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Policy and Code of Practice

Safeguarding Policy
Safeguarding Code of Practice

Safeguarding Policy

IMPERIAL COLLEGE LONDON

CHILD PROTECTION AND ADULTS AT RISK SAFEGUARDING POLICY

INTRODUCTION AND DEFINITIONS

1. Safeguarding involves taking steps to protect people (especially children and adults at risk) from harm and responding appropriately when required.

2. For the purpose of this Policy and associated Code of Practice, the following definitions will apply:

a. “Child” or “Children”: The statutory guidance Working Together to Safeguard Children (“Working Together”) defines a “child” as anyone who has not yet reached their 18th birthday. The terms “child” and “children” will be used to describe all children and young people under the age of 18 years.

b. “Adults at risk”: The Care Act 2014 provides that safeguarding duties apply to an adult who (a) has needs for care and support, (b) is experiencing, or is at risk of, abuse or neglect, and (c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it. The term “adults at risk” will be used to describe adults who meet these criteria.

c. “Staff”: The term “staff” will be used to describe those people employed on a contract of employment at the College, as well as those working on consultancy agreements as contractors and on a voluntary and/or unpaid basis.

d. “Student”: The term “student” will be used to describe any undergraduate or postgraduate student registered with the University.

GENERAL PRINCIPLES

3. Working Together to Safeguard Children defines safeguarding and promoting the welfare of children as:

protecting children from maltreatment
preventing impairment of children’s mental and physical health or development
ensuring that children grow up in circumstances consistent with the provision of safe and effective care
taking action to enable all children to have the best outcomes.

4. The University has a specific responsibility to protect children from harm and abuse including neglect, physical injury, sexual abuse and emotional abuse. The University also has a duty to make services accessible. Imperial College recognises and accepts these responsibilities and seeks to safeguard the welfare of all children that attend, visit or engage with Imperial College. The University will take proactive and appropriate steps to ensure that its responsibilities are met. All Imperial staff should be aware of safeguarding issues that can put children at risk of harm.

5. The Care and Support statutory guidance sets out that adult safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect. It says that adult safeguarding is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action.

6. In a Higher Education context, the term safeguarding may also be used more broadly to refer to a general duty of care to members of our community and the communities where we work to deliver education and to carry out research. The University prioritises student and staff welfare and the prevention of harm. Our safeguarding information and guidance will be applied, in an integrated way, to support all those who may be vulnerable. Supporting policies, including those covering bullying and harassment, are listed in the associated Code of Practice.

POLICY

7. To fulfil its safeguarding obligations, it is Imperial College Policy:

a. To always request a Disclosure and Barring Service (DBS) check (see the Code of Practice) for those staff and students who undertake regulated activity, and will consider obtaining a DBS check in other circumstances where the University is legally entitled to do so. This requirement also applies to overseas workers.

b. To require staff to notify the Head of Department of any current criminal conviction. (See Core Terms and Conditions of Service [PDF]‌). All staff (including those who do not work directly with children or adults at risk) are required immediately to notify their Head of Department of any circumstances that may impact on their suitability to work alongside children or adults at risk, including but not limited to any arrest or charge for a sexual offence of any kind (regardless of whether it relates to children and/or adults at risk) or for an offence relating to any other form of misconduct involving children or adults at risk. The requirement to notify the University of any current criminal conviction or circumstance impacting suitability will also apply to workers engaged by external commercial partnerships on University sites.

c. To require ethical reviews and risk assessments to be undertaken for all activity involving children or adults at risk, including overseas fieldwork, to account for the possibility of sustained contact with children and/or vulnerable groups and to ensure appropriate reporting strategies are in place. The process for review and approval of risk assessments is available on the Imperial College Safeguarding webpages.

d. To ensure that staff and students who have unsupervised or regular access to children and/or vulnerable groups have access to appropriate guidance and training.

e. To ensure appropriate safeguards and risk assessments are in place for commercial contracts where children and/or vulnerable groups are using University facilities.

8. A member of staff who has any concerns regarding the welfare of a child or vulnerable adult must report their concerns to their local safeguarding officer as an individual set out in the referral’s flowchart – see Imperial College safeguarding webpages. This requirement applies to concerns that arise both within the University or elsewhere. The Local Safeguarding Officer will liaise with the appropriate Lead Safeguarding Officer.

9. The Lead Safeguarding Officer will guide on appropriate action and may refer the case as appropriate to the DBS, to children’s social services where they conclude that someone may have caused harm or abuse or poses a risk of harm or abuse to a child, to the Local Authority Designated Officer where there are concerns that that a member of staff may be abusing a child, and/or to the Police where there is a concern that a crime may have been committed. In all circumstances, the University will adopt an integrated approach to safeguarding working with multi-agency support as appropriate.

10. If appropriate, the Director of Safeguarding will refer a case for any relevant action, such as suspension or commencing disciplinary proceedings, if such action has been approved by the Police and/or the Local Authority Designated Officer, where such external agencies are involved.

11. The Imperial College will make a referral to the DBS when a member of staff is dismissed or leaves following safeguarding allegations and where the DBS harm criteria is met.

12. The University Management Board has agreed this Policy and associated Code of Practice. The Director of Safeguarding will have responsibility for the day to day implementation with advice from Imperial College’s Safeguarding Committee. See Imperial College safeguarding webpages for the Safeguarding Committee’s membership and terms of reference.

MONITORING

13. The Director of Safeguarding will have overall oversight of cases that are referred under this Policy. There will be an ongoing review of the implications of any cause for concern arising under this Policy and associated Code of Practice and whether, as a result, it might be necessary to take further action itself or to review or amend its Policy, Code of Practice and procedures.

DISSEMINATION OF THE POLICY

14. This Policy and associated Code of Practice will be available for reference on Imperial College’s Central Secretariat and Human Resources web pages.

15. Copies will be made available to all Imperial College subsidiaries to which the Policy and associated Code of Practice will also apply.

16. Parents/guardians of children, schools, external clients and contractors involved in activities related to the University will be made aware of this Policy and associated Code of Practice and required to follow the requirements whilst using University facilities and services.

REVIEW

17. The operation of the Policy and associated Code of Practice will be reviewed annually by Imperial College’s Safeguarding Committee. An annual report will be provided to the University Management Board’s Risk, Compliance and Ethics Committee and the Council’s Audit and Risk Committee.

18. This Policy and associated Code of Practice should be read in conjunction with the Human Resources Guidance Note – Disclosure and Barring Service Checks - Guidelines for Line Managers.

19. All personal and sensitive data will be collected, processed and stored securely and confidentially in accordance with the Data Protection Act (DPA) 1998 and, the General Data Protection Regulation (GDPR) - and any other applicable legislation which may follow as well as Imperial College’s Data Protection policy.

Approved by the Imperial College’s Safeguarding Committee and Provost’s Board March 2018

Updated July 2020, November 2020, February 2022 and March 2023 (Provost’s Board changed to University Management Board), March 2024

Safeguarding Code of Practice

IMPERIAL COLLEGE LONDON

CHILD PROTECTION AND SAFEGUARDING - CODE OF PRACTICE

IMPERIAL COLLEGE POLICY

1. This Code of Practice complements the Child Protection and Adults at Risk Safeguarding Policy and provides more detailed guidance for staff on protecting children from harm.

RESPONSIBILITIES

2. The University Management Board. The responsibility for oversight of the Imperial College’s Child Protection and Adults at Risk Safeguarding Policy rests with the University Management Board’s Risk, Compliance and Ethics Committee, with delegated responsibility to the Director of Safeguarding with advice from Imperial College’s Safeguarding Committee.

3. The Director of Safeguarding. The University’s Child Protection Officer and Designated Officer for Ofsted. Delegated responsibility for oversight of Imperial College’s Child Protection and Adults at Risk Safeguarding Policy with advice from Imperial College’s Safeguarding Committee.

4. Lead Safeguarding Officers. These are the Director of Safeguarding, the Director of Student Services, the Head of Outreach Programmes and the Head of the Early Years Learning Centre. They act as the main contacts in the University for the protection of children and adults at risk and may take the lead in making referrals to the DBS, the Police and/or the Local Authority Designated Officer as appropriate.

5. Local Safeguarding Officers. Act as the main contact in their area for the protection of children and adults at risk and the person to whom staff should report concerns. Responsible for escalating concerns to Lead Safeguarding Officers as appropriate.

6. Staff Compliance team. The Staff Compliance team has a responsibility for obtaining DBS checks for members of staff, prospective staff, casual workers, volunteers and honorary contracts in liaison with the individual and/or department concerned, and for handling any disclosures made as a result. See below for information regarding student DBS checks, and/or checks relating to non-staff volunteers working with the Outreach Department.

7. Imperial College’s Safeguarding Committee. The Safeguarding Committee is chaired by the Director of Safeguarding. The membership includes representatives from across the University who have lead responsibility for activities involving under 18s or vulnerable adults. The Committee meets at least twice a year to (1) agree protocols and procedures that reflect a best practice approach to safeguarding (2) ensure clear accountability and training for those with responsibility for safeguarding (3) share learning and casework developments to improve awareness and compliance.

8. Faculty Deans, Heads of Departments/ Divisions. Faculty Deans and Heads of Department/ Divisions and all other managers have delegated responsibility in their own areas supported by Faculty Operating Officers and Faculty Senior Tutors and research leads.

9. Individual staff members. Individual members of staff are responsible for familiarising themselves with the Policy, undertaking the mandatory online safeguarding training and informing colleagues and/ or managers of their particular requirements, for example, regarding further training.

REGULATED ACTIVITY AND THE DISCLOSURE AND BARRING SERVICE CHECKS

10. It is a criminal offence for an employer to knowingly place staff (including casual workers, honorary and volunteers) or volunteers who have been barred by the DBS in posts working with children and/or adults at risk where staff, casual workers, honorary or volunteers will be carrying out regulated activity, and it is a criminal offence for individuals barred by the DBS to work in or apply to work in those positions. The DBS is responsible for maintaining a list of individuals barred from working with children and/or adults at risk and for processing requests for DBS checks (criminal record checks). The University is registered with a third party provider (Mayflower Disclosure Services Ltd) for DBS checks and will ensure that a check is conducted when required.

A DBS check is needed for all staff and students who are engaged in, or will engage in, “regulated activity”([1]) and the University is also entitled to carry out DBS checks on individuals in certain other roles to which an exception under the Rehabilitation of Offenders Act 1974 applies. The University will usually arrange for a DBS check to be carried out when it is legally entitled to do so, even if this is not a legal requirement. There are four levels of check: Basic (only carried out by Imperial in specific circumstances) Standard, Enhanced and Enhanced with Barred List Checks. The Staff Compliance team has procedures in place for obtaining the requisite clearance from the DBS for staff. In some cases, a safeguarding risk assessment will also be required. The online DBS application form requires input from both the individual requiring the DBS check (the “applicant”) and the Staff Compliance team. The DBS will send a copy of the disclosure certificate directly to the applicant. The Staff Compliance team will review the result and refer to the Director of Safeguarding if necessary. For posts where DBS checks are an essential and ongoing requirement, the individual will be required to subscribe to the DBS update service which will allow the Staff Compliance team to carry out regular checks on the individual’s DBS status.

When recruiting an overseas candidate, it may be necessary to ask the candidate to apply for a criminal records check overseas or certificate of good character.

STUDENTS UNDER THE AGE OF 18

11. Imperial College has a duty of care towards students who are defined as children. For these students, good practice means that the University will:

a. Inform parents and guardians that it does not act in the place of a parent;

b. Have a list of the student’s emergency contact details, in particular those of parents and guardians;

The Safeguarding Vulnerable Groups Act 2006 set out the activities and work considered to be “regulated activity”, which a barred person must not do. The Protection of the Freedoms Act 2012 amended the definition.

With regard to activity relating to children, regulated activity “comprises in summary:

(i) unsupervised activities: teach, train, instruct, care for or supervise children, or provide advice/guidance on well-being, or drive a vehicle only for children;

(ii) unsupervised work for a limited range of establishments (‘specified places’) with opportunity for contact: for example, schools, children’s homes, childcare premises, children’s nurseries, children’s hospitals.

Work under (i) and (ii) is regulated activity only if done regularly.”

“Regular” means carried out by the same person frequently (once a week or more often), or on 4 or more days in a 30-day period (or overnight (2am to 6am).

c. Inform the student that they may not enter licensed premises or hold office;

d. Undertake risk assessments of activities involving children, and

e. If concerns arise, take appropriate action to safeguard the welfare of such students, taking into account their age.

To ensure the above measures are implemented, the procedures set out in the Imperial College London Policy and Procedure for Admitting Students Under 18 Years of Age will be followed and the applicable declaration completed and signed.

12. Academic Staff. Within Departments/ Divisions, academic staff will have the primary contact with students under 18. It is the responsibility of the relevant Head of Department/ Division to identify at the earliest possible opportunity children who will be studying in the Department/ Division, and to notify the appropriate members of staff of these students, as well as ensuring that the steps in the paragraph above are carried out including ensuring risk assessments are in place for all activities. The Head of Department/ Division will have the responsibility to ensure that any staff within the Department/ Division undertaking, or due to be undertaking work that requires DBS clearance are DBS checked using the process put in place by Staff Compliance. Those who will be subject to DBS checks may include (depending on the course and level of study) personal tutors, academic tutors, admissions staff and supervisors). When interviewing students for places on degree programmes, given the short, one-off nature of such interviews, a DBS check is not required but it is good practice not to have one sole interviewer. Risk assessments should be in place.

13. Halls of Residence Staff. Where a student under the age of 18 is admitted to the University and is to be placed in an Imperial College Hall of Residence, Wardens, Sub-Wardens, Assistant Wardens and any staff at student residences engaged in caring for, supervising or providing advice or guidance to children on a regular basis are likely to be carrying out regulated activity and will therefore be subject to a DBS check for a Child Workforce including the Children’s Barred List check. Where the Halls of Residence Staff do not have their own separate front door to their own accommodation, any person aged 16 or over who lives with them will also need a DBS Check at the same level. For all Halls of Residence staff, including those who do have their own separate front door to their own accommodation, work with students under 18 should not take place within the staff’s accommodation and to do this would require a DBS check at the aforementioned level for anyone aged 16 or over who lives with them. The Director of Student Services will advise the Staff Compliance team of new personnel to ensure that necessary checks are made prior to commencement of employment.

14. Contractors. The Campus Services Department will notify Estates Facilities to any students under the age of 18 who are staying in Halls of Residence. If a visit by maintenance, security or cleaning staff to a room being inhabited by a child under 18 is necessary, then these staff (either in-house or contracted) must either be:

a. accompanied by a member of the Residences team; or

b. DBS checked, where the College is entitled to request a DBS check.

ADDITIONAL MEASURES FOR STUDENTS UNDER THE AGE OF 16

15. If any of the staff are not able to be DBS checked in time (for example, student choices of modules may not be known in time to ensure that relevant staff have been DBS checked) it is acceptable to have different arrangements for students under 16. For example requiring under 16s to be accompanied by a designated adult/ chaperone at all times, with the student’s funding body/ family/ guardians meeting the costs of such arrangements. It is Imperial College Policy not to accommodate students under the age of 16 in Halls of Residence. For details of the additional steps in the admissions process relating to students aged under sixteen on entry, see the Imperial College London - Policy and Procedure for Admitting Students Under 18 Years of Age.

CHILDREN IN THE EARLY YEARS EDUCATION CENTRE

16. All staff working at the Early Years Education Centre are required to be enhanced level DBS and Children Barred List checked before commencing work. If the DBS check has not been processed before the commencement of employment then a risk assessment will be carried out and all contact with children will be supervised until DBS clearance has been received.

17. Visitors to the Early Years Education Centre will be supervised at all times.

18. The Early Years Education Centre has in place its own detailed child safeguarding policies relevant to the activities undertaken and the recruitment of staff.

CHILDREN AND/OR ADULTS AT RISK USING IMPERIAL COLLEGE’S SPORTS FACILITIES

19. Staff working at Imperial College sports facilities who are or will be engaged in teaching, training, instructing, caring for, supervising or providing advice or guidance to children on a regular basis are required to be DBS checked before commencing work. However, a DBS check cannot be requested if the service is provided and designed for adults, so the presence of a child is incidental, for example an exercise class that is run for adults and attended by some students under 18 years of age. Risk assessments should be in place.

20. External organisations engaged in providing sporting opportunities for children and/or adults at risk, the latter must be specifically working with vulnerable adults because of their age, illness or disability, must ensure that they have their own child protection and safeguarding procedures in place, and where appropriate have completed DBS checks on their staff. The University will undertake periodic checks to ensure the appropriate policies and risk assessments are in place.

CHILDREN ENGAGED WITH STUDENT RECRUITMENT AND OUTREACH ACTIVITIES SUCH AS OPEN DAYS, SUMMER SCHOOLS MENTORING AND TUTORING AND OTHER WIDENING PARTICIPATION SCHEMES

21. All staff (both employees and casual workers) and students who are employed or volunteer to undertake a project in Marketing, Recruitment and Admission (MRA) and Outreach, who are or will be engaged in caring for, supervising or providing advice or guidance to children on a regular basis will be required to undergo a DBS check unless they are assisting with a work experience placement. MRA and Outreach offer a DBS checking service for student volunteers and workers engaged with their programmes to use, whereas staff will need to use the service provided by Staff Compliance.

22. Where outreach activities involving children are organised by the Imperial College Union, the Union Managing Director, in co-operation with the Union President, will ensure that those staff and students involved in regulated or regular activity undergo the relevant checks.

23. The Outreach Department has in place a detailed Safeguarding and Child Protection Policy relevant to these activities.

CHILDREN AND/OR ADULTS AT RISK WITH WHOM IMPERIAL COLLEGE STAFF AND STUDENTS COME INTO CONTACT AS A RESULT OF STUDIES INCLUDING PLACEMENTS, RESEARCH AND VOLUNTARY ACTIVITIES AND CHILDREN ON WORK EXPERIENCE

24. As a condition of admission, students applying for subjects or postgraduate research where they will come into contact with children are required to be checked through the DBS. The same will apply where contact with vulnerable adults (For DBS purposes a vulnerable adult is 18+ years old and is elderly, ill or disabled (illness is defined as someone in receipt of Healthcare) is at a level requiring DBS clearance. Medical Students on clinical placements are required to be DBS checked and to comply with requirements of the relevant NHS Trust. The relevant Head of Department/ Division will be responsible for ensuring that the relevant checks are carried out in conjunction with the Registry. Staff who undertake work or research with such groups may need to be DBS checked if they have unsupervised, regular access to children or vulnerable adults. Staff who supervise children under 16 who are on work experience placements within the University will require a DBS check if they will be supervising the child for more than three days in a 30-day period and they will not themselves be supervised by someone in regulated activity. In addition, a risk assessment must be undertaken, and suitable arrangements implemented in light of the results of the risk assessment. DBS checks are not required for staff who supervise children on work experience who are aged 16 or over. Please view guidance on work experience placements at Imperial. Further guidance on safeguarding considerations for research activity is available on Imperial College’s safeguarding webpages.

25. The Imperial College Union will undertake DBS checks where student volunteers are undertaking regulated activity organised by the Imperial College Union, or where it is requested by a host organisation. Where the Imperial College Union works with a partner organisation to provide student volunteers in roles working with children or vulnerable adults (as per the DBS definition), it is the partner organisation’s responsibility to undertake DBS checks. This requirement will be stipulated in the agreement with the partner organisation.

CHILDREN USING FACILITIES THROUGH COMMERCIAL EVENTS

26. Imperial College will ensure, through its procurement process, that all commercial activities involving children and/or adults at risk have appropriate safeguarding policies in place that meet Imperial College’s policy and guidance, including risk assessments of space. All commercial clients will be required to disclose any safeguarding issues or concerns that have emerged in connection with any activity on or linked to University premises.

CHILDREN VISITING IMPERIAL COLLEGE EVENTS OPEN TO THE GENERAL PUBLIC

27. When arranging an event that may involve child visitors, organisers should undertake a risk assessment and ensure that appropriate measures are put in place in line with the Imperial College’s policy and guidance on working or volunteering with children.

GUIDELINES FOR STAFF AND STUDENTS

28. It is recommended that staff and students who have access to children and/or adults at risk, including students under 18, take steps to ensure that they do not put themselves in a position where an allegation can be made against them. Such staff and students must give special consideration to ensuring that they do not become involved in circumstances where an allegation can be raised. Such consideration might involve, but is in no means limited to:

a. Treating children and adults at risk with respect and dignity at all times, reflecting their age, background, culture and special needs;

b. Ensuring that interaction with children occurs in the company of others wherever possible to ensure that an allegation of improper behaviour does not arise;

c. Retaining a professional approach to children which will involve behaviour such as not divulging home telephone numbers or addresses, refraining from any social media interaction, ensuring that there is no physical contact, avoiding inappropriate familiarity, including discussing matters of a sexual nature, maintaining self-control and being sensitive to issues that can be misconstrued; and

d. Seeking guidance from a Safeguarding Officer on their own interactions with children if they have any concerns about their appropriateness or the possibility of them being misconstrued.

All staff should:

Maintain an attitude of ‘it could happen here’ where safeguarding is concerned.
Share information where children may be at risk, even if this relates to concerns outside the University, for example, domestic abuse
Adhere to the principles and procedures contained in safeguarding and child protection policy
Recognise the power balances between children and staff, and different levels of seniority of staff and ensure that power and authority are never misused
Share low-level concerns
Report and challenge abusive adult activities, such as ridicule or bullying
Share concerns about inappropriate adult behaviour with the Lead Safeguarding Officer including behaviour not directly involving children but that indicates an adult may not be suitable to work with children
Be confident and understand the Whistleblowing policy and procedure
Take responsibility for their own continuing professional development
Use appropriate language at all times

Staff should not:

Play inappropriate physical contact games with children or vulnerable adults
Engage in inappropriate verbal banter
Make suggestive remarks or gestures or tell jokes of a sexual nature
Fail to act upon and record any allegations made by a child or vulnerable adult;
Believe that an allegation could not be made against them – it could
Give their personal contact details – such as home or mobile phone number, email or home address – to any child, parent or vulnerable adult, without prior permission from the Head of Department.
Make contact with, or allow contact from children, parents or vulnerable adults, within social networking sites.

29. Any employee or volunteer at the University who comes into contact with children under the age of 18 is considered to be in a position of trust, whether or not they meet the strict legal definition, and any sexual activity between an employee or volunteer and a child with whom the employee or volunteer has come into contact through activities carried out in the course of his or her employment or volunteering will be treated as a very serious disciplinary matter. Anyone who meets the legal definition of “position of trust” under the Sexual Offences Act 2003 and who engages in any sexual activity with a person under 18 is also committing a criminal offence, and such cases will be reported to the Police. Imperial College has a legal duty to report to the DBS any individual whom it believes ought to be placed on the list of individuals barred from working with children.

30. These guidelines for staff and students will always apply for contact with children, including students under the age of 18 years, and adults at risk. The reporting and escalation procedures in this code of practice should also be used where there are wider safeguarding concerns and the Lead Safeguarding Officers will direct to the appropriate procedure based on the individual circumstances.

31. A brief guide for staff and students on how to respond to allegations / suspicions of abuse or harm, both within and outside the University, can be found on Imperial College’s safeguarding webpages.

LINKED POLICIES AND GUIDANCE

32. The following policies and guidance are included for reference in line with Imperial College’s wider duty of care beyond children and adults at risk. Any question about the appropriate policy or procedure to be used may be raised with the Director of Safeguarding. (l.lindsay@imperial.ac.uk).

Approved by Imperial College’s Safeguarding Committee and Provost’s Board March 2018

Updated July 2020, November 2020, February 2022, March 2023 (Provost’s Board changed to University Management Board), March 2024

Policy and Code of Practice