Michaela

Policies

Take a look at Gradvert's policies...


Your privacy is very important to us. Accordingly, we have developed this policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information.

The following outlines our privacy policy:

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected and how long we will retain this information.
  • We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • You have the right to opt out and request for your data to be ‘forgotten’ at any time.
  • We will only retain personal information as long as necessary for the fulfilment of those purposes.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

Our Commitment:

Gradvert is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with the data protection principles and the Data Protection Act (DPA).

https://ico.org.uk/for-organisations/guide-to-data-protection/data-protection-principles/

Changes to data protection legislation shall be monitored and implemented in order to remain compliant with all requirements.

The member(s) of staff responsible for data protection is Gradvert’s Managing Director, Michaela Reaney.

Gradvert is also committed to ensuring that it’ staff are aware of data protection policies, legal requirements and adequate training is provided to them.

The requirements of this policy are mandatory for all staff employed by Gradvert and any third party contracted to provide services within the school.

Notification:

Our data processing activities will be registered with the Information Commissioner’s Office (ICO) as required of a recognised Data Controller. Details are available from the ICO: 

https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/

Changes to the type of data processing activities being undertaken shall be notified to the ICO and details amended in the register.

Breaches of personal or sensitive data shall be notified immediately to the individual(s) concerned and the ICO.


Personal and Sensitive Data:

All data within Gradvert’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.

The definitions of personal and sensitive data shall be as those published by the ICO for guidance:

https://ico.org.uk/for-organisations/guide-to-data-protection/key-definitions/

The principles of the Data Protection Act shall be applied to all data processed:

  1. Processed fairly and lawfully.
  1. Obtained only for lawful purposes and is not further used in any manner incompatible with those original purposes.
  1. Accurate and, where necessary, kept up to date.
  1. Adequate, relevant and not excessive in relation to the purposes for which it is processed.
  1. Not kept for longer than is necessary for those purposes.
  1. Processed in accordance with the rights of data subjects under the DPA.
  1. Protected by appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage.
  1. Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection of the personal information.


Fair Processing / Privacy Notice:

We shall be transparent about the intended processing of data and communicate these intentions via notification to staff, delegates, clients and stakeholders prior to the processing of individual’s data.

Notifications shall be in accordance with ICO guidance and, where relevant, be written in a form understandable by those defined as young adults or adults under the legislation. 

https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/

The intention to share data relating to individuals to an organisation outside of our organisation shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information.

Any proposed change to the processing of individual’s data shall first be notified to them.


Data Security:

In order to assure the protection of all data being processed and inform decisions on processing activities, we shall undertake an assessment of the associated risks of proposed processing and equally the impact on an individual’s privacy in holding data related to them.

Risk and impact assessments shall be conducted in accordance with guidance given by the ICO:

https://ico.org.uk/for-organisations/guide-to-data-protection/principle-7-security/

https://ico.org.uk/for-organisations/guide-to-data-protection/principle-7-security/

https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2014/02/privacy-impact-assessments-code-published/

Security of data shall be achieved through the implementation of proportionate physical and technical measures. Nominated staff shall be responsible for the effectiveness of the controls implemented and reporting of their performance.

The security arrangements of any organisation with which data is shared shall also be considered and these organisations shall provide evidence of the competence in the security of shared data.

Data Access Requests (Subject Access Requests):

All individuals whose data is held by us, has a legal right to request access to such data or information about what is held. We shall respond to such requests within 40 days and they should be made in writing to Michaela Reaney.

A charge may be applied to process the request.

https://ico.org.uk/media/for-organisations/documents/1586/personal_information_online_small_business_checklist.pdf

https://ico.org.uk/media/for-organisations/documents/1131/definition-document-colleges-of-further-education.pdf


Photographs and Video:

Images of staff and learners may be captured at appropriate times and as part of training activities. Consent of use of any images will be obtained in line with our image consent policy.

Unless prior consent from parents/learners staff has been given, we shall not utilise such images for publication or communication to external sources.

It is our policy that external parties (including parents/ carers/ other learners) may not capture images of staff or learners during such activities without prior consent.


Data Disposal: 

Our organisation recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk.

All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner with demonstrable competence in providing secure disposal services.

All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process. 

Disposal of IT assets holding data shall be in compliance with ICO guidance:

https://ico.org.uk/media/for-organisations/documents/1570/it_asset_disposal_for_organisations.pdf

Introduction

Gradvert is committed to ensuring equal opportunities, fairness of

treatment, dignity, the encouragement of diversity and the elimination of all forms of discrimination in the workplace or learning environment for all its’ employees, job applicants and learners.  

The Company aims to create an environment in which all individuals can make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.  

A key objective of this policy is so that The Company can provide a working / learning environment in which all people who work for, or with Gradvert, feel

comfortable and confident that they will be treated with respect and dignity.

  1. Policy Statement

1.1. It is Gradvert’s aim to ensure that no employee, job applicant, or learner receives less favourable facilities or treatment (either directly or indirectly) in recruitment, employment, or training and assessment on grounds of:

  • age
  • disability
  • gender reassignment
  • marriage
  • pregnancy and maternity
  • race
  • religion or belief
  • sex
  • sexual orientation

 (the protected characteristics)

1.2. The Company intends that its’ workforce and learners be truly representative of all sections of society and each employee and learner feels respected and able to give off their best.

1.3. The Company opposes all forms of unlawful and unfair discrimination or

victimisation. To that end the purpose of this policy is to provide equality and

fairness for all in The Company’s employment and training.

1.4. All employees and learners, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. 

1.5. All employees and learners will be helped and encouraged to develop their full potential, and the talents and resources of the workforce will be fully utilised to maximise the efficiency of The Company.

1.6. Employees and learners of Gradvert will not discriminate directly or

indirectly, or harass customers or clients because of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation, in the provision of The Company’s or, in the case of learners their employers’, goods and services.

1.7. This policy and the associated arrangements shall operate in accordance with statutory requirements.  In addition, full account will be taken of any guidance or Codes of Practice issued by the Equality and Human Rights Commission, any Government Departments, and any other statutory bodies.

  1. Gradvert’s Commitment:

2.1. To promote equality in the workplace and learning environment which is good management practice and makes sound business sense and conforms to all employments standards required by law.

2.2. To create an environment in which individual differences and the contributions of all our employees and learners are recognised and valued.

2.3. That every employee is entitled to a working environment that promotes dignity and respect to all, and every learner is entitled to a learning environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.

2.4. Training, development and progression opportunities are available to all

employees.

2.5. All learners have access to training and assessment appropriate to their learning programme.

The Company will review and monitor its’ employment practices and

procedures, and those covering the training it delivers, to ensure fairness.

2.7. Breaches of The Company’s Equality Policy will be regarded as misconduct and could lead to disciplinary action.

2.8. The Policy will be monitored and reviewed annually.

  1. Responsibilities of Management

3.1.  Responsibility for ensuring the effective implementation, operation and

monitoring of the arrangements will rest with the Senior Management Team and Directors.  

3.2. All managers will ensure that they and the employees within their departments operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination.  Each line manager will ensure that:

3.2.1.  All employees within their department are aware of the policy and the arrangements, and the reasons for the policy.

3.2.2. Grievances concerning discrimination are dealt with properly, fairly and as quickly as possible.

3.2.3. Proper records are maintained.

  1. Responsibilities of Employees

4.1.   Responsibility for ensuring that there are no unlawful discrimination rests with all employees and learners, and the attitude of employees and learners are crucial to the successful operation of fair practices.  In particular, all employees and learners should:

4.1.1. Comply with the policy and arrangements.

4.1.2. Not discriminate in their day to day activities or induce others to do so.

4.1.3. Not victimise, harass or intimidate other employees, learners or groups who have, or are perceived to have one or more of the protected characteristics.

4.1.4. Ensure no individual is discriminated against or harassed because of their association with another individual who has a protected characteristic.

4.1.5. Inform their line manager, or in the case of learners any member of

 Gradvert staff, if they become aware of any discriminatory practice.

4.1.6. Equality information is included in induction programmes for employees

and learners. 

4.1.7 Equality issues will be discussed with learners at relevant milestones in their programmes

  1. Related Policies

5.1. All employment policies and arrangements have a bearing on equality of opportunity. 

5.2. The Company policies will be reviewed regularly, and any discriminatory elements removed.

  1. Grievances/ Discipline

6.1. Employees have a right to pursue a complaint concerning discrimination or victimisation via The Company Grievance Procedures, Policy; learners should use the Appeals Procedure which is covered in the Appeals Policy.

6.2. Discrimination and victimisation will be treated as disciplinary offences and they will be dealt with under the company Disciplinary Procedure as detailed in Policy

  1. Monitoring & Review

7.1. The Company deems it appropriate to state its intention not to discriminate and assumes that this will be translated into practice.  Accordingly, it will periodically monitor and measure the effectiveness of the policy and arrangements.

7.2. If monitoring shows that The Company or its’ learners are not representative, or that sections of our workforce or learners are not progressing properly within The Company or their learning programmes, then an action plan will be developed to address these issues.  This will include a review of recruitment and selection procedures, the delivery of leaning programmes, and Company Policies and practices.

Document security classification: Staff

Purpose and Scope

GRADVERT LTD is committed to operating a proactive and reactive approach towards safeguarding the welfare of children, young people and adults who, through the delivery of our services, we have some form of contact with. This is also applicable to staff and volunteers.

We will:

  • Promote positive personal welfare and safety
  • Provide support (including utilising signposting)
  • Respond promptly and effectively to any concerns.

The protection of children, young people and adults is set out in legislation and guidance, such as: Working Together to Safeguard Children 2015; Children Act 1989 & 2004; The Children (Northern Ireland) Order 1995; Children (Scotland) Act 1995; Children and Young People (Scotland) Act 2014; Social Services and Wellbeing (Wales) Act 2014; Human Rights Act 1998; Care Act 2014; Adult Support and Protection (Scotland) Act 2007; Protection of Older People in Wales 2014; Safeguarding Vulnerable Adults: A Shared Responsibility 2010 (Northern Ireland); The Counter-Terrorism and Security Act 2015; The Prevent Duty (England, Wales and Scotland). (The difference of legislation across the four nations in the UK is recognised). 

This policy has been developed to:

  • establish best practice across GRADVERT LTD
  • ensure GRADVERT LTD applies a robust safeguarding framework within legislative and guidance parameters
  • reflect GRADVERT LTD values
  • enable all staff to act appropriately if any concerns are identified relating to the welfare of an individual
  • provide a clear process for reporting and recording concerns.

“Safeguarding is everyone’s business” (Care Act 2014) and all GRADVERT LTD employees and volunteers have a responsibility regarding safeguarding towards children, young people and adults (to include clients, learners, internal and external staff). This policy provides a framework for exercising our duty of care appropriately and effectively, should any concerns be identified that may impair, or be likely to impair, someone’s development or health, quality of life, or if someone is at risk of significant harm (including all forms of abuse).

This policy, and any associated documents, applies to all employees and volunteers of GRADVERT LTD, regardless of role or position.

It is recognised all supply chain partners providing a service for GRADVERT LTD have a requirement to have their own safeguarding policies reflecting legislative requirements and best practice.  All supply chain partners must ensure their employees and sub-contractors follow their policies. 

This policy will be reviewed biannually or following relevant developments within legislation, guidance and lessons from Serious Case Reviews (SCRs). 


Roles and Responsibilities

The Safeguarding Champion retains responsibility for the overall implementation and management of this policy, alongside providing relevant reporting to the Managing director.

The Safeguarding Champion is also the Single Point of Contact (SPOC) with regards to our duties under the Prevent Strategy (2011) and is the Designated Safeguarding Officer (DSO).

They are also the lead for: Mental Capacity and Deprivation of Liberty Safeguards; Child Sexual Exploitation (CSE) and Female Genital Mutilation (FGM).

The Managing Director has accountability for ensuring GRADVERT LTD fulfils its safeguarding responsibilities. All employees and volunteers across all divisions have a responsibility to ensure they adhere to this policy. 

In addition, managers are responsible for promoting and monitoring the application of this policy across their team(s).

Regular reviews of the use and application of this policy, across all divisions and offices, will be undertaken by the Safeguarding Champion. All relevant associated policies, procedures and information will be available in the Safeguarding section on Gradvert’s company website.

The Safeguarding Champion is available for support and guidance regarding the application of this policy. In the absence of the Safeguarding Champion, the Deputy Safeguarding Champion will be available.

Definitions and Language

For the purposes of this policy, the following terms are defined as such:

Child: “every human being below the age of 18 years”

(Article 1, United Nations Convention on the Rights of the Child)

Acknowledgement that Adult Support and Protection (Scotland) Act 2007 states adult “means a person aged 16 or over” (Section 53(1))

Young people: The United Nations uses ‘young people’ to refer to those aged between 15 and 24 years.

Adult: an adult is aged 18 and older. Depending on their circumstance, they may also be an ‘adult at risk’, for which this policy will use the following definition: “an adult who is an older person; or is affected by disability, illness, or physical or mental infirmity; or has an impairment of, or disturbance in, the functioning of the mind or brain; and as a result, may be unable to safeguard their own well-being, property, rights or other interests. In addition, an adult is at risk if: “another person’s conduct is causing (or is likely to cause) the adult to be harmed, or the adult is engaging (or is likely to engage) in conduct which causes (or is likely to cause) self-harm” (Adult Support and Protection (Scotland) Act 2007 s.3(2)) 

Safeguarding: “the action we take to promote the welfare of children and protect them from harm” (Working Together to Safeguard Children 2013, p.7). For the purposes of this policy, ‘safeguarding’ means the action we take to promote the welfare of children, young people and adults and protect them from harm

Welfare: “physical and mental health and happiness” (Cambridge Online Dictionary, 2016)

Concern: anything that may cause worry about another person or contributes to a person feeling uncomfortable or unsure about the safety or welfare of someone else or themselves (including indications of potential radicalisation and expressions of extremist views)

Harm: “ill-treatment or the impairment of health or development” (Children Act 1989 s.31(9 & 10)). For the purposes of this policy, this definition is applied to children, young people and adults. This policy also recognises that harm applicable to children and young people includes “impairment suffered from seeing or hearing the ill-treatment of another” (Children Act 1989 as amended by Children and Adoption Act 2002)

The definition of harm also includes abuse in all its forms and bullying. For the purposes of this policy, the following types of abuse and bullying, as provided by the Social Care Institute for Excellence (SCIE) for adults (2016), and as provided by the National Society for Prevention of Cruelty to Children (NSPCC) for children and young people (2016) are recognised:

Adults

Children and Young People

Neglect or acts of omission

Neglect

Sexual Abuse

Sexual abuse

Physical abuse

Physical abuse

Domestic abuse

Domestic abuse

Psychological / Emotional abuse

Emotional abuse

Financial or material abuse

Online abuse

Modern Slavery

Child sexual exploitation (CSE)

Discriminatory abuse

Female Genital Mutilation (FGM)

Organisational or institutional abuse

Bullying and Cyberbullying

Self - neglect

Child trafficking

Hate crime

Grooming

 

Harmful sexual behaviour


For full definitions of these, refer to Safeguarding Guidance document.

The above table does not provide an exhaustive list of concerns that are relevant to this policy. Other concerns to be noted can include: homelessness; depression; suicidal thoughts and intent; self-harm or injury; eating disorders; use of substances; cyber-bullying and radicalisation. It is recognised that abuse and bullying can occur online for adults as well as for children and young people.

Confidentiality

GRADVERT LTD is not afforded powers of being able to keep private any information relating to a safeguarding concern. Therefore, a key component to any professional relationship between GRADVERT LTD employees and members of the public accessing our services is the sharing of our confidentiality status: i.e. If a concern is identified or raised, that indicates a child, young person or adult is being harmed, or is at risk of being harmed, or requires additional support, that concern will be shared with a manager.

This may also result in a referral to an external agency, such as health services, the police or social services. No concerns relating to a potential safeguarding issue can be kept private.

This policy recognises information sharing is a significant element to effective safeguarding practice: “Early sharing of information is the key to providing an effective response where there are emerging concerns” (Care and Support Statutory Guidance 2014, p. 239, s.14.34). When information relating to a concern is shared, it must be: within the values and principles of care and trust; safety and dignity; on a ‘need to know’ basis and within information sharing guidelines.  (For more details, see Safeguarding guidance document). 

Actions

All concerns relating to the safeguarding of children, young people and adults must be recorded and appropriate actions taken in a timely manner. In the first instance, information relating to the concern will be shared with the safeguarding champion (in required situations, it will be emergency services).  Details on time scales can be found in the Safeguarding guidance documents. All concerns must be reported via the Concern Report Form, available online via the company one drive.  All reports are sent to the besafe@gradvert.com, who in turn go to the Safeguarding Champion and Deputy 

Data Protection

All information relating to concerns will be stored and monitored in line with GRADVERT LTD Data Protection and Document Retention policies. The information must be viewed only by relevant persons and on a ‘need to know’ basis.  

Recruitment

Employees will be recruited and selected according to GRADVERT LTD Recruitment and Selection Policy, reflecting best practice recommendations from guidance such as

The Warner Report (1992), the Bichard Enquiry (2004), and lessons identified in Serious Case Reviews (SCR).

All relevant positions within GRADVERT LTD will be subject to satisfactory checks, including references, employment checks and with the Disclosure and Barring System (DBS) Check (England and Wales), Disclosure Scotland and Access NI (Northern Ireland), where required.

Training and Awareness

  • All GRADVERT LTD employees and volunteers will receive training on safeguarding awareness, through a combination of online and face-to-face training, with ongoing support being provided by the line manager and the Safeguarding Champion
  • Updated alerts will be included in regular communications to staff and supply chain partners
  • Safeguarding awareness will feature in Personal Development Reviews (PDRs)
  • All offices will have safeguarding posters clearly on display for staff and members of the public
  • People accessing our services will be made aware of our safeguarding policy verbally and through written format

Contact Details

Safeguarding Champion/ Designated Safeguarding Officer / Single Point of Contact:

James.neilands@gradvert.com   0191 607 0225

Deputy Contact: niamh.finlay@gradvert.com,  0191 607 0225

Document Management:

Owner: Michaela Reaney

Company: Gradvert

Effective Date: 29.05.18

Context

This procedure accompanies the Gradvert Safeguarding Policy and refers to our duties under the UK Government’s Prevent Duty for England and Wales.

Radicalisation or expressions of extremist views can be a safeguarding concern (“anything that may cause worry about another person or contributes to a person feeling uncomfortable or unsure about the safety or welfare of someone else or themselves (including indications of potential radicalisation and expressions of extremist views)” {Gradvert’s safeguarding policy).

Therefore, awareness of Prevent and this accompanying document is expected by all members of relevant staff and volunteers.

The DSO (James Neilands), 0191 607 0225 will monitor the implementation of this procedure (including overseeing the Prevent Risk Assessment and Action Plan) and is the Single Point of Contact (SPOC) and Designated Safeguarding Officer (DSO) for safeguarding concerns connected to radicalisation and extremism. Overall accountability for safeguarding and our Prevent Duties remains with the Managing Director.

The following documents will be referenced to throughout this document:

https://www.gov.uk/government/publications/prevent-duty-guidance

https://www.gov.uk/government/uplaods/system/uploads/attachment_data/file/425189/Channel_Duty_Guidance_April_2015.

Prevent Strategy

Prevent forms part of the UK’s overall counter-terrorism strategy ‘Contest’. Its aim is to “reduce the threat to the UK from terrorism by stopping people becoming terrorists or supporting terrorism” (violent and non-violent). The three objectives for Prevent are:

  • Respond to the ideological challenge of terrorism and the threat faced from those who promote it.
  • Prevent people from being drawn into terrorism and ensure they are given appropriate advice and support.
  • Work with sectors and institutions where there are risks of radicalisation that need to be addressed.

It also includes extremism: “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 extremism calls for the death of members of our armed forces, whether in this country or abroad” (Prevent Strategy, 2011). Therefore, extremism can also include expressions of racism, homophobia, anti-Semitic views and Islamophobia.

It is acknowledged that there is no ‘one single’ process of radicalisation or profile of an individual likely to become involved in terrorist-related activity. The process of radicalisation is a grooming one: ways of communication and indicators of grooming are the same for other forms of abuse. Methods can be: face-to-face; through befriending; online; information leaflets to initiate interest; manipulation; giving a sense of belonging and creating ‘secrets’.

Indicators can be: a significant change in someone’s physical appearance or clothing; change in behaviour; self-isolation; expressions of extremist views; self-harm. (For further indicators, see Appendix I below. All indicators can also be observed with other forms of abuse or if an individual needs additional support for a personal welfare issue. They are not exclusive to radicalisation).

In addition, there are recognised ‘push’ and ‘pull’ factors that may contribute to an individual becoming radicalised or involved in extremist groups. The presence of one or more of these does not automatically mean an individual is being radicalised. However, they can contribute to an individual becoming vulnerable to potential radicalisation and extremism. Examples of known factors include:

  • Isolation and identity crisis
  • Personal crisis and circumstances
  • A sense of grievance, thinking the ‘world owes them a favour’
  • Discriminatory thought processes against groups in society and abroad
  • Distrust of UK Foreign Policy
  • Lack of knowledge about the group or movement
  • Ideology and politics
  • Need for protection and seeking excitement
  • Looking for a sense of belonging
  • Seeking status and identity

Therefore, all employees and volunteers must be alert to any of these occurring with clients and as well as within staff cohorts. This is relevant across all divisions of Gradvert and with all forms of contact with individuals including face-to-face, telephone or written media. Expressions of extremist views must be dealt with appropriately: they must be challenged (not confronted).

If an employee or volunteer believes themselves to be at risk of harm or their safety is compromised, they must prioritise their own physical wellbeing and make contact with their Line Manager (or Duty Manager) immediately.

Reporting Process

If a concern is identified regarding the welfare of any individual, and with indications of potential radicalisation or expressions of extremist views, then the following reporting process must be followed:

  1. If the individual, employee or volunteer, or local community are thought to be in immediate danger (e.g. a bomb threat has been made) then contact the emergency police on 999 and follow Gradvert’s Business Continuity Plan process.
  1. If there is no perceived immediate threat of danger, the employee or volunteer contacts their Line Manager (or other duty manager) as soon as is reasonably possible to discuss their concerns and any potential level of risk under the Prevent Duty. If unsure, the Line Manager must discuss these concerns with the Single Point of Contact (SPOC) / Designated Safeguarding Officer (DSO) James Neilands, 0191 6070225 . This discussion will assess if a referral to the local Prevent Coordinator and Channel Panel may be required. The outcome of this assessment will influence which action follows. If no, go to point 3. If yes, go to point 6:
  1. If the referral threshold to a Channel Panel is not met, the Line Manager must consider an alternative, appropriate intervention for the individual (i.e. diversity workshop) and confirm this with the SPOC / DSO
  1. Employee and Line Manager complete a Concern Report Form within one working day and send to besafe@gradert.com address and record information on the individual’s file.
  1. If Gradvert have ongoing contact with the individual, they must continue to be monitored for further indications of concern.
  1. If the referral threshold to a Channel Panel is met (see Vulnerability Assessment for Referral to Channel document), the SPOC / DSO will contact the Regional Prevent Coordinator (UK Government). A meeting will be arranged with the individual to discuss a referral to Channel as this is a voluntarily process. Attendees of the meeting will likely be the individual, the employee and Line Manager with possible attendance from the Prevent Coordinator and / or SPOC / DSO
  1. Employee and Line Manager complete a Concern Report Form within one working day and send to safeguarding@gradvert.co.uk
  1. If consent is gained from the individual, the employee and Line Manager complete the Vulnerability Assessment for Referral to Channel document. This document must be password protected and sent to the SPOC / DSO besafe@gradvert.co.uk. The SPOC / DSO will review the document and make arrangements with the local Channel Panel for submission.

Information-Sharing

Gradvert recognise the importance of appropriate and proportionate Information-Sharing. The Channel Duty Guidance acknowledges information may be shared with partners (see above for referral to a Channel Panel), typically with consent of the individual. However, it is also “dependent on the circumstances of the case but may relate to issues such as the health of the individual, law enforcement or protection of the public” (Channel Duty Guidance, p. 11, pt. 46). The SPOC / DSO will liaise with our Compliance Team and the local Prevent Coordinator for guidance, if necessary, on this issue and on a case-by-case basis.

Individuals who are suspected of being involved in any form of illegal terrorist-related activity must be referred to the police after a discussion with SPOC / DSO, who will involve the Head of Compliance and Audit Staff Training:

  • All relevant staff working in the Gradvert EPA division must complete the online Prevent training module for Practitioners provided by the Education and Training Foundation:

https://www.foundationonline.org.uk/course/index.php?categoryid=14

  • For staff in all divisions, it is highly recommended they access and complete the relevant training module for their role. “Safeguarding is everyone’s business” (Care Act 2014) and awareness of Prevent-related concerns forms an important element of effective and best safeguarding practice.
  • Staff can also attend a Workshop to Raise Awareness of Prevent (WRAP), delivered by a Home Office authorised facilitator Further Duties Under Prevent and Best Practice.
  • The promotion of British Values in teaching curriculum and interventions with clients and learners.
  • Promotion of the nine protected characteristics in the Equality Act 2010 (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion and belief; sex; sexual orientation).
  • Posters promoting the above can be displayed in training environments and offices and shared with clients and learners. These can be found on the Gradvert website.

The following associated documents must be read in conjunction with this procedure:

Gradvert Safeguarding Policy

IT Acceptable Use for Clients and Learners Policy

External Speakers Policy

External Speakers Risk Assessment Checklist

Gradvert Business Continuity Plan

Appendix I

Further Possible Indicators (Channel Duty Guidance)

  • Spending increasing time in the company of other suspected extremists
  • Changing their style of dress or personal appearance to accord with the group
  • Their day-to-day behaviour becoming increasingly centred around an extremist ideology, group or cause
  • Loss of interest in other friends and activities not associated with the extremist ideology, group or cause
  • Possession of material or symbols associated with an extremist cause (e.g. the swastika for far-right groups)
  • Attempts to recruit others to the group/cause/ideology
  • Communications with others that suggest identification with a group/cause/ideology
  • Clearly identifying another group as threatening what they stand for and blaming that group for all social or political ills
  • Using insulting or derogatory names or labels for another group
  • Speaking about the imminence of harm from the other group and the importance of action now
  • Expressing attitudes that justify offending on behalf of the group, cause or ideology
  • Condoning or supporting violence or harm towards others
  • Plotting or conspiring with others.
  • Having a history of violence
  • Being criminally versatile and using criminal networks to support extremist goals
  • Having occupational skills that can enable acts of terrorism (such as civil engineering, pharmacology or construction)
  • Having technical expertise that can be deployed (e.g. IT skills, knowledge of chemicals, military training or survival skills)