise relevant policies or training to address any school-culture factors that enabled the behaviour

• Records of concerns are retained by Roots Federation until the individual reaches retirement-age or for the next ten years, whichever period is longer

Managing Allegations (those that DO MEET the Harm Threshold for LADO)

When concerns/allegations meet the harm threshold Roots Federation is required to comply with both Part Four of KCSiE and Hertfordshire Safeguarding Children Partnership Procedures Manual Section 5.1.5 Managing Allegations Against Adults Who Work With Children and Young People

All staff and volunteers at Roots Federation are required to immediately report any level of concerns about behaviour and/or conduct of an adult working/volunteering with children towards a child to leadership and management. This includes reporting adults who are providing out of school activities/leasing Roots Federation facilities.

These are Roots Federation procedures for managing cases of concerns/allegations that meet the Harm Threshold and may indicate a person is a risk of harm to children if they continue to work in their present position, or in any capacity with children and young people. This is the process and the threshold criteria we apply if it is alleged that anyone working in our school or a college, including supply teachers, volunteers and contractors has:

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