Policies

Child Protection and Safeguarding Policy

Contents
1. Introduction
2. Ethos
3. Implementation
4. Statutory Framework
5. The Designated Safeguarding Lead
6. Supporting Children
7. Dealing with Disclosure
8. Record Keeping
9. Confidentiality
10. Procedure
11. Communication with Parents
12. Allegations involving Staff/Volunteers
13. Safer Working Practice
14. Safer Recruitment
15. Keeping Children Safe in Education (2023)

Appendices
A. Types of Abuse
B. Managing Allegations and Escalation
C. Referral Routes
D. How to Respond to a Disclosure
E. Prevent and Radicalisation
F. Restraint
G. Useful Contacts
H. Cause for Concern Reporting Form
I. What Regent Guardians staff should do if worried about a Child in Need/Child at Risk

1. Introduction
All children and young people will have the same protection regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity. We are committed to anti-discriminatory practice and recognise the additional needs of children from minority ethnic groups and disabled children and the barriers they may face, especially around communication.
This Child Protection and Safeguarding Policy applies to all staff, including senior managers, paid staff, local guardians, drivers, host families, volunteers and sessional workers, agency staff, students or anyone working on behalf of this organisation.

This policy remained in force throughout the response to coronavirus (COVID-19). Regent Guardians upheld the AEGIS Covid-19 Safe Charter and the BSA Covid Safe Charter details of which can be found via these links:
https://aegisuk.net/aegis-covid-19-safe-charter/
https://regentguardians.com/wp-content/uploads/2020/07/BSA-COVID-Guardian-Charter-1.pdf

We believe that a child or young person should never experience abuse of any kind. We have a responsibility to promote the welfare of all children and young people and keep them safe.

Purpose:
● To inform all staff of their responsibilities for safeguarding children and young people and to enable everyone to have a clear understanding of how these responsibilities will be carried out.
● To inform on the Somerset Safeguarding Children Board’s Inter-agency Child Protection and Safeguarding Procedures and on other areas’ services where Regent Guardians are operating.

Regent Guardians Ltd has a responsibility to provide a safe and secure environment in which children can thrive.

All Regent Guardians staff, including the Primary Carer in the Host Family, therefore receive appropriate safeguarding training during their induction training so that they are knowledgeable and aware of their role in the early recognition of the indicators of abuse or neglect and of the appropriate procedures to follow. Training is in two parts:
● an online course provided by the NSPCC called ‘Child Protection: An Introduction’ as recommended by Local Safeguarding Partners (LSPs) or by the AEGIS Level 1 online training or a similar suitable alternative. Regent Guardians ensures this training is updated every 2 years;
● Safeguarding and child protection updates are provided as required, but at least annually, to provide staff with relevant skills and knowledge to safeguard children effectively.

All temporary staff/volunteers are made aware of the policies and procedures and trained by the Designated Safeguarding Lead including Child Protection and Safeguarding Policy.

We recognise the Director of Children’s Services, within the Local Authority has the overarching responsibility for safeguarding and promoting the welfare of all children and young people in the area. They have a number of statutory functions under the Children Acts 1989 and 2004 which make this clear. This policy is to add detail to expectations of staff/volunteers to expect specific duties to happen in relation to children in need and children suffering, or likely to suffer, significant harm, regardless of where they are or who takes any further action.

“Children are best protected when professionals are clear about what is required of them individually, and how they need to work together.” (Working Together to Safeguard Children 2023)

1a. Terminology
Safeguarding and promoting the welfare of children refers to the process of protecting children from maltreatment, preventing the impairment of health or development, ensuring that children grow up in circumstances consistent with the provision of safe and effective care and taking action to enable all children to have the best outcomes.
Child Protection refers to the processes undertaken to protect children who have been identified as suffering or being at risk of suffering significant harm.
Staff refers to all those working for or on behalf of Regent Guardians, full time or part time, temporary or permanent, in either a paid or voluntary capacity.
Child includes everyone under the age of 18 years old. Those over 18 but on a roll of an education setting are referred to Adult services for support.
Parent refers to birth parents and other adults who are in a parenting role, for example step-parents, foster carers and adoptive parents.

2. Ethos
● Establish and maintain an environment where Regent Guardians staff and volunteers feel safe, are encouraged to talk and are listened to when they have concerns about the safety and well-being of a child.
● Ensure children know that there are adults in the company whom they can approach if they are worried.
● Ensure that children, who have additional/unmet needs, are supported appropriately. This could include referral to Early Help services or specialist services if they are a child in need or have been / are at risk of being abused and neglected.
● Protect children and young people in our care from maltreatment and impairment.
● Consider how children may be reminded about safeguarding, including online safety, when in the care of Regent Guardians.

Those working with children are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a child, staff members should always act in the interests of the child and develop a culture where Safeguarding is everyone’s responsibility.

All staff, including host families, should be aware that children may not feel ready or know how to tell someone that they are being abused, exploited or neglected, and/or they may not recognise their experiences as harmful. This should not prevent staff from having a professional curiosity and speaking to the Designated Safeguarding Lead (DSL) if they have concerns about a child.

Implementation, Monitoring and Review of the Child Protection Policy
This policy applies to all pupils, staff, parents, volunteers and visitors. This policy is reviewed annually by the company. It is implemented through Regent Guardians induction and training programme, and as part of day to day practice. Compliance with the policy is monitored by the Designated Safeguarding Lead (DSL) through staff performance measures and day to day practice.

4. Statutory Framework
To safeguard and promote the welfare of children, Regent Guardians acts in accordance with the following legislation and guidance:
● The Children Act 1989 and 2004
● United Convention of the Rights of the Child 1991
● Data Protection Act 2018 and the General Data Protection Regulation
● Safeguarding Vulnerable Groups Act 2006
● The Education Act 2002
● Somerset Safeguarding Children Partnership Inter-agency Child Protection and Safeguarding Children Procedures (Effective Support for Children and Families)
● Keeping Children Safe in Education (DfE, September 2023)
● Special educational needs and disability (SEND) code of practice: 0-25 years. HM government 2014
● Section 26, The Counter Terrorism and Security Act 2015 (PREVENT duty)
● Female Genital Mutilation Act 2003 (Section 74, Serious Crime Act 2015)
● Sexual violence and sexual harassment between children in schools and colleges; DfE May 2018.
● The Prevent Duty 2015
● Voyeurism Act 2019
● Cardiff and the Vale Regional Safeguarding Children Board (RSCB) Information Pack
● Keeping learners safe – Welsh Government 2015 158/2015
● The rights of children and young persons (Wales) measure 2011
● National Wales Safeguarding Procedures

Working Together to Safeguard Children (DfE 2023) requires Regent Guardians to follow the procedures for protecting children from abuse which are established by the South West Child Protection Procedures (www.swcpp.org.uk) and Somerset Safeguarding Children Partnership. Regent Guardians follows similar safeguarding procedures dependent upon which geographical area it is working in at the time.
Regent Guardians ensures that they have appropriate procedures in place for responding to situations in which: a child may have been abused or neglected or is at risk of abuse or neglect: a member of staff or volunteer has behaved in a way that has, or may have, harmed a child or that indicates they would pose a risk of harm.

5. The Designated Safeguarding Lead
Jenny Chan is the Designated Safeguarding Lead (DSL) for Regent Guardians. A written job specification is provided for this role. The DSL is always available for staff in Regent Guardians or other professionals to discuss any safeguarding concerns. On the rare occasion when the DSL is not available, Rachel Debenham fulfils the duties of a Deputy DSL (DDSL).

5a. Responsibility of the Designated Safeguarding Lead (DSL)
● The DSL refers all cases of suspected abuse or neglect to the Local Authority Children’s Services (Safeguarding and Specialist Services) and/or Police (cases where a crime may have been committed) or to the Channel programme where there is a radicalisation concern.
●Liaise with other key stakeholders or equivalent to inform them of issues- especially ongoing enquiries under Section 47 of the Children Act 1989 and police investigations or Section 42 where adults are concerned
●Act as a source of support, advice and expertise to staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with relevant agencies.
●Support staff members around requests for involvement to other agencies.
●Have clear systems and processes for Mental Health concerns.
●Utilise, implement, scrutinise and monitor the use of Early Help Assessments in Regent Guardians.
●Work with relevant staff in the provision to ensure Regent Guardians services are safe and secure.
●Ensure recording child safeguarding and child protection files are correctly drawn up with effective chronologies and regularly reviewed to scrutinise any patterns or drift/outstanding actions
●Ensure Regent Guardians’ Single Central Record is correct at all times and safe recruitment procedures are upheld.
●Ensure Regent Guardians risk assessments are maintained and completed to support staff and children feel safe.
●Undertake the necessary training and ensure it is effectively and regularly shared within the setting
●Liaise closely with the student’s school, parents, host family, driver to ensure the best outcome for the student

5b. Training
The DSL undergoes certificated Level 3 DSL training at least every two years. The DSL also undertakes Prevent (WRAP) awareness and disseminates this information in addition to this training. Other requirements are:
●Understand the assessment process for providing early help and intervention, for example through locally agreed common and shared assessment processes such as early help assessments (EHA).
●Have a working knowledge of how different local authorities conduct a child protection case conference and a child protection review conference and be able to attend and contribute to these effectively when required to do so.
●Ensure each member of staff has access to and understands Regent Guardians safeguarding and child protection policy and procedures, especially new and part time staff.
●Be alert to the specific needs of children in need.
●Understand and support the school or college with regards to the requirements of the Prevent duty and able to provide advice and support to staff on protecting children from the risk of radicalisation.

Have a working knowledge of the Link Programme which is being rolled out in conjunction with the Anna Freud Foundation and the DfE to support Mental Health concerns.
●Be able to keep detailed, accurate, secure written records of concerns and referrals with actions and outcomes.
●Obtain/disseminate access to resources and attend any relevant or refresher training courses.
●Encourage a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures Regent Guardians may put in place to protect them.
●Attend the Local Authority’s education DSL conferences in Regent Guardians primary regions that are held regularly for updates
The DDSL also holds a Level 3 DSL certificate and attends annual update training on all matters relating to Safeguarding & Child Protection.

5c. Raising Awareness
The DSL ensures Regent Guardians policies are known, understood and used appropriately.
●Ensure Regent Guardians Safeguarding and Child Protection policy is reviewed annually, and the procedures and implementation are updated and reviewed regularly, and work with governing bodies or proprietors regarding this.
●Ensure the Safeguarding and Child Protection policy is available publicly and parents are aware of the fact that referrals about suspected abuse or neglect may be made and the role of Regent Guardians in this.
●Link with the Somerset Safeguarding Children Partnership (SSCP) and other Safeguarding boards to make sure staff are aware of training opportunities and the latest local policies on safeguarding.
●Where children leave Regent Guardians, ensure their file for safeguarding is appropriately and securely forwarded as necessary and obtain notification of its safe arrival.
●Ensure all Regent Guardians staff receive suitable induction and on-going training in Safeguarding and know how to access more information or seek clarification.
●Ensure all Regent Guardians staff have access to and have read and understood the Staff Code of Conduct.

6. Supporting Children
Safeguarding and promoting the welfare of children is everyone’s responsibility. In order to fulfil this responsibility effectively, all professionals should make sure their approach is child centred. This means that they should consider, always, what is in the best interests of the child.

Children who may require early help will be offered early intervention through Early Help support services for families.

All staff are aware of the early help process, and understand their role in identifying emerging problems, including sharing information with other professionals to support early identification and assessment of a child’s needs. It is important for children to receive the right help at the right time to address risks and prevent issues escalating. This also includes staff monitoring the situation and feeding back to the DSL any ongoing/escalating concerns so that consideration can be given to a request for involvement to Children’s Services in liaison with the child’s school if the child’s situation does not appear to be improving.

Staff and volunteers working within Regent Guardians will also be alert to the potential need for early help for children also who are more vulnerable. For example:
●Children with a disability and/or specific additional needs
●Children with special educational needs
●Children who are acting as a young carer
●Children who are showing signs of engaging in anti-social or criminal behaviour especially if there is a concern that it is exploitative
●Children missing education
●Children whose family circumstances present challenges, such as substance abuse, adult mental health or learning disability, domestic violence
●Children who are showing early signs of abuse and/or neglect including affluent neglect
●Children with poor attendance or high medical absence
●Children suffering peer on peer abuse / child on child abuse

Regent Guardians staff members are aware of the main categories of maltreatment: physical abuse, emotional abuse, sexual abuse and neglect. They are also aware of the indicators of maltreatment and specific safeguarding issues so that they can identify cases of children who may need help or protection.
(See Appendix A for information on further descriptors of abuse and specific safeguarding issues)

6.1 Children with SEN and disabilities
There’s a concern sometimes, for children with SEN and disabilities, that their SEN or disability needs are seen first, and the potential for abuse second. If children are behaving in particular ways or they’re looking distressed or their behaviour or demeanour is different from in the past, our staff need to think about that being a sign of the potential for abuse, and not simply see it as part of their disability or their special educational needs.

6.2 Emergency Contacts for Children
Keeping Children Safe in Education (2023) says that provisions should have at least two emergency contacts for every child in case of emergencies. Regent Guardians endeavour to maintain at least two contact numbers for every child on roll.

6.3 Mental and Emotional Health of Children
It is widely recognised that a child’s emotional health and wellbeing influences their cognitive development and learning as well as their physical and social health and their mental wellbeing in adulthood. Regent Guardians offers clear support and guidance for children both when they are at school and with a host family.

6.4 Local Issues and Contextual safeguarding
Safeguarding incidents can be associated with factors outside the setting and between children outside of school. This is called contextual safeguarding. Regent Guardians staff are aware of the definition of contextual safeguarding when reporting concerns and must ensure all information and background detail is given to the DSL when discussing concerns. We are aware that in different regions there will be many local issues that can impact on the safeguarding of children and we endeavour to be aware of all local issues and work with children to ensure they are safe.

6.5 Homestays
Regent Guardians students can stay with fully inspected local host families at various times during their education in the UK. An integral part of Regent Guardians procedures is to carry out enhanced DBS check on all household members or any regular visitors staying over at the same time if aged 16 or over. These checks are renewed every three years. As well as ensuring full Safer Recruitment processes are carried out when appointing home stays, Regent Guardians also carries out spot checks on home stay providers (see Regent Guardians Safer Recruitment Policy).
Regent Guardians understands that even low level concerns tend to grow. If an individual either has or may have behaved in a way that indicates they may not be suitable to work with children then we need to consider whether there is a ‘transferable risk’. Relevant questions are asked of all Host Family members to tease out any such concerns in the initial stages and during annual checks.

The Primary Carer within each host family setting receives appropriate Safeguarding training during their induction, followed up by the Primary Carer completing the certificated (NSPCC Child Protection: An Introduction – online course) or a similar suitable course every three years, and receives safeguarding updates as they become available, but at least annually.

7. Dealing with a disclosure
If a child discloses that he or she has been abused in some way, the member of staff or volunteer should:
●Listen to what is being said without displaying shock or disbelief
●Accept what is being said
●Allow the child to talk freely
●Reassure the child, but not make promises which it might not be possible to keep
●Never promise a child that they will not tell anyone – as this may ultimately not be in the best interests of the child
●Reassure him or her that what has happened is not his or her fault
●Stress that it was the right thing to tell
●Listen, only asking questions when necessary to clarify
●Explain what must be done next and who has to be told
●Make a written record (see Record Keeping & Appendix H)
●Pass the information to the Designated Safeguarding Lead without delay
●Check with the DSL after 24 hours about what action has been taken and follow up if concerned

When assessing the needs of a child staff should consider the following definitions:
Child in need – A child in need is defined under the Children Act 1989
as a child who is unlikely to achieve or maintain a reasonable level of health or development, or whose health and development is likely to be significantly or further impaired, without the provision of services; or a child who is disabled.
Child at risk – Serious and immediate concern about a student who is at risk of serious harm

See Appendix I – What Regent Guardians staff should do if worried about a Child in Need or Child at Risk.

See Appendix D – How to respond to a disclosure, for more support.
Dealing with a disclosure from a child, and safeguarding issues can be stressful. The member of staff/volunteer should, therefore, consider seeking support for him/herself and discuss this with the DSL.

If a Regent Guardians staff member receives a disclosure about potential harm caused by another staff member, they should see section 12 – Allegations involving Staff/Volunteers.

8. Record Keeping
All concerns, discussions and decisions made and the reasons for those decisions should be recorded in writing. If in doubt about recording requirements staff should discuss with the DSL.
When a child has made a disclosure, the member of staff/volunteer should:
●Record as soon as possible after the conversation. Use the record of concern sheet wherever possible – Appendix H
●Do not destroy the original notes in case they are needed by a court
●Record the date, time, witness, place and any noticeable non-verbal behaviour and the words used by the child
●Indicate the position of any injuries if evident
●Record statements and observations rather than interpretations or assumptions
●Agree and record actions and outcomes

All records need to be given to the DSL promptly. No copies should be retained by the member of staff or volunteer.
The DSL ensures that all safeguarding records are managed in accordance with the Education Regulations 2005.
All child protection records should be scrutinised regularly to ensure the action and outcome has been carried and any drift avoided. All records are kept on a confidential need to know basis and are stored securely at Regent Guardians.

9. Confidentiality
Safeguarding and protecting children raises issues of confidentiality that must be clearly understood by all staff/volunteers.

All Regent Guardians staff have a responsibility to share relevant information about the protection of children with other professionals, particularly the investigative agencies (Children’s Services: Safeguarding and Specialist Services and the Police).

If a child confides in a member of staff/volunteer and requests that the information is kept secret, it is important that the member of staff/volunteer tell the child in a manner appropriate to the child’s age/stage of development that they cannot promise complete confidentiality – instead they must explain that they may need to pass information to other professionals to help keep the child or other children safe. This may ultimately not be in the best interests of the child.

Staffs/volunteers who receive information about children and their families during their work should share that information only within appropriate professional contexts.

10. Procedure
When a member of staff is concerned about a child, he or she informs the DSL who then decides whether the concerns should be referred to Children’s Services. If it is decided to make a request for involvement to Children’s Services (using the Local Safeguarding Board’s ‘Thresholds for Assessment Services’) this is discussed with the parents and other stakeholders, unless to do so would place the child at further risk of harm.
While it is the DSL’s role to make request for involvement, any staff member can make a referral to Children’s Services. If a child is in immediate danger or is at risk of harm (e.g. concern that a family might have plans to carry out Female Genital Mutilation), a referral should be made to Children’s Services and/or the Police immediately. Where referrals are not made by the DSL, the DSL must be informed as soon as possible.

See Appendix I What Regent Guardians staff should do if worried about a Child in Need or Child at Risk.

Any person employed by Regent Guardians who discovers that an act of Female Genital Mutilation (FGM) appears to have been carried out on a girl under the age of 18 or there is a risk this might occur the must report this to the police. This is a mandatory reporting duty. See Keeping Children Safe in Education (DfE 2020): Annex A for further details.
The member of staff must record information regarding the concerns on the same day. The recording must be a clear, precise, factual account of the observations. (See Appendix H).

11. Communication with Parents
We are fully committed to working in partnership with Parents. Regent Guardians ensures the Safeguarding Policy is available publicly via our website and in hard copy if requested.
Parents should be informed prior to referral, unless it is considered to do so might place the child at increased risk of significant harm by:
●The behavioural response it prompts e.g. a child being subjected to abuse, maltreatment or threats / forced to remain silent if alleged abuser informed;
●Leading to an unreasonable delay;
●Leading to the risk of loss of evidential material.
(The provision may also consider not informing parent(s) where it would place a member of staff at risk).

The Provision ensures that parents/carers understand the responsibilities placed on Regent Guardians and staff for safeguarding children.

12. Allegations involving staff/volunteers
An allegation is any information which indicates that a member of staff/volunteer may have:
●Behaved in a way that has, or may have harmed a child
●Possibly committed a criminal offence against/related to a child
●Behaved towards a child or children in a way which indicates s/he would pose a risk of harm if they work regularly or closely with children

This applies to any child the member of staff/volunteer has contact within their personal, professional or community life.
All staff and volunteers should feel able to raise concerns about poor or unsafe practice and potential failures in Regent Guardians safeguarding arrangements.

Appropriate whistleblowing procedures, which are suitably reflected in staff training and staff behaviour policies, should be in place and easily accessed for such concerns to be raised with Regent Guardians. (See Whistleblowing Policy in list of Policies below)

If staff members have concerns about another staff member then this should be referred to the Director.

In the event of a staff member who feels unable to raise an issue with their employer or feels that their genuine concerns are not being addressed, allegations should be reported directly to the Local Authority Designated Officer (LADO). See Appendix G Useful Contacts. Staff may consider discussing any concerns with the DSL if appropriate and make any referral via them. (See Keeping Children Safe in Education: Part Four, DfE 2022, for further information)

The person to whom an allegation is first reported should take the matter seriously and keep an open mind. S/he should not investigate or ask leading questions if seeking clarification; it is important not to make assumptions. Confidentiality should not be promised, and the person should be advised that the concern will be shared on a ‘need to know’ basis only.

Actions to be taken include making an immediate written record of the allegation using the informant’s words – including time, date and place where the alleged incident took place, brief details of what happened, what was said and who was present. This record should be signed, dated and immediately passed on to the Director.

The recipient of an allegation must not unilaterally determine its validity, and failure to report it in accordance with procedures is a potential disciplinary matter.

The Director does not investigate the allegation itself, or take written or detailed statements, but assesses whether it is necessary to refer the concern to the Local Authority Designated Officer:
If the allegation meets any of the three criteria set out at the start of this section, contact should always be made with the Local Authority Designated Officer without delay. See Appendix G Useful Contacts.
If it is decided that the allegation meets the threshold for safeguarding, this takes place in accordance with Somerset Safeguarding Children Partnership Inter-agency Child Protection and Safeguarding Children Procedures or the Board local to the place where the allegation occurred.

If it is decided that the allegation does not meet the threshold for safeguarding, it is handed back to the employer for consideration via the company’s internal procedures. These procedures are outlined in the Regent Guardians Whistleblowing Policy, which includes a Low Level Concerns section (see list of supporting Policies below).

The Director should as soon as possible, (following briefing from the Local Authority Designated Officer) inform the subject of the allegation.
Where a staff member feels unable to raise an issue with their employer through the whistleblowing procedure or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them:

NSPCC whistleblowing helpline is available for those who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285, line is available from 8:00 AM to 8:00 PM, Monday to Friday and Email: help@nspcc.org.uk

13. Safer Working Practice
To reduce the risk of allegations, all staff should be aware of safer working practice and should be familiar with the guidance contained in the Staff Code of Conduct and Safer Recruitment Document Guidance for safer working practice for those working with children and young people in education settings (2015)

The document seeks to ensure that the responsibilities of managers towards children and staff are discharged by raising awareness of illegal, unsafe, unprofessional and unwise behaviour. This includes guidelines for staff on positive behaviour management in line with the ban on corporal punishment (School Standards and Framework Act 1998).

14. Safer Recruitment
Regent Guardians ensures that there are appropriate staff with safer recruitment training for interviews and that safer recruitment practices are followed always. We maintain a single central record to ensure all statutory requirements. All references are verified and recorded. See separate Safer Recruitment Policy.

15. Keeping Children Safe in Education 2023
The statutory guidance ‘Keeping Children Safe in Education’ 2023 is available online:

Keeping children safe in education 2023 (publishing.service.gov.uk)

Staff have access to this online document and are advised as part of their induction to read Part 1 and Annex A, which provides further information on:
●Children missing from education
●Child criminal exploitation
●Child sexual exploitation
●County lines
●Honour based abuse
●FGM mandatory reporting duty
●Forced marriage
●Preventing radicalisation
●Harmful Sexual Behaviour
●Peer on Peer / Child on Child abuse
●Upskirting

Part 5 provides additional details about Child on Child sexual violence and sexual harassment and is of particular importance today in light of current issues in the press and the many testimonies on Everyone’s Invited website https://www.everyonesinvited.uk/
This is to assist staff to understand and discharge their role and responsibilities as set out in this guidance.

16. Regent Guardians supporting policies
This policy is to be read in conjunction with Regent Guardians’ other policies, all of which can be found at the bottom of each page of the Regent Guardians website Regent Guardians – UK School Guardianship:

Anti-bullying and Cyberbullying (See separate Anti-bullying and Cyberbullying Policy)

Complaints (See separate Complaints Policy)

Emergency Procedure (See separate Emergency Contingency Policy)

Missing Students (See separate Missing Students Policy)

Online Safety and Sexting (See separate Online Safety Policy)

Anti-Radicalisation (See separate Prevent Anti-Radicalisation Policy)

Safer Recruitment (See separate Safer Recruitment Policy)

Whistle Blowing (See separate Whistleblowing Policy)

Appendix A.

Types of Abuse
Physical abuse is deliberately hurting a child causing injuries such as bruises, broken bones, burns or cuts. It isn’t accidental – children who are physically abused suffer violence such as being hit, kicked, poisoned, burned, and slapped or having objects thrown at them. Shaking or hitting babies can cause non-accidental head injuries (NAHI). Sometimes parents or carers will make up or cause the symptoms of illness in their child, perhaps giving them medicine they don’t need and making the child unwell – this is known as fabricated or induced illness (FII).There’s no excuse for physically abusing a child. It causes serious, and often long-lasting, harm – and in severe cases, death.

Neglect is the ongoing failure to meet a child’s basic needs and is abuse. A child may be left hungry or dirty, without adequate clothing, shelter, supervision, medical or health care. A child may be put in danger or not protected from physical or emotional harm. They may not get the love, care, and attention they need from their parents. A child who’s neglected will often suffer from other abuse as well. Neglect is dangerous and can cause serious, long-term damage – even death. Affluent neglect may display in different ways but is still a serious concern.

Sexual Abuse A child is sexually abused when they are forced or persuaded to take part in sexual activities. This doesn’t have to be physical contact and it can happen online. Sometimes the child won’t understand that what’s happening to them is abuse. They may not even understand that it’s wrong. It may be initiated by an adult or another child.

Emotional abuse is the ongoing emotional maltreatment of a child. It’s sometimes called psychological abuse and can seriously damage a child’s emotional health and development. Emotional abuse can involve deliberately trying to scare or humiliate a child or isolating or ignoring them. Children who are emotionally abused are often suffering another type of abuse or neglect at the same time – but this isn’t always the case

Specific abuse and vulnerability concerns
Breast Ironing/Binding
Breast ironing (also known as breast flattening) is the pounding and massaging of a pubescent girl’s breasts, using hard or heated objects, to try to make them stop developing or to disappear.
When a disclosure or signs of breast ironing are noted, staff should always alert the DSL immediately.

Child Exploitation, Sexual (CSE) and Child Criminal Exploitation (CCE)
There will be other circumstances which give cause for serious concern about the welfare of children; such as Child Exploitation (CE).
The exploitation of children and young people under 18 involves exploitative situations, contexts and relationships where young people (or a third person or persons) receive something (e.g. food, accommodation, drugs, alcohol, cigarettes, affections, gifts, money) as a result of them performing, and/or another or others performing on them, sexual activities.

CSE can occur through the use of technology without the child’s immediate recognition; for example, being persuaded to post sexual images on the Internet/mobile phones.
In all cases, those exploiting the child/young person have power over them by virtue of their age, gender, intellect, physical strength and/or economic or other resources.
Violence, coercion, and intimidation are common; involvement in exploitative relationships being characterised in the main by the child or young person’s limited availability of choice resulting from their social/economic and/or emotional vulnerability.

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

Child Criminal exploitation can take the form of involvement in ‘county lines’ where gangs and organised crime networks exploit children to sell drugs. Often these children are made to travel across counties, and they use dedicated mobile phone ‘lines’ to supply drugs. Further information on county lines can be found at https://www.childrenssociety.org.uk/what-is-county-lines
More details about Child Criminal Exploitation and the influence of urban gangs can be found below.

County Lines, Cross Borders, Gangs, Trafficking and Cuckooing
These are police terms for urban gangs supplying drugs to suburban areas and market/or coastal towns using dedicated mobile or ‘deal lines’. Gangs use children and vulnerable people to move drugs and money. Often they take over the homes of vulnerable adults and children by force or coercion in a practice referred to cuckooing Getting involved in gang culture can have serious and potentially devastating consequences, with dealers/offenders/members not afraid to use violence. Any activity that deems to be suspicious, or involve drug dealing/crime/exploitation should be passed to the police on 101. Should young people thought to be involved the early help assessment is a useful tool. A request for involvement to CSC/police is needed if the child is at immediate risk of harm.
https://www.gov.uk/government/publications/criminal-exploitation-of-children-and-vulnerable-adults-county-lines

Domestic Abuse
Domestic abuse may take many forms. Witnessing the physical and emotional suffering of a parent may cause considerable distress to children, and both the physical assaults and psychological abuse suffered by adult victims who experience domestic abuse can have a negative impact on their ability to look after their children. Children can still suffer the effects of domestic abuse, even if they do not witness the incidents directly. However, in up to 90% of incidents involving domestic violence where children reside in the home, the children are in the same or the next room. Children’s exposure to parental conflict, even where violence is not present, can lead to serious anxiety and distress among children. Children can see school as a safe retreat from problems at home or alternatively not attend school through a perceived need to be at home to protect abused parents or siblings.

Domestic abuse can therefore have a damaging effect on a child’s health, educational attainment and emotional well-being and development. The potential scale of the impact on children is not always easy to assess, but may manifest itself as behavioural, emotional, or social difficulties,including poor self-esteem, withdrawal, absenteeism, adult–child conflict. Children sometimes disclose what is happening or may be reluctant to do so, hoping that someone will realise something is wrong.

Extremism and Radicalisation
The UK Government defines extremism as: “The vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs” and/or “calls for the death of members of our armed forces, whether in this country or overseas.” Radicalisation is defined by the UK Government within this context as: “The process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.”

We take the “Prevent” duty seriously and recognise that Safeguarding against extremism and radicalisation is no different from Safeguarding against any other vulnerability; it is about protecting children and young people from being groomed and exploited by others. (See Prevent Policy)

Fabricated or Induced Illness by Carer (FII)
FII is a condition whereby a child suffers harm through the deliberate action of their carer and which is attributed by the adult to another cause.
FII can cause significant harm to children. FII involves a well child being presented by a carer as ill or disabled, or an ill or disabled child being presented with a more significant problem than he or she has in reality, and suffering harm as a consequence.
There are three main ways of the parent/carer fabricating or inducing illness in a child:
• Fabrication of signs and symptoms, including fabrication of past medical history.
•Fabrication of signs and symptoms and falsification of hospital charts, records, letters and documents, and specimens of bodily fluids.
•Induction of illness by a variety of means.

The possibility of fabricated and induced illness should be considered where there are discrepancies between professional and parental perceptions of the child’s needs or of any illness or disability and where there is a possibility of significant harm to the child.

Faith Abuse
Faith abuse is linked to a belief in witchcraft or possession by spirits and demons. In such instances, physical and/or psychological violence may be used in order to “get rid” of the possessing spirit.

Child abuse is never acceptable in any community, in any culture, in any religion, under any circumstances. This includes abuse that might arise through a belief in spirit possession or other spiritual or religious beliefs.
Faith abuse usually occurs in the household where the child lives. It may also occur in a place of worship where alleged “diagnosis” and “exorcism” may take place.

When a disclosure or signs of faith abuse are noted, staff should always alert the DSL immediately. In such situations, the DSL will always call Somerset Children’s Social Care Emergency Duty Team on 0300 123 2224 or the team in their locality.

Female Genital Mutilation (FGM)
FGM comprises all procedures that involve partial or total removal of the external female genitalia, or other injury to the female genital organs for non-medical reasons (World Health Organisation). It is also sometimes referred to as female genital cutting or female circumcision. The practice is illegal in the UK.

FGM is not an issue that can be decided on by personal preference – it is an illegal, extremely harmful practice, and a form of child abuse and violence against women and girls. Professionals have a statutory duty to report all cases of FGM to the Police where disclosure or signs of FGM are noted or where a person knows or suspects FGM has been – or will be – perpetrated. When someone reports FGM to the Police, they should ask for a crime reference number.

If there is an IMMEDIATE RISK, call the Police on 999 (emergency number).
If there is NOT an immediate risk, call the Police on 101 (non-emergency number).

Forced Marriage
The UK Government describes this as taking someone, usually overseas, to force them to marry (whether or not the FM takes place), or marrying someone who lacks the mental capacity to consent to the marriage (whether they’re pressured to or not). Breaching a Forced Marriage Protection Order is also a criminal offence.

When a disclosure or signs of FM are noted, staff should always alert the DSL immediately. Regent Guardians should never attempt to intervene directly. In such situations, the DSL will always call either Somerset Direct/Police or other local organisation and/or the Forced Marriage Unit on 020 7008 0151.

Grooming
Is when someone builds an emotional connection with a child to gain their trust for the purposes of sexual abuse, sexual exploitation or trafficking. Children and young people can be groomed online or face-to-face, by a stranger or by someone they know – for example a family member, friend or professional. Groomers may be male or female. They could be any age. Many children and young people don’t understand that they have been groomed or that what has happened is abuse.

Hate Crime
A hate Incident is any incident which the victim, or anyone else, thinks is based on someone’s prejudice towards them because of their race, religion, sexual orientation, disability or because they are transgender. If you, or anyone you know, has been called names, been bullied or had anything happen to them that you think may be because of one of these factors, then you should report this as a hate incident. Not all hate incidents will amount to criminal offences, but those that do become hate crimes.

Historical Abuse
Historical abuse (also known as non-recent abuse) is an allegation of neglect, physical, sexual or emotional abuse made by or on behalf of someone who is now 18 years or over, relating to an incident which took place when the alleged victim was under 18 years old.

The Police should be informed about allegations of crime at the earliest opportunity through the DSL.

Honour-Based Abuse
So-called ‘honour-based’ abuse encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation, Forced Marriage and practices such as breast ironing.
All forms of so-called honour-based abuse are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubt, staff should speak to the DSL. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBV, or already having suffered honour-based abuse.

Missing Children
A young person is to be considered “missing” if he/she is absent from his/her place of residence without authority to a degree or in circumstances where the absence causes concern for safety of the child or a danger to the public”. This includes children and young people who have been forced to leave home and those whose whereabouts are unknown and those who feel they have had to leave home (rather than making a positive choice to do so).
High risks concerns include where:
●The responsible adult has no indication when the child is likely to return
●The child develops a pattern of going missing repeatedly
●The child’s location is unknown, or reason for absence is unknown there is cause for concern for the child because of their vulnerability
●The child is at high risk of CSE/CCE/gangs
●The child is pregnant or has a young child
●The child has a history of suicidal thoughts or behaviours
●The child is at risk of radicalisation
(See Missing Student Policy)

Online Abuse
This type of abuse happens on the web, through social networks, playing online games or using a mobile phone. Children and young people may experience cyberbullying, grooming, sexual abuse, sexual exploitation or emotional abuse. Children can be at risk of online abuse from people they know, as well as from strangers. Online abuse may be part of abuse that is taking place in the real world (for example bullying or grooming). Or it may be that the abuse only happens online (for example persuading children to take part in sexual activity online). Children can feel like there is no escape from online abuse – abusers can contact them at any time of the day or night, the abuse can come into safe places like their bedrooms, and images and videos can be stored and shared with other people. (See Cyberbullying & E-Safety Guidelines)

Peer on peer / child on child abuse including Harmful Sexual Behaviour, Sexual violence and Harassment in education (2021)
Education settings are an important part of the inter-agency framework not only in terms of evaluating and referring concerns to children’s services and the police, but also in the assessment and management of risk that the child or young person may pose to themselves and others in the education setting.

When considering whether behaviour is abusive, it is important to consider: Whether there is a large difference in power (for example age, size, ability, development) between the young people concerned; or whether the perpetrator has repeatedly tried to harm one or more other children; or where there are concerns about the intention of the alleged perpetrator.

Peer on peer / child on child abuse can manifest itself in many ways and different gender issues can be prevalent. Severe harm may be caused to children by abusive and bullying behaviour of other children, which may be physical, sexual or emotional and can include gender-based violence/ sexual assaults, sexting, teenage relationship abuse, peer-on-peer exploitation, serious youth violence, sexual bullying or harmful sexual behaviour.

Guidance on responding to and managing sexting incidents can be found at: https://ceop.police.uk

Staff should recognise that children can abuse their peers and other children and this should not be tolerated or passed off as “banter” or “part of growing up”.

To minimise the risk of peer on peer / child on child abuse Regent Guardians will:
Have systems in place for any student to raise concerns with staff, knowing that they will be listened to, believed and valued and have relevant policies in place (see Anti-Bullying and Cyberbullying Policy).

More details on this topic can be found in Section 5 of keeping Children Safe in Education (2022)
Keeping children safe in education 2022 (publishing.service.gov.uk)

Private Fostering
Private fostering is when a child under the age of 16 (18 if they are disabled) lives with someone who is not a close relative, guardian or person with parental responsibility for 28 days or more. Private fostering is not the same as fostering arranged by the local authority.

Children and young people become privately fostered for a variety of reasons
o Their parents live overseas and they come to this country to attend school
o Their parents are ill and cannot look after them
o Their parents work away from home, possibly abroad
o Their parents have come to the UK to study or work and require someone to look after their children
o They are teenagers who are estranged from their families

The Children Act 1989, and section 44 of the Children Act 2004, outlines the legal duty of the local authority to make sure that the welfare of all privately fostered children is safeguarded and promoted. As stated in law Regent Guardians will inform the Local Authority about all private fostering arrangements if they were to happen.

Sharing of nude and semi-nude images
The sharing of nude and semi-nude images or sexting is sending, receiving, or forwarding sexually explicit messages, photographs or images, primarily between mobile phones. It may also include the use of a computer or any digital device. If this were to happen, Regent Guardians will follow local procedures with police and Somerset Safeguarding Children Partnership or the Board nearest to the place of the incident. (See Online Safety Policy)

Upskirting
The Voyeurism (Offences) Act, which is commonly known as the Upskirting Act, came into force on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a person’s clothing (not necessarily a skirt) without their permission and or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. It is a criminal offence. Anyone of any gender, can be a victim.

Appendix B.

Managing Allegations and Escalation
The statutory guidance ‘Keeping Children Safe in Education (2023)’ states that governing bodies and proprietors should appoint a member of staff of the school’s or college’s leadership team to the role of designated safeguarding lead. (Hence within Regent Guardians the Director is the DSL.) All staff should be instructed that any allegation should be reported immediately to the DSL. Written safeguarding procedures should reflect this guidance.

On being advised of an allegation which meets the criteria, DSL should contact the Local Authority Designated Officer (LADO) within 1 working day.

Phone Somerset Direct on 0300 123 2224 for a referral if the alleged incident has taken place within Somerset.

The LADO’s role is to provide advice and guidance to organisations dealing with allegations, to liaise with the police and other agencies, and to monitor the progress of cases to ensure that they are dealt with as quickly as possible, consistent with a thorough and fair process.

All allegations against staff are dealt with in accordance with ‘Working Together to Safeguard Children 2023’. In addition, schools should have regard to Part 4 of the statutory guidance ‘Keeping Children Safe in Education (2023)’. Should the allegation be about the DSL, allegations should be passed directly to the LADO.

Appendix C.

Referral Routes
Somerset Safeguarding Children Partnership
The SSCP has a statutory duty to co-ordinate how agencies work together to safeguard and promote the well-being of children and young people in Somerset and to ensure the effectiveness of the safeguarding arrangements.

Report a child at risk If you are worried about a child or young person who could be in danger, please contact
● Children’s Social Care on 0300 123 2224
● by email at childrens@somerset.gov.uk
● or the police

You can contact the police directly by dialling 101 and they will discuss with Children’s Social Care what action should be taken. In an emergency always contact the police by dialling 999.

If you would like to speak to a social worker outside of office hours, please phone the Emergency Duty Team (EDT) on 0300 123 23 27.

Referral routes Cardiff and the Vale Regional Safeguarding Children Board
The Cardiff and the Vale Regional Safeguarding Children Board (RSCB) has full procedures on their website at http://www.cardiffandvalelsb.co.uk

If you are concerned about the safety of a child/children contact Cardiff Children’s Services via the Children’s Access Point on: 029 2053 6490
Or out of office hours the emergency duty team on: 029 2078 8570

Referral routes for other LSPs
Regent Guardians will work closely with and provide contacts for Local Safeguarding Partnerships in all regions where it operates. Click on one of the following links to access all LSPs:

https://www.safecic.co.uk/your-scb-acpc/55-free-downloads-and-safeguarding-links/61-safeguarding-children-board-links

https://www.childprotectionuk.co.uk/local-safeguarding-children-boards-for-england-and-wales.php

Appendix D

How to Respond to a Disclosure
Receive
Listen
Accept what the student says
Take it at their pace
Try not to burden them with guilt by asking questions like, “Why didn’t you tell me before?”

Reassure
Stay calm and reassure the student that they have done the right thing in talking to you
Don’t promise confidentiality: you have a duty to refer a student who is at risk
Try to alleviate any feelings of guilt that the student displays
Acknowledge how hard it must have been for the student to tell you what happened
Empathise with the student – don’t tell them what they should be feeling

React
React to the student only to establish whether or not you need to refer this matter
Do not ask leading questions ask open questions like “Anything else to tell me?” or “And?”
Do not criticise the perpetrator
Do not ask the student to repeat everything to another member of staff
Explain what you have to do next and to whom you have to talk
Inform the designated safeguarding lead immediately

Record
Make some very brief notes, at the time, write them up as soon as possible onto the confidential cause for concern form
Do not destroy your original notes
Record the date, time, place, any noticeable non-verbal behaviour and the words used by the child
If appropriate. draw a diagram to indicate the position of any bruising
Be objective in your recording: not your interpretations or assumptions

Support
Make sure that you continue to support the student
Get some support for yourself, without disclosing confidential information about the student to colleagues.

DO
Listen to and take seriously any disclosure or information that a student may be at risk of harm.
Explain sensitively to the person that you have a responsibility to refer the
information to the senior designated person.
Try to ensure that the person disclosing does not have to speak to another member of College staff.
Clarify the information using actual words where possible. Sign and date the record.
Try to keep questions to a minimum and of an ‘open’ nature e.g. ‘Can you tell me
what happened?’ rather than ‘Did x hit you?’
Try not to show signs of shock, horror or surprise.
Don’t express feelings or judgements regarding any person alleged to have harmed the student.
Reassure and support the student as far as possible.
Explain that only those who ‘need to know’ will be told.
Explain to the student what will happen next and that they will be involved as appropriate.
Make sure the student is safe and supported.
Complete the Confidential Cause for Concern Form (see Appendix H) and return it to the DSL as soon as possible.

DO NOT
Promise confidentiality
Judge or criticise the alleged perpetrator or the student.
Ask leading questions.
Interrogate or try to establish if the student is telling the truth.
Attempt to investigate the circumstances.
Put words into the student’s mouth.
Trivialise any aspect of a disclosure.
Let any allegations, suspicions or concerns go unreported.

Remember – Safeguarding is everybody’s business

Appendix E

Prevent & Radicalisation
Radicalisation and Extremism is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate in terrorist groups.

“Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas” (HM Government Prevent Strategy 2011). Prevent is one part of the United Kingdom’s counter-terrorism strategy (CONTEST) and aims to stop people from being exposed to extreme ideologies and becoming radicalised. The CONTEST strategy is divided up into four priority objectives:
● Pursue – stop terrorist attacks by prosecuting offenders.
● Prepare – where we cannot stop an attack, mitigate its impact
● Protect – strengthen overall protection against terrorist attacks
● Prevent – stop people becoming terrorists and supporting violent extremism

It is an approach that involves many agencies and communities to safeguard people who may be at risk of radicalisation. Since the publication of the Prevent Strategy, there has been an awareness of the specific need to safeguard children, young people and families from violent extremism. There have been attempts to radicalise vulnerable children and young people to develop extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

Keeping children safe from these risks is a safeguarding matter and should be approached in the same way as safeguarding children from other risks. Children should be protected from messages of all violent extremism.

To report concerns in Somerset, contact the Regional Police Prevent Team:
● Phone: 01179 455 536
● Email: channelsw@avonandsomerset.pnn.police.uk
● SWCPP (Safeguarding Children and Young people against Radicalisation and Violent Extremism) http://www.proceduresonline.com/swcpp/somerset/p_sg_ch_extremism.html?zoom_highlight=prevent
● Revised Prevent Duty guidance for England and Wales https://www.gov.uk/government/publications/prevent-duty-guidance

(See separate Anti-Radicalisation / Prevent Duty Policy)

Appendix F
Restraint
What is reasonable force?
1. It is never acceptable to use corporal punishment
2. The term ‘reasonable force’ covers the broad range of actions that involve a degree of physical contact.
3. Force is usually used either to control or restrain. This can range from guiding a pupil to safety by the arm through to more extreme circumstances such as breaking up a fight or where a young person needs to be restrained to prevent violence or injury.
4. ‘Reasonable in the circumstances’ means using no more force than is needed.

For further clarification click on the link below:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/444051/Use_of_reasonable_force_advice_Reviewed_July_2015.pdf

Appendix G

Useful Contacts
Regent Guardians Staff
Designated Safeguarding Lead: Jenny Chan
Telephone: +44 (0)1823 428793 this is a 24-hour contact number
Mobile: +44 (0) 7799 819787 this is a 24-hour contact number
E-mail: jenny@regentguardians.com

Deputy Designated Safeguarding Lead: Rachel Debenham
Rachel covers for Jenny when she is unavailable, using the same contact telephone numbers

Somerset Safeguarding Children Partnership

Children & Young People’s Team
Customer Contact, PO Box 618, Taunton, Somerset, TA1 3WF
childrens@somerset.gov.uk

Consultation Line for Children’s Safeguarding Leads: 0300 123 3078

Early Help Advice Hub: 01823 355803
EHACoordinator@somerset.gov.uk

Somerset Direct (Children’s and Adult’s): 0300 123 2224

Emergency Duty Team: 0300 23 23 27

LADO: Mr Anthony Goble
Tel: 01823 359029

Prevent: Mr Mike Perry
Tel: 01179 455536
Prevent – Regional Police Prevent Team: 01179 455536/539
channelsw@avonandsomerset.pnn.police.uk

Children’s Commissioner England Dame Rachel de Souza: 020 7783 8330

Children & Adolescent Mental Health Services (CAMHS) Telephone Advice Line (12.00pm to 2.00pm Monday to Friday)
● Mendip 01749 836561
● South Somerset 01935 384140
● West 01823 368368

LGBT – stonewall.org.uk

Somerset Drug and Alcohol Service (SDAS) 0300 303 8788
Somerset Integrated Domestic Abuse Service (SIDAS) 0800 694 9999
Somerset Partnership Integrated Therapy Service 0303 033 3002

Somerset Support for Education (SSE)
http://www.supportservicesforeducation.co.uk/

Somerset Direct
http://www.somerset.gov.uk/childrens-services/safeguarding-children/report-a-child-at-risk/

LSCB referral routes Cardiff and the Vale Safeguarding Children Board
The Cardiff and the Vale Regional Safeguarding Children Board (RSCB) has full procedures on their website at http://www.cardiffandvalelsb.co.uk

If you are concerned about the safety of a child/children contact Cardiff Children’s Services via the Children’s Access Point on: 029 2053 6490

Or out of office hours the emergency duty team on: 029 2078 8570

Or out of office hours the emergency duty team on: 029 2078 8570

Cardiff and the Vale RSCB
Telephone – 029 2233 0879 / 07772 105787
E-mail – cardiffandvalelsb@cardiff.gov.uk
Cardiff and the Vale of Glamorgan
Children’s Services
County Hall
Cardiff
CF10 4UW

Cardiff Children’s Services
If you think a child or young person is being harmed or is at risk of being harmed
then you should contact the Children’s Access Point on: 029 2053 6490
Monday to Friday, 8.30am-5pm

If it is outside of these hours, please call the emergency duty team on:
029 2078 8570

Designated Officer or Team of Officers (DOTO) (Through Children’s Services)
Telephone – 029 20536490
For allegations of abuse made against staff members the referral must be made within one working day.

Prevent Lead
For non-emergency referral telephone: 101
DfE dedicated telephone helpline and mailbox for non-emergency advice for staff and trustees
E-mail: counter-extremism@education.gsi.gov.uk
Telephone: 020 73407264
Cardiff Prevent Team Cardiff Bay: 029 20527306

South Wales Police
To contact the police by phone, 24 hours a day dial 101.
If life is in danger or a crime is in progress dial 999.
Protecting Vulnerable People (South Wales Police) 029 2022 2000

Reporting FGM to Police: Since October 2015, it has been a legal obligation for all staff to report suspected cases of FGM to the police. South Wales Police have trained, specialist officers who can be contacted by calling 101.

NSPCC Cardiff: 029 2010 8080

Children’s Commissioner for Wales: 0800 801 1000

Referral routes for other LSPs
Regent Guardians will work closely with and provide contacts for Local Safeguarding Partnerships in all regions where it operates. Click on one of the following links to access all LSPs:

https://www.safecic.co.uk/your-scb-acpc/55-free-downloads-and-safeguarding-links/61-safeguarding-children-board-links

https://www.childprotectionuk.co.uk/local-safeguarding-children-boards-for-england-and-wales.php

Appendix H

Cause for Concern Reporting Form
Logging a concern about a young person’s safety or welfare

Appendix I

What Regent Guardians staff should do if they are worried about a ‘Child in Need’

What Regent Guardians staff should do if they have serious and immediate concerns about a ‘Child at Risk’

Children suffer if we…..
● Fail to act on and refer the early signs of abuse;
● Fail to keep records
● Fail to listen to the views of the child
● Fail to re-assess and communicate
● Fail to challenge others who are not acting on the information

Child Protection and Safeguarding Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Emergency Contingency Policy

This policy contains the outline plans and procedures to be implemented in the case of a major incident or emergency such as:

• the death of a student or students
• a serious accident affecting a student or students
• an incident that affects the repatriation of a student to their home, such as the transportation of a student within or outside the UK
• an epidemic or pandemic which prevents the student from either being at school or repatriated to their home.

In the event of such a major incident or emergency, the Director will be nominated as the person responsible for the contingency plan.  In the unlikely event that the Director is not available, the Deputy Designated Safeguarding Lead (DDSL) Rachel Debenham will take charge using the same phone numbers.

Our emergency number +44 (0) 7799 819787 will be given to all relevant parties and, as always, will be staffed 24 hours a day.  In the event of a major incident affecting multiple students, further numbers will be allocated as necessary.

The death of, or serious accident affecting, a student or students

The following procedure will be put into place:

1. Establish the nature and extent of the emergency.  Ensure we have facts.
2. Establish the name(s) of the injured and call whichever emergency service is required if relevant.
3. Advise senior staff of the incident and that the emergency plan is in operation.
4. If relevant, ensure that a responsible adult accompanies student(s) to hospital.  Consider need for a competent speaker of student’s first language to go too.  The nominated member of Regent Guardians senior management will contact parents, school or police as appropriate.  It is highly desirable that clear facts relating to the incident, with no hysteria, supposition or hearsay, are given to parents and authorities from a single source.
5. A record must be kept of all incoming and outgoing calls so that we know who has been contacted and what has been said.
6. In the event of a fatality, it is the role of the police to contact the appropriate embassy in London, who will then inform the family of the death of their relative.
7. The student(s)’ Personal Accident cover may or may not include repatriation of body expenses. In liaison with the school, Regent Guardians will communicate with the family over this and associated issues.
8. In due course, we will make plans, where appropriate, for visits to hospitals, attendance at the funeral or memorial services; seek help from outside professionals for counselling support for all those affected; anticipate the need to support staff and other students for some considerable time after the event; review and amend this policy in the light of experience.

An incident that affects the repatriation of a student to their home, such as the transportation of a student within or outside the UK

This plan applies to students who are affected by a major incident which, for example, closes an airport while they are in transit, making their onward journey impossible or badly delayed.

The overall plan is to move the student to a safe place and if necessary, to safe accommodation, depending on whether the incident takes place within or outside the UK.   All plans will be made in cooperation with the school, parents, transport companies and any authorities involved in the incident.

1. An incident within the UK

Regent Guardians allows extra time to travel to airports to allow for travel problems or problems at the airport.  We plan arrival time to be 3 hours prior to the departure of the flight.  If a student’s flight is cancelled or missed due to an incident, we will transport the student to be accommodated at a host family or other appropriate accommodation until their flight is rebooked and then transport them back to the airport.

2. An incident outside the UK

We will remain in contact with parents, school, student, host families, drivers and authorities as relevant if a student is stranded at an airport when travelling to the UK or back home. Although we could not travel to meet the student, we will liaise with all parties, set up a helpline and act as a point of contact for all concerned until the incident is over.

If the student stranded overnight, we will, on the request of parents, arrange for hotel accommodation if the airline or authorities are unable to do so.

An epidemic or pandemic which prevents the student from either being at school or repatriated to their home. 

If there is an outbreak of an infectious or contagious disease in the country from where a student is travelling to the UK, we reserve the right to refuse to accept the student into our care.  If the student has arrived in the UK ill, we will make every effort to find host family accommodation for them.  If the school or host family refuse to accept the student, we will care for them ourselves for the sole purpose of arranging the student’s travel home as soon as possible, at the expense of the parent.  If the student becomes ill after arriving at the school and the school is unable to care for them, we will make every effort to find host family accommodation for them and, if this proves impossible, we will care for them ourselves until they are well enough to either go back to school or go home, at the expense of the parent.

COVID-19
Regent Guardians fully supports and adheres to the AEGIS Covid-19 Safe Charter which can be found here: https://aegisuk.net/aegis-covid-19-safe-charter/

Regent Guardians upholds the BSA Covid-Safe Charter; click here: https://www.boarding.org.uk/userfiles/bsa/Covid%20documents/83021%20BSA%20COVID%20Guardian.pdf

Although not necessarily an emergency, we will also accommodate a student who cannot be accommodated by the school due to illness, disciplinary action or any other cause.  This will be done by contacting the student’s normal host family.  If this family cannot accommodate the student, other host families will be contacted.  In the unlikely event that no host family can accommodate the student, they will be accommodated at the home of Regent Guardians Director until alternative arrangements can be made.

Emergency Contingency Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Missing Students Policy

Introduction
Safeguarding and promoting the welfare of children is a key duty of care for Regent Guardians. When a child goes missing or runs away they are at risk. Regent Guardians policy on safeguarding children therefore includes protecting them from that risk, hence the Missing Student Policy.

There are concerns about the links between children running away and the risks of sexual and/ or criminal exploitation. Missing children may also be vulnerable to other forms of exploitation, to violent crime, gang exploitation including county lines, or to drug and alcohol misuse.

This policy sets out the steps that Regent Guardians staff should take to prevent children from going missing and to protect them when they do go missing.

This policy considers the following publications:

• Statutory Guidance on children who run away or go missing from home or care (January 2014);
• Working Together to Safeguard Children and related statutory guidance (2023);
• Safeguarding Children and Young People from Sexual Exploitation (2009);
• Tackling Child Sexual Exploitation Action Plan (2011);
• Children Act 1989 guidance and regulations

Minimising the likelihood of a child going missing
By following the guidelines laid down by Regent Guardians in the Host Family Handbook and the Student Handbook it is anticipated that the likelihood of a child going missing whilst under the care of Regent Guardians is minimal. These guidelines suggest the best ways for host families to keep young people safe by providing age-appropriate supervision schedules and curfews alongside encouraging host families and their student guests to have open and frank conversations if there are wellbeing concerns. The Student Handbook reminds students of the importance of communicating openly and honestly with their host family, keeping them fully informed of any plans and taking responsibility for themselves during their stay.

Steps to take if you think a child has gone missing
There are many circumstances in which a child may not be accounted for but in many of these they will not be considered as a ‘missing person’. Most children will turn up safe and well, unaware that their actions have caused any concern or alarm. However, Regent Guardians staff and host families must be aware that if a student has run away and if their absence is unexplained and if there is concern for their safety then urgent action is required to ensure the safety and wellbeing of that student.

The following checks should be undertaken first:

• When were they last seen and by whom?
• Had they informed anyone else (friend, host family member) where they might be going?
• Can they be contacted by mobile or social media?
• Can they be tracked using a location finding device on their mobile?
• Are they with another responsible adult (parent, driver) whom you can contact?
• Are they in possession of their passport or ID card?
• Do they have access to money?

If, after completing these steps, it seems likely the young person’s absence is unexplained and the circumstances surrounding the absence are of concern, the host family or other Regent Guardians staff need to call the Regent Guardians Director at any time of the day or night on 07799 819787 and seek advice.  If the situation is felt to require it e.g. there are concerns for the student’s safety, the host family or other Regent Guardians staff may of course choose to contact the police directly.

It is not easy to decide whether a missing student has run away and is safe and well or if they have been abducted and/or come to harm. Careful thought needs to be given to this and any leads appropriately followed up on to ensure the student’s safe return.

If the Regent Guardians Director is concerned that the student’s disappearance might be suspicious or that they might come to any harm they will then decide whether to contact the police, how, when and if to contact the parents or agent and which other interested parties, e.g. school, need to be contacted. If the student is missing for any length of time, the Director will automatically inform the school in their capacity as Student Sponsor. 

Once the missing student has been found and assuming no harm has come to them, he/she will be reunited with the host family if both sides are happy with a continuation of the relationship. It is important that the host family continue to offer warm and consistent care when a child returns, and that running away should not be viewed as behaviour that needs to be punished. Regent Guardians will work very closely with the host family and the student to ensure the on-going safety of the student and to provide reassurance to the host family.

However, if circumstances dictate that a different host family is required, then Regent Guardians will make that change and work closely alongside both the student and the new host family. The student’s school will more than likely be informed of the incident if deemed to be of benefit to the on-going safety of the student once back in school.

Children Missing Education guidance is not relevant to Regent Guardians students as they are all students in boarding schools.

Missing Students Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Online Safety Policy

Introduction
This policy is based on the key government document ‘Keeping Children Safe in Education, 2023’ and supported by other guidance produced by the National Society for the Prevention of Cruelty to Children (NSPCC) and Local Safeguarding Partnerships (LSPs) in the areas pertinent to Regent Guardians operations. This policy is to be read in conjunction with the Regent Guardians Child Protection and Safeguarding policy alongside other relevant policies.

It is important to be aware that COVID-19 increased screen time further for most young people and therefore those caring for young people need to understand more than ever the risks that are present online. International students are extremely vulnerable for several reasons and when linked to culture shock they need guidance and support keeping safe. Risks include over-use, exposure to harmful content, online abuse such as bullying and grooming into criminal activity. Whilst we are in loco parentis, it is increasingly important that we can spot the signs and indicators.

Online Safety
The use of technology has become a significant component in many safeguarding issues. Child Sexual Exploitation (CSE); Child Criminal Exploitation (CCE); radicalisation; sexual abuse; sexting; technology often provides the platform that facilitates harm. An effective approach to online safety empowers Regent Guardians to protect and educate its students and staff in their use of technology and establishes mechanisms to identify, intervene in, and escalate any incident where appropriate.

The type of issues classified within online safety is considerable, but can be categorised into three areas of risk:

• content: being exposed to illegal, inappropriate or harmful material; for example pornography, fake news, racist or radical and extremist views;
• contact: being subjected to harmful online interaction with other users; for example commercial advertising as well as adults posing as children or young adults; and
• conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images, or online bullying.

Sharing of nude and semi-nude images and/or videos
More and more children are engaging or being affected by the sharing of indecent images and videos or ‘sexting’. With most young people having access to phones and social media accounts, it is becoming easier for them to send and receive explicit messages and images.

Sexting means sending sexually explicit messages and/or suggestive images, such as nudes. This can be done via any messaging service, including emails and social media. Therefore, they can be sent or received via several electronic devices such as smart phones, computers and tablets.

If a child is under the age of 18, it is illegal for them to take a nude photo of themselves or a friend, as well as distribute them. Even though the age of sexual consent is 16, the Protection of Children Act means it is against the law for a child to share a sexual image, even if it is with someone who is under the age of 18.

Images covered under the law include, but are not limited to, naked pictures, topless photos of girls, any sex acts or sexual images in underwear. If it is found that a child under the age of 18 is in possession of any of these, has been sending them or taking these types of photos, the police can record it as a crime.

Training and Updates
Regent Guardians staff are trained in all aspects of Safeguarding including Online Safety and Sexting as part of their induction programme. They also receive and work through the Staff Code of Conduct which supports safer online working practices and provides guidelines for the use of social media and images.  The DSL will distribute regular updates via email on this topic from the NSPCC and other affiliated organisations to all staff and ensure that they maintain their understanding of online safety through regular refresher training courses.

Host families will receive similar advice and support through the Host Family Handbook as well as regular updates from the DSL and the Guardian. Host families are crucial when it comes to ensuring young people use their mobile devices and the internet within the guidelines established in the Host Family handbook and are also on the front line for young people when they may be vulnerable to inappropriate online activity and wish to pass on information.

Regent Guardians drivers will be similarly trained and updated in safer online issues so if an incident were to arise whilst the young person is in transit, they would know the procedure to follow.

Students are inducted into the importance of safer online activity on receipt of their Student Handbook and will discuss the importance of this with the Guardian at their initial meetings. They also understand and agree to Regent Guardians Student Behaviour guidelines which clearly explain the importance of safer online activity and what to do if they are worried about anything online. Within their schools, the students will also receive similar information and advice on how to keep themselves safe online and who to talk to if they have a problem or concern. Regent Guardians online safety advice supports the work done in schools.

How does Regent Guardians protect children?
Regent Guardians staff need to ensure that realistic measures are put in place to ensure that young people’s access to online activity is appropriate. The Host Family handbook outlines what can be done to control the young person’s use of the internet and is discussed in greater depth by the Guardian when visiting the host family. For example host families are to use privacy settings, parental controls and internet safety features provided by all main internet service providers. Host families also need to ensure appropriate filters and monitoring systems are in place. The extent to which these controls are put in place are clearly dependent upon the age of the young person in their care and how often he/she is accessing the internet.

In respect to mobile phones and tablet usage, host families need to be aware of possible concerns over access to public wifi, the taking and sending of pictures and location tracking. On social networking sites it is important that host families check that young people know how to report offensive posts, how to keep their settings private and how to block someone.

Students sign up to the Regent Guardians Student Behaviour Policy in which they agree to adhere to appropriate ‘house rules’ when staying with a host family, understand the importance of sharing any concerns they might have with the host families and understand the consequences of not following online safety guidelines.

If host families need any further guidance on issues relating to safer online activity they are welcome to discuss matters with the Regent Guardians DSL and there are also a number of online support websites for parents and carers listed at the end of this policy document.

It is important that Regent Guardians staff develop an open and trusting relationship with the child in their care so that the child feels able and confident to react appropriately if they are, for example, sent any unwanted images or messages which can be distressing, especially for younger children. If the child knows they have support from an adult who is looking after them, they are more likely to ask questions and for advice.

Similarly, Regent Guardians staff need to know what signs to look for if they suspect a child is experiencing online abuse. The NSPCC has produced this list of possible signs although it must be remembered these are not exhaustive:

• being upset after using the internet or phone;
• having more than one phone and responding differently to activity on each one;
• being unwilling to talk or secretive about their online activity;
• significantly changing the amount of time they spend on online activities;
• changing mood and appearing upset or angry after being on their online devices;
• not wanting to return to school or meet up with friends
• avoiding social situations
• sleeping problems
• lowering of self esteem

If children are found to have been practising unsafe online activities or sexting whilst in the care of Regent Guardians either during transits or during homestay visits, Regent Guardians staff need to know what steps to take.

Further Support
The following websites provide useful additional information and support for staff and carers to keep children safe online:

www.thinkuknow.co.uk – an education programme from CEOP (Child Exploitation and Online Protection), a UK organisation which protects children both online and offline

https://www.thinkuknow.co.uk/parents/articles/what-is-the-internet-of-things-iot – explains what is meant by the ‘Internet of Things’ and how Host Families in particular can use these devices safely with hosted children

www.internetmatters.org – help for parents keep their children safe online

www.parentzone.org – support for digital family life

www.nspcc.org.uk – advice for schools and young people

www.net-aware.org.uk – NSPCC advice for parents

Procedures
Guidance on dealing with incidents of inappropriate online activity including sexting in educational settings has been issued by the government, which means that there is a process in place for dealing with any cases. The ‘Keeping Children Safe in Education, 2023’ guidance means any cases of inappropriate online activity or sexting must be reported to a designated member of staff, who will then lead an investigation. If a member of Regent Guardians staff finds out that a child has been involved in sexting they must inform the Designated Safeguarding Lead (DSL) or phone the Regent Guardians 24/7 emergency number 07799 819787 as soon as possible.

The DSL will then follow the appropriate course of action as per the Regent Guardians Child Protection and Safeguarding Policy, and outlined on the following page:

Procedure followed by Regent Guardians in response to a disclosure:

Online Safety Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Prevent Anti-Radicalisation Policy

Introduction
Section 26 of the Counterterrorism and Security Act (2015) places a duty on certain bodies ‘to have due regard to the need to prevent people from being drawn into terrorism’. Regent Guardians is one of those bodies as it has a role in protecting vulnerable people and/or our national security.

The Prevent Duty Guidance (2023) provides advice for schools and childcare providers:

Prevent duty guidance: Guidance for specified authorities in England and Wales (publishing.service.gov.uk)

The aim of the Prevent strategy is to reduce the threat to the UK from terrorism by stopping people becoming terrorists or supporting terrorism.

The Prevent Duty
Regent Guardians staff need to be able to identify children who may be vulnerable to radicalisation and know what to do when they are identified. Regent Guardians can also build young people’s resilience to radicalisation by promoting fundamental British values and enabling them to challenge extremist views. ‘Extremism’ is defined as vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. It also includes calls for the death of members of our armed forces, whether in this country or overseas. Terrorist groups very often draw on extremist ideas developed by extremist organisations.

The general risks affecting children and young people can vary from area to area, and according to their age. Regent Guardians staff, host families and drivers should be in an important position to identify risks within their local context. Regent Guardians also need to be aware of the increased risk of online radicalisation, as terrorist organisations such as IS as well as far right political groups seek to radicalise young people using social media and the internet.

There is no single way of identifying an individual who is likely to be susceptible to a terrorist ideology. Regent Guardians staff need to be alert to changes in students’ behaviour which could indicate that they may be in need of help or protection. Young people at risk of radicalisation may display different signs or seek to hide their views. Staff should use their professional judgement in identifying young people who might be at risk of radicalisation and react proportionately. Staff will not be expected to unnecessarily intrude into family life but as with any other safeguarding risk, they must act when they observe behaviour of concern.

Training
The Designated Safeguarding Lead DSL undertakes Prevent awareness training and provides advice and support to other members of staff on protecting young people from the risk of radicalisation. This happens during a staff member’s induction to Regent Guardians and is updated at least annually. Students will also be alerted to the Prevent policy upon joining Regent Guardians through their Local Guardian.

The Home Office has developed three e-learning modules useful for Regent Guardians staff:

1. Prevent awareness e-learning offers an introduction to the Prevent duty (ideal for staff and Host Families)
   https://www.elearning.prevent.homeoffice.gov.uk/edu/screen1.html
2. Prevent referral e-learning supports staff to make Prevent referrals that are robust, informed and with good intention (ideal for DSLs and Directors) https://www.elearning.prevent.homeoffice.gov.uk/prevent_referrals/01-welcome.html
3. Channel awareness e-learning is aimed at staff who may be asked to contribute to or sit on a multi-agency Channel panel (additional optional training for DSLs) https://www.elearning.prevent.homeoffice.gov.uk/channel_awareness/01-welcome.html

Procedure
If Regent Guardians staff or students do have a concern about a young person, they should follow Regent Guardians normal safeguarding procedures, including discussing their concerns with the DSL. Further steps can then be taken by the DSL to refer on to the Local Safeguarding Partnership and/or seek advice from other involved parties such as schools.

Regent Guardians DSL 24-hour contact number: 07799 819787

In Prevent priority areas of the UK, the local authority will have a Prevent lead who can also provide support.

The local police can also be contacted by dialling 101 (non-emergency number).

The Department for Education (DfE) has a dedicated helpline (Tel: 020 7340 7264) to enable staff to raise concerns relating to extremism directly. Email: counter.extremism@education.gov.uk

The helpline is not intended for use in emergency situations, such as a young person being at immediate risk of harm or a security incident, in which case the normal emergency procedures should be followed.

Prevent Anti-Radicalisation Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

RG Staff Code of Conduct

Rationale
As stated in the statutory government guidance Keeping Children Safe in Education, 2023, schools and other organisations working with young people have a requirement to provide a code of conduct for all staff. For Regent Guardians this Code of Conduct applies to suppliers eg. Host Families and drivers as well as to employees. The word ‘staff’ in this Code of Conduct therefore applies to both categories.

Regent Guardians Aims, Principles & Practice
Regent Guardians cares for your child as if they were our own.

We act as the bridge between parents and school: liaising with both, caring for students, and making practical arrangements, all of which enable your child to thrive.

By spending time getting to know your child, meeting up with them regularly and maintaining contact with them, we respond quickly and effectively to their needs, to your requests, to the school and in support of our Host Families.

Regent Guardians staff always act professionally to support all our stakeholders and foster genuine friendships with those in our care.

Linked documents
This code of conduct must be read with due regard to the following documents which are available either on the Regent Guardians website www.regentguardians.com or upon request:

• Child Protection and Safeguarding Policy
• Prevent / Anti-Radicalisation Policy
• Online Safety and Sexting Policy
• Anti-bullying and Cyberbullying Policy
• Missing Students Policy
• Emergency Contingency Policy (includes pandemic information)
• Safer Recruitment Policy
• Complaints Policy
• Whistleblowing Policy
• Information Sharing and Data Protection Policy
• Host Family Handbook
• Student Handbook including A-Z of Behaviour Guidelines
• Staff Terms & Conditions and Contracts
• Personal job descriptions

Safeguarding & Welfare
Regent Guardians is fully committed to safeguarding and promoting the welfare of both young people and staff within its organisation. It operates within prescribed government guidelines including:

• Children’s Act 1989 & 2004
• Care Standards Act 2000
• Working Together to Safeguard Children 2023
• Keeping Children Safe in Education 2024

and fosters a positive working culture through mutual respect and tolerance of all staff and students.

Communication
When communicating with students by email always use the company email if you have access to it and send mail to the student’s school email address whenever possible. If not, it is a sensible precaution to copy in another staff member. A phone call is an acceptable method of communicating with the students if they are confident enough in their use of the spoken language. Other acceptable means of electronic communication are text messages or WhatsApp messages if you need to communicate urgently. Hasty messages sent without proper consideration can cause upset, concern or misunderstanding. Using social network sites as a means of communication between parties within the company is not acceptable.

Dress
Staff appearance and style of clothing also need considering depending on a student’s culture and background; revealing clothing can cause offence.

Gifts & rewards
It is normally inappropriate to give personal gifts or high value rewards which single out specific students in a group. It is important not to cause embarrassment or appear to favour one student for preferential treatment in this way. However, gifting an Easter egg to each student in the group or a small value birthday present to one person as part of company policy is acceptable and would be encouraged.

Language
When working with young people staff need to use language appropriate to the student’s age, level of English and maturity. It is always inappropriate to swear in front of them and it is also important to be aware that blasphemy may be viewed differently by different cultures so there is a need to be sensitive.

Meetings
When meeting with a student consider the location carefully. To safeguard yourself and the student choose somewhere which offers adequate privacy if you think that might be needed but one which is not hidden from view. Most classrooms and meeting rooms in schools have a window in the door which is useful. A student’s bedroom should be avoided as a meeting place but, if is necessary to use this, try to keep the door open.

Photos & videos
No member of Regent Guardians staff is allowed to take photos or videos of students without their permission. If photos or videos are taken they must not be uploaded onto social media sites or otherwise distributed.

Privacy
When staying with a host family it is important to appreciate a student’s right to privacy in his/her bedroom and bathroom. Do not enter your student’s room before knocking, calling out and receiving a response and do not hurry a student whilst they are using the bathroom.

Relationships
Appropriate social interaction with the students is important. Depending upon your role within Regent Guardians you will develop a certain relationship. For example, working as a host family ‘in loco parentis’ and caring for the student as if they were one of your own family necessitates a different level of social interaction from that which a Regent Guardians driver would have. The primary carer in the host family may need to offer support to a distressed student or restrain an upset student from hurting themselves or someone/something else. In these cases, it may be justifiable and helpful to make physical contact with the student but, under no circumstances should corporal punishment be used. Any form of sexual contact with a young person in the care of Regent Guardians, regardless of their age, is forbidden and would lead to external involvement

When working for Regent Guardians your role may entail interacting on a business or social level with the students’ parents, agents and school staff. In all circumstances you are representing Regent Guardians and therefore need to maintain appropriate levels of professionalism.

Searches
It is not acceptable to search a student or their belongings unless very strict guidelines are followed. If any member of staff has good reason to request a search, permission must first be sought from their line manager.

Smoking, drugs and alcohol
Regent Guardians operates a no smoking and no drugs policy. Alcohol should not normally be consumed within the working day other than for celebrations or business-related means. Host families may consume a sensible amount of alcohol whilst caring for students if that is the norm in the household. If a member of the host family smokes, Regent Guardians needs to be informed of this, and care must be taken not to smoke in rooms to which the student has access. Drugs or other illegal substances must not be used within host families.

Transportation
When transporting Regent Guardians students, the normal rules of the road need to be followed including appropriate use of child seats. If space permits, it is normal practice for the student to sit in the rear seat and this is strongly advisable when only transporting one passenger over a long distance.

Summary
Regent Guardians appreciates that whilst its staff work in positions of power and trust, uphold a duty of care to children and young people and need to exercise their own professional judgement to carry out their roles, there needs to be transparency and openness within the company. Hence, Director and DSL Jenny Chan is happy to answer any query, offer support or for clarification – the virtual door is always open.

Staff Code of Conduct – Regent Guardians
Updated May 2024; to be reviewed April 2025

Safer Recruitment Policy

Introduction
Regent Guardians is committed to providing the best possible care to its pupils and to safeguarding and promoting the welfare of children and young people. The Company is also committed to providing a supportive and flexible working environment to all its members of staff. The Company recognises that, to achieve these aims, it is of fundamental importance to attract, recruit and retain staff of the highest calibre who share this commitment.

The aims of the Company’s recruitment policy are as follows:
• to ensure that the best possible staff are recruited based on their merits, abilities and suitability for the position;
• to ensure that all job applicants are considered equally, consistently and with due reference to The Equality Act 2010;
• to ensure compliance with all relevant legislation, recommendations and guidance including the statutory guidance published by the Department for Education (DfE), Keeping children safe in education (2023) (KCSIE), Disqualification under the Childcare Act 2006 (DUCA), the Prevent Duty Guidance for England and Wales 2023 (the Prevent Duty Guidance) and any guidance or code of practice published by the Disclosure and Barring Service (DBS); and
• to ensure that the Company meets its commitment to safeguarding and promoting the welfare of children and young people by carrying out all necessary pre-employment checks.

Employees involved in the recruitment and selection of staff are responsible for familiarising themselves with and complying with the provisions of this policy and all other Regent Guardians literature, in particular:
• Child Protection & Safeguarding Policy
• Staff Code of Conduct

Recruitment and selection procedure
Advertisements will be placed in suitable media and will include a statement that safer recruitment guidelines will be followed and an Enhanced DBS check needed for the role.

Applicants will receive a job description and person specification for the role applied for. Application forms, job descriptions, person specifications and the Company’s Child Protection Policy are forwarded to applicants on request.

After completing a comprehensive application form, the applicant may then be invited to attend a formal interview at which their relevant skills and experience will be discussed in more detail. At least 2 closed references will be requested prior to attending interview and online checks undertaken. All shortlisted applicants will be questioned at interview about their suitability to work with children.

There will always be at least one member of the interview panel who has had certificated safer recruitment training in the last two years.

If it is decided to make an offer of employment following the formal interview, any such offer will be conditional on several factors including appropriate background, ID, Barred List and Enhanced DBS checks.

Recruitment information on the successful candidate will be stored on Regent Guardians’ single central record and in our staff files, in encrypted form. Information on unsuccessful candidates will also be stored in encrypted form during the recruitment process and then deleted once the successful candidate has been recruited.

Induction & Ongoing Training
All successful applicants will receive a comprehensive induction programme including child protection training and regular updates.

New employees will take part in an organised appraisal programme enabling them to progress appropriately and Regent Guardians to regularly assess the suitability of new candidates.

Each new employee will undergo a 3-month probationary period.
Only those applicants who share Regent Guardians drive to safeguard and promote the welfare of young people and children in its care should apply for a post.

Safer Recruitment Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Whistleblowing Policy

Introduction
Regent Guardians seeks to provide a culture of trust and openness amongst its staff and therefore encourages honest and appropriate feedback on all aspects of its operations. Whistleblowing procedures protect staff members who report colleagues they believe are doing something wrong or illegal, or who are neglecting their duties.

Under certain circumstances employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work. Making such a disclosure is called Whistleblowing.

Qualifying Disclosures

1. Certain disclosures are prescribed by law as ‘qualifying disclosures’. A ‘qualifying disclosure’ means a disclosure of information that the employee genuinely and reasonably believes is in the public interest and shows that the company has committed a ‘relevant failure’ by:

• committing a criminal offence;
• failing to comply with a legal obligation;
• a miscarriage of justice;
• endangering the health and safety of an individual;
• environmental damage; or
• concealing any information relating to the above.

2. These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening or is likely to happen. Regent Guardians will take any complaints you wish to raise relating to the above matters very seriously.

3. The Employment Rights Act 1996 provides protection for workers who ‘blow the whistle’ where they reasonably believe that some form of illegality, injustice or breach of health and safety has occurred or is likely to occur. The disclosure must be ‘in the public interest’. We encourage you to use the procedure to raise any such concerns.

1. Procedure
   In the first instance you should report any concerns you have to Jenny Chan, Director, (jenny@regentguardians.com) who will treat the matter with the utmost confidence.
2. You may also make a formal representation in writing to the Trustees of AEGIS (the Association for the Education and Guardianship of International Students), c/o Yasemin Wigglesworth, Executive Officer (info@aegisuk.net)
3. The NSPCC have a whistleblowing helpline which is available for staff who do not feel able to raise concerns regarding child protection failures within an organisation. Staff can call 0800 028 0285 between 8am Monday to Friday or can email: help@nspcc.org.uk
4. In addition, Protect provide a free, confidential advice line for concerned staff to call before whistleblowing.  The helpline is 020 3117 2520 and their website is: Protect – Speak up stop harm – Protect – Speak up stop harm (protect-advice.org.uk)

Treatment by Others
Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

Low Level Concerns
Regent Guardians recognizes that the safety and wellbeing of students in our care depends on the vigilance of all our staff and suppliers.  We rely on prompt communication of any concerns, no matter how small, about any conduct by an adult which causes doubt about that adult’s suitability to work with or have access to, children.  This includes any adult whether staff, volunteers, host families, visitors to host families, school staff, drivers.

Where an adult’s behaviour towards a child or another adult is deemed inappropriate but does not meet the threshold set out in the Safeguarding and Child Protection Policy, the Director of Regent Guardians, Jenny Chan, should be informed on the contact details in the footer.

The Director will then examine the evidence and discuss the behaviour with the adult concerned before reminding them of the company’s expectations, provide necessary training, set realistic goals and monitor the situation going forward. If further allegations were to be made and were found to be justified, then more serious steps would be taken that could involve a termination of their contract with Regent Guardians.

If there are low level concerns about the Director, then Regent Guardians Deputy Designated Safeguarding Lead (DDSL) Rachel Debenham should be informed on r.debenham@wellington-school.org.uk

Regent Guardians will always act if alerted to the possibility of abuse of any person, whether in or outside of our care.  The notification and prompt handling of all concerns is fundamental to safeguarding students.  It helps to identify and prevent abuse and also to protect adults against misunderstanding or misinterpretation.  It also encourages transparency, openness and trust as well as clarifies expected behaviour.

Those raising concerns or reporting allegations in good faith will always be supported, including adults about whom concerns or allegations have been raised but not substantiated.

Whistleblowing Policy – Regent Guardians
Updated May 2024; to be reviewed April 2025

Anti-Bullying & Cyberbullying Policy

Overview
This policy has due regard to the following documents:
• DFE Advice ‘Preventing & Tackling Bullying’ (2017)
• Keeping Children Safe in Education (2023)
• Local Safeguarding Partnerships (LSPs)
• The Equality Act (2010)
This policy should be read in conjunction with Regent Guardians’ Child Protection and Safeguarding
Policy and the ‘A-Z of Behaviour Guidelines’.

Aims
• Eliminate unlawful discrimination of any kind
• Promote equality of opportunity
• Value qualities of respect, tolerance, inclusion and kindness
• Promote diversity and a culture of inclusion

Bullying
Bullying is behaviour by an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally. It can be defined by the victim and not by the perpetrator.
For example, the perpetrator may argue their actions were ‘just banter’ and not meant to offend but if the victim has shown their unhappiness over these actions and asked the perpetrator to stop then Regent Guardians views this as bullying. Bystanders in bullying incidents
can also be considered to be perpetrators if they do not intervene to support the victim.

Due to the nature of bullying, the child may find it difficult to tell anyone for fear that things will get worse if they do. Bullies rely on this fear to continue bullying, resulting in the bullied child feeling ashamed or embarrassed about what’s happening.

There are 3 identified types of bullying:
• Indirect bullying also known as social bullying or relational bullying (spreading rumours, social exclusion, disclosing another’s secrets to a third party).
• Direct verbal bullying (yelling abuse at another, name-calling, insulting someone, using
verbal threats)
• Direct physical bullying (pushing, hitting, punching, kicking)

Early intervention in bullying is crucial to ensure that light hearted ‘banter’ does not cross the line into bullying and to ensure that boundaries are set. Where it is thought a child is suffering ‘significant harm’ the bullying incident will be treated as a child protection concern.

Bullying itself is not a criminal offence in the UK but some types of harassment are, and could be defined as a hate crime. If this were to be the case, Regent Guardians would notify the police.

Cyberbullying
Cyberbullying is bullying that takes place using technology. Whether on social media sites, through a mobile phone, or gaming sites, the effects can be devastating for the young person involved.

Regent Guardians would liaise closely with the student’s school in any cyberbullying cases using, if necessary, powers prescribed in the Education Act 2011 to enable the searching and deletion of electronic images or files on electronic devices including phones.

If Regent Guardians believes the police need to be involved because of pornographic images of a child or extreme pornography, then images must not be deleted.

Training
Regent Guardians staff, host families and drivers receive basic training in anti-bullying and cyberbullying during their induction and regular updates at least once a year as part of their ongoing safeguarding training.

Procedures
Regent Guardians fosters an ethos of inclusion, inculcating respect for others, their property and their individuality. These values also pay heed to the fundamental British values of democracy, the rule of law, individual liberty and mutual respect and tolerance of those of different faiths and
beliefs. All Regent Guardians staff are aware that bullying is unacceptable and should not be tolerated at any time. All staff are prepared and skilled to recognise, listen and act upon any bullying incident. Advice and support are offered to all.

Regent Guardians does not tolerate any form of bullying involving students or staff and investigates all allegations of bullying/cyberbullying, dealing with each incident swiftly and effectively. Our aim is to protect the victims of bullying and to educate the perpetrator about the consequences of their inappropriate behaviour. It is hoped, in most cases, that all people involved will learn from the experience and that relationships can be rebuilt positively.

Host families may find themselves in a situation where the young person opens up and tells them that he/she is being bullied. If this does happen, the host family member would need to adopt the same protocol as for any safeguarding incident; not promising confidentiality, listening without judging, supporting the young person, making notes and then informing Jenny Chan, Designated Safeguarding Lead (DSL) by email jenny@regentguardians.com or by calling the 24/7 emergency number 07799 819787.

In more serious cases, some of which have been mentioned above, the DSL may need to refer the matter to outside agencies. It is likely that Regent Guardians will involve the young person’s school in the process as well as their parents, but it must be appreciated that each case is investigated on an individual basis.

Further Resources
The following websites provide useful advice and guidance for recognising, supporting and dealing with bullying incidents:
www.thinkuknow.co.uk
www.childline.org.uk
www.nspcc.org.uk

Anti-Bullying & Cyberbullying Policy – Regent Guardians
Updated April 2024; to be reviewed April 2025

Complaints Policy

Regent Guardians recognises that there may be legitimate concerns, complaints or grievances from
• Parents
• Students
• Staff
• Schools
• Host families
• Agents
• Other partners

about any aspect of Regent Guardians services or activities. We encourage any concerns to be made known to Regent Guardians as soon as possible so that we can work together in partnership to address them and improve our service. A complaint or grievance, in contrast to a concern which is raised informally, may be informal or formal and requires investigation. This policy lays out our procedures for dealing with complaints quickly and fairly.

Regent Guardians:
• Takes all concerns, complaints and grievances seriously
• Aims to resolve all complaints and grievances within 28 working days of the complaint being received, in line with the procedure set out in this policy
• Makes a full and fair investigation of any complaint or grievance
• Ensures that no-one is penalised for making a complaint in good faith
• Keeps a written record for at least three years of all complaints, action taken and outcomes
• Reviews annually the written record of complaints and their outcomes
• Keeps all records relating to complaints confidential

Stage 1 – Informal
All complaints, whether orally or in writing, should be made to the individual’s line manager and/or Director. A record will be kept by the relevant manager of all correspondence, conversations, responses and action taken. It is hoped that the matter will be resolved satisfactorily between the parties involved. If appropriate, Regent Guardians may call upon the services of a suitably experienced and impartial arbitrator.

Stage 2 – Formal
If the matter cannot be resolved informally, then complaints or grievances must be directed, if they haven’t already been, in writing to the Director. A record will be kept of all correspondence, responses and action taken. The Director will send a reply to the complainant on the same day as the complaint is received. The reply may be in the form of a holding email, allowing further time to look into the complaint. After the complaint is investigated, a response will be sent acknowledging the complaint and presenting a solution where possible. Any further information given will be taken into account and a final formal response given within 28 working days of the formal complaint being received.

Stage 3 – Panel
If the complaint or grievance cannot be successfully resolved at Stage 2, parties may make a formal representation in writing to:

The Trustees of AEGIS (the Association for the Education and Guardianship of International Students),
c/o Yasemin Wigglesworth, Executive Officer
The Wheelhouse, Bond’s Mill Estate,
Bristol Road,
Stonehouse,
Gloucestershire,
GL10 3RF
info@aegisuk.net
+44 (0) 1453 821293

Complaints Policy – Regent Guardians
Updated January 2024; to be reviewed January 2025

Information Sharing and Data Protection Policy: Third Party Contractors

Regent Guardians Ltd respects your privacy and is committed to protecting your personal data. This policy will explain how we look after your personal data and tell you about your privacy rights and how the law protects you.

We use third party contractors to help us in supplying our services to our customers (international students and their parents). These contractors include (but are not limited to) host families, drivers, DBS checking services and educational consultants.

We require our contractors to protect any personal data to which they have access and to share it only in accordance with our guidelines. We will train you in data protection compliance and give you written guidelines on information sharing and data protection procedures. We will then require you to sign an agreement that you will adhere to our guidelines. See Guidelines for Contractors at the end of this policy.

Summary of how we use your personal data
• Regent Guardians uses your personal data:
○ where we need to perform the contract which we are about to enter into, or have entered into, with you;
○ where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
○ where we need to comply with legal obligations;
○ where we have your consent.

• Personal data is shared with other companies for example to pay you for your services and
with third parties such as:
○ other companies that assist us in performing our services;
○ our insurance providers;
○ accreditation organisations;
○ companies carrying out DBS checks (where relevant and necessary).

• Where we rely on your consent, such as for marketing purposes, you can withdraw this consent at any time.

• This policy sets out more details of the processing, including details of your data protection
rights, including your right to object to certain processing.

What information do we collect?
We collect and process personal data about you. This includes:
•  your name, contact details, information for DBS checks, bank details
•  communications that you may send to us.

How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract. This includes:
○ verifying your identity;
○ making payments;
○ communicating with you;
○ providing customer services by sharing your details when necessary with students, parents and schools;
○ we will use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation), for example we may need to share personal data with an inspection authority to comply with our regulatory obligations.

Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal data for other purposes, such as those set out above.

Who will we share this personal data with, where and when?
Personal data will be shared with other individuals and organisations as set out above such as schools, students, parents, insurers and organisations which conduct background checks, where necessary.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of a Controller for the purposes identified above. In particular, we use third party providers of website hosting and maintenance, identity checking, educational consultancy providers and business development services.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this personal data with another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or where we are using the personal data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us via our Data Protection Controller using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data
protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner’s Office in the UK.

How will you keep my personal data safe?
We will keep all personal data in a password protected electronic database which only our own staff can access. Any paper copies which may need to be made will be kept in a locked cupboard in the lockable Regent Guardians office.

The transmission of information via the internet is not completely secure and such transmission from you to us is therefore at your own risk. Any password protection used relies upon you keeping the password confidential.

How long will you retain my personal data?
We only retain your personal data for as long as is required by law, or for as long as necessary for the purposes for which we process your personal data. This is ordinarily 6 years after you have ceased to be our contractor.

How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your personal data. If you have any concerns about how we process your personal data, or would like to opt out of direct marketing, you can get in touch with our data protection Controller by email on
info@regentguardians.com

Which Controller entity is my data controller, and which affiliates might my personal data be shared with?
The data Controller for your information is the entity with which you have a relationship; in this case Regent Guardians Ltd. It is likely that your personal data would only be shared within Regent Guardians Ltd.

Guidelines for Contractors
We require our contractors to protect any personal data on Regent Guardians students and parents to which they have access and to share it only in accordance with our guidelines. We will train you in data protection compliance, information sharing and data protection procedures. We will then require you to sign an agreement that you will adhere to our guidelines as follows:
• All Regent Guardians personal data is stored on a password encrypted database. The database must remain in an encrypted fashion at all times and not be stored unencrypted elsewhere
• Any breach of this will be treated as gross misconduct
• Where specific data needs to be transferred from the database e.g. in order for a host family or driver to complete a service, this data will comprise the minimum necessary for the service to be completed.
• The data, if sent electronically, will be password protected. If it is necessary for the data to be held on paper e.g. when meeting a student at an airport or transporting them to a school, the contractor must destroy the personal data that they hold once the service has been completed
• Data must not be shared with any other party except Regent Guardians personnel
• If any breach of personal data occurs, the contractor must inform Regent Guardians immediately
• Failure to inform Regent Guardians of such a breach will be treated as gross misconduct

Information Sharing & Data Protection Policy; Contractors – Regent Guardians
Updated April 2024; to be reviewed April 2025

Information Sharing and Data Protection Policy: Parents and Students

Regent Guardians respects your privacy and is committed to protecting your personal data. This privacy policy will explain how we look after your personal data when you visit our website (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.

Summary of how we use your personal data
• Regent Guardians uses your personal data:
○ where we need to perform the contract which we are about to enter into, or have entered into, with you;
○ where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests;
○ where we need to comply with legal obligations;
○ where we have your consent.

• Personal data is shared with other companies and with third parties, such as:
○ your child’s host family / families;
○ your child’s school;
○ your child’s driver(s);
○ your educational agent (where relevant and necessary);
○ other companies that assist us in performing our services;
○ our insurance providers;
○ companies carrying out background checks (where relevant and necessary)

• Where we rely on your consent, such as for marketing purposes, you can withdraw this consent at any time.

• Our privacy policy sets out more details of this processing, including details of your data protection rights, including your right to object to certain processing.

What does this policy cover?
This policy describes how Regent Guardians will make use of your personal data when you register your details or your child’s details on the Regent Guardians website. When we mention “Controller”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company or third party responsible for processing your personal data.

The policy also describes your data protection rights, including a right to object to some of the processing which a member of the Regent Guardians carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?
We collect and process personal data about you when you interact with us and our websites, and when you purchase resources and/or services from us. This includes:
○ your name, contact details, relationship to the child, nationality and consents given;
○ your child’s name, date of birth, gender, contact details, photograph, nationality, passport and visa details, religion and school reports;
○ full medical information on your child, including any allergies and disabilities;
○ your payment and delivery details, including billing address and credit card details, where you make purchases from us (where relevant);
○ your marketing preferences, including any consents you have given us;
○ communications that you may send to us;
○ information related to the browser or device you use to access our website.

How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you purchase resources or services from us. This also includes:
○ verifying your identity;
○ taking payments;
○ communicating with you;
○ providing customer services and arranging the delivery or other provision of resources or services.

• As required to conduct our business and pursue our legitimate interests, in particular:
○ we will use your information to provide details of resources and services you have enquired about or resources or services you have requested, and respond to any comments or complaints you may send us;

○ we monitor use of our website and online services, and use your information to help us monitor, improve and protect our resources, content, services and website, both online and offline;

○ we use information you provide to personalise our website, resources or services for you;

○ where relevant, if you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);

○ we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;

○ we use information you provide to investigate any complaints received from you or from others, about our website or our resources or services;

○ we will use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation), for example we may need to share personal data with the Department of Education or an inspection authority to comply with our regulatory obligations;

○ we use personal data of some individuals to invite them to take part in market research.

• Where you give us consent:
○ we will send you direct marketing in relation to our relevant resources and services, or other resources and services provided by us.;
○ we place cookies and use similar technologies in accordance with our cookies policy (see below paragraph Cookies and how we use them) and the information provided to you when those technologies are used;
○ on other occasions where we ask you for consent, we will use the personal data for the purpose which we explain at that time.

• For purposes which are required by law:
○ where we need parental consent to provide online services to children under 13. However, most of our websites are not designed for children under 16;
○ in response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, updating your preferences in any account or by contacting us using the details set out below.

Who will we share this personal data with, where and when?
Personal data will be shared with other individuals and organisations as set out above such as schools, host families, insurers and organisations which conduct background checks, where necessary.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of a Controller for the purposes identified above. In particular, we use third party providers of website hosting, maintenance and identity checking.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Cookies and how we use them
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you
from taking full advantage of the website.

What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this personal data with another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or where we are using the personal data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us via our Data Protection Controller using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This likely to be the Information Commissioner’s Office in the UK. 

How will you keep my personal data safe?
We will keep all personal data in a password protected electronic database which only our own staff can access. Any paper copies which may need to be made will be kept in a locked cupboard in the lockable Regent Guardians office.

How long will you retain my personal data?
We only retain your personal data for as long as is required by law, or for as long as necessary for the purposes for which we process your personal data. If your child does not sign up for Regent Guardians, we will destroy your data one year after your application. If the child does sign up for
Regent Guardians, we will destroy your data one year after the child leaves our guardianship. The child’s data will be kept electronically to comply with Safeguarding regulations.

How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your personal data. If you have any concerns about how we process your personal data, or would like to opt out of direct marketing, you can get in touch with our Data Protection Controller by email on
info@regentguardians.com

Which Controller entity is my data controller, and which affiliates might my personal data be shared with?
The Controller for your information is the entity with which you have a relationship; in this case Regent Guardians Ltd.

Information Sharing & Data Protection Policy: Parents & Students – Regent Guardians
Updated April 2024; to be reviewed April 2025

Privacy Policy

Regent Guardians Ltd. respects your privacy and is committed to protecting your personal data. This privacy policy informs you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you register your details or your child’s details with us. It tells you about your privacy rights and how the law protects you. It also describes your data protection rights, including the right to object to some of the processing which Regent Guardians carry out. Information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

Summary of how we use your personal data Regent Guardians uses your personal data:
o where we need to perform the contract which we are about to enter into, or have entered into, with you;
o where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
o where we need to comply with legal obligations;
o where we have your consent.
Personal data is shared on occasion with third parties, such as:
o companies that assist us in performing our services;
o our insurance providers;
o companies carrying out background checks (where relevant and necessary).

Where we rely on your consent, such as for marketing purposes, you can withdraw this consent at any time. This policy sets out details of the processing, including details of your data protection rights and your right to object to certain processing.

What information do we collect?
We collect and process personal data about you when you interact with us and our website, and when you purchase services from us. This includes:
o your name / your child’s name;
o your / your child’s nationality and gender;
o your child’s age/date of birth;
o relevant medical information required for us to perform our service;
o your / your child’s home address, email address and phone number;
o details of your child’s school, academic progress and interests;
o your payment details where relevant;
o your marketing preferences, including any consents you have given us;
o communications that you may send to us;
o information related to the browser or device you use to access our website.

How do we use this information, and what is the legal basis for its use?
We process this personal data for the following purposes:
• To fulfil a contract, or take steps linked to a contract: this is relevant where you purchase
services from us. This includes:
o verifying your identity;
o taking payments;
o communicating with you;
o providing customer services and arranging the provision of resources or services.

• As required to conduct our business and pursue our legitimate interests, in particular:
o we will use your information to provide details of resources and services you have enquired about or requested, and respond to any comments or complaints you may send us;
o we monitor use of our website and online services, and use your information to help us monitor, improve and protect our resources, content, services and website, both online and offline;
o we use information you provide to personalise our website, resources or services for you;
o where relevant, we may use third parties to check the validity of your payment details in order to prevent fraud (see data sharing below);
o we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
o we use information you provide to investigate any complaints received from you or from others, about our website or our resources or services;
o we will use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation), for example we may need to share personal data with an inspection authority to comply with our regulatory obligations;
o we use personal data of some individuals to invite them to take part in market research.

• Where you give us consent:
o we will send you direct marketing in relation to our relevant resources and services, or other resources and services provided by us;
o we place cookies and use similar technologies in accordance with our cookies policy (see below paragraph Cookies and how we use them) and the information provided to you when those technologies are used;
o on other occasions where we ask you for consent, we will use the personal data for the purpose which we explain at that time.

• For purposes which are required by law:
o for DBS checks on suppliers such as host families and drivers;
o in response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the email address set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, updating your preferences in any account or by contacting us using the details set out below.

Who will we share this personal data with, where and when?
Regent Guardians may share personal data with other organisations, such as insurers and organisations which conduct background checks, where necessary.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of Regent Guardians for the purposes identified above. For example, we use third party providers of website hosting and maintenance; DBS checking of employees and suppliers; providers of host family and driving services; educational consultants; business development consultants.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business.

Which Controller entity is my data controller, and which affiliates might my personal data be shared with?
The Controller for your information is the entity with which you have a relationship, or which manages the website you have visited. In this case it is Regent Guardians Ltd.

Storing your personal data
Data provided is kept in a password protected encrypted electronic database which only our own staff can access. Where paper copies are needed of any data, these are stored in a locked cupboard in Regent Guardians office. The transmission of information via the internet is not completely secure and such transmission from you to us is therefore at your own risk. Any password protection used relies upon you keeping the password confidential.

Cookies and how we use them
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the
owners of the site.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this personal data with another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or
where we are using the personal data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us via our Data Controller using the email address set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner’s Office in the UK.

How long will you retain my personal data?
We only retain your personal data for as long as is required by law, or for as long as necessary for the purposes for which we process your personal data.

How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your personal data. If you have any concerns about how we process your personal data, or would like to opt out of direct marketing, you can get in touch with our Data Controller at info@regentguardians.com

Privacy Policy – Regent Guardians
Updated April 2024; to be reviewed April 2025