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

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.


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: 

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 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. 

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:

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.



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:



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


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.



The purpose of this policy is to ensure the safety and wellbeing of our staff, customers and the learners we work with. Gradvert Ltd has a statutory, moral and ethical responsibility to

safeguard the welfare of all of our learners. Our workplace is a safe environment where all individuals are respected and valued.


The aim of this policy is to ensure all learners are protected and receive the support, assistance, protection and respect they are entitled to and deserve. Gradvert Ltd aims to create a culture where the welfare of learners is paramount and that all staff are trained and confident in addressing any concerns.


This policy covers all employees, consultants, contractors, volunteers, interns, work experience, learners, casual workers and agency workers and our learning partners. The word ‘staff’ is used for ease of description.


This policy does not form part of any employee's contract of employment and we may amend it at any time. 


Personnel Responsibility for this policy


The Company Directors have overall responsibility for the effective operation of this policy and for ensuring compliance with any relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring its maintenance and review has been delegated to the Quality and Compliance Manager.


All managers have a specific responsibility to operate within the boundaries of this policy, to ensure that all staff understand the standards of behaviour expected of them and to take action when behaviour falls below its requirements.




  • The term ‘child’ means a person under 18 years of age.
  • ‘Adult at risk’ of abuse or neglect means any adult (a person aged 18 or over) who has needs for care and support (whether the local authority is meeting any of those needs or not) and is experiencing, or at risk of, abuse or neglect; and as a result of care and support needs is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.




Safeguarding Vulnerable Groups Act 2006

Disciplinary Procedure

Whistleblowing Policy

Recruitment Policy

Complaints Policy

Prevent Policy

Health and Safety Policy

Equality and Diversity Policy

Protection of Freedom Bill

Children’s Act 1998 and 2004

Care Act 2014


Core Principles


Gradvert Ltd is fully committed to safeguarding the welfare of all children and adults at risk in our care by taking all reasonable steps to protect them from neglect, physical, sexual or emotional harm. Gradvert Ltd’s Safeguarding Policy and Procedure is based on the principles contained within UK and international legislation and government guidance.  All staff will, at all times, show respect and understanding for the rights, safety and welfare of the children and adults at risk in our care and conduct themselves in a way that reflect the principles of our organisation.


We will do this by:

  • Ensuring that all new staff, including volunteers and interns, are made aware of Gradvert Ltd’s arrangements for safeguarding children, adults at risk and their responsibilities.
  • Providing mandatory safeguarding training for staff and volunteers which will be reviewed on an annual basis and updated in line with Local Multi-Agency Safeguarding Procedures for Children and Adults at Risk. The Designated Safeguarding Lead (DSL) and Deputy Designated Safeguarding Lead (DDSL) will receive training updated every two years, including training in interagency procedures.
  • Recognising the roles and responsibilities of the statutory agencies in safeguarding learners and the responsibility and expertise of the relevant agencies in determining whether individuals have or may have been abused or otherwise harmed.
  • Carefully assessing all risks which children and adults at risk encounter and taking all necessary steps to minimise and manage them.
  • It is the responsibility of child protection and adult safeguarding professionals to determine whether abuse has taken place, but it is everyone’s responsibility to report concerns. All staff must follow the procedures in place for reporting concerns or disclosures (See Appendix 3 & 5).
  • Informing parents, children, adults at risk and any relevant parties on how to voice concerns or complaints about anything that they may not be happy with.
  • Giving parents, children, adults at risk and staff information about what we do and what can be expected from us.
  • Responding to allegations appropriately with full investigation and, if appropriate, implement Gradvert Ltd’s disciplinary and appeals procedures.
  • Illustrating a clear commitment to prevention of abuse through rigorous selection (Disclosure and Barring Service disclosure checks) recruitment and training and the promotion of safer working practice which supports transparency and prompt reporting of suspicions or allegations.
  • Monitoring and reviewing systems to ensure compliance with Child Protection Adult Safeguarding Legislation, Statutory Guidance and procedures.


Gradvert Ltd is committed to ensuring that the organisation:

  • Provides activities and events that are planned, taking into consideration the safety and well-being of children and adults at risk, and organised in a way which minimises the possibility of them being harmed.
  • Practises safe recruitment in checking the suitability of staff (including agency staff), volunteers and contractors to work with or in an environment where young people and vulnerable adults are present.
  • Notifies the DBS of any suspicions regarding staff or prospective members of staff.
  • Identifies children and adults at risk who are suffering, or likely to suffer, significant harm. In addition, ensuring that the safety of children and adults at risk is always considered where domestic abuse, mental health or drug and alcohol abuse are known to be a factor.
  • Takes appropriate action to see that such children and adults at risk are kept safe at all times.
  • Takes appropriate action to ensure that such children and adults at risk have access to all appropriate, available support in order to improve life chances and opportunities to learn and achieve.
  • Ensures staff are trained appropriately in recognising signs of child/adult abuse or neglect and the safeguarding procedures they need to follow including the signs and symptoms that may suggest a child or adult at risk is being drawn into terrorism or violent extremism (See Appendix 1.6 Prevent Duty)
  • Ensure staff are trained in procedures to protect themselves and limit the opportunities for misconduct allegations.
  • Complies with the DBS reporting requirement where it has concerns that a member of staff has caused harm or poses a future risk of harm to vulnerable groups, including children.


  • Conducts a risk assessment if disclosures are identified to assess the risk to learners prior to being recruited with Gradvert Ltd.


In the pursuit of these aims, Gradvert Ltd will annually review policies and procedures with the aim of:

  • Raising the awareness of issues relating to the welfare of children and adults at risk and the promotion of safe environments in which they can learn.
  • Aiding the identification of children and adults at risk of significant harm, from others or themselves, and providing procedures for reporting concerns.
  • Establishing procedures for reporting and dealing with allegations of abuse against members of staff.
  • Ensuring the effective and safe recruitment of staff. Gradvert Ltd will assess all posts to be filled and ensure recruitment checks, including DBS checks are undertaken in line with the Gradvert Ltd’s Safer Recruitment Policy. Recruitment, selection and pre-employment vetting are carried out in accordance with Keeping Children Safe in Education 2018.


In developing these policies and procedures, Gradvert Ltd will consult with, and take account of, guidance issued by the Department for Education, the Department for Health & Social Care, the DBS and any other relevant bodies and groups.


Appendix 1 details the definitions of child abuse that staff will be trained in recognising.

Appendix 2 details the definitions of adult abuse that staff will be trained in recognising.


Designated staff with responsibility for Safeguarding Children and Adults at risk.


The Designated Safeguarding Lead (DSL) is the Quality and Compliance Manager, Andrea Satterthwaite, who can be contacted on 0191 6070225. 

The Deputy Designated Safeguarding Lead (DDSL) is the Learning Solutions Manager, Niamh Finlay who can be contacted on 0191 6070225. 


Both the DSL and DDSL are members of Gradvert Ltd’s Leadership Team. The DSL has a key duty to take lead responsibility for raising awareness within the staff of issues relating to the welfare of children and adults at risk, and the promotion of a safe and positive learning environment.


The DSL and the DDSL receive training in safeguarding children and adults at risk, issues and inter-agency working, and receive refresher training every two years. 


 The DSL is responsible for:

  • Overseeing the referral of cases of suspected abuse or allegations to the relevant investigating agencies.
  • Ensuring that, when appropriate, Early Help Procedures for children are implemented e.g. Common Assessment Framework (CAF) procedures and overseeing the CAF process.
  • Providing advice and support to staff on issues relating to safeguarding.
  • Maintaining a proper record of any safeguarding referral, complaint or concern (even where that concern does not lead to a referral to an external agency).
  • Ensuring there is effective liaison with the Local Authority and the Newcastle upon Tyne Safeguarding Children Board and Safeguarding Adults Board and other appropriate agencies.
  • Ensuring that all staff receive training in safeguarding issues and are aware of Gradvert Ltd’s safeguarding procedures.
  • Complying with the duties under the Care Act 2014, the Children Act 1989 & 2004, Working Together to Safeguard Children 2018 and Keeping Children Safe in Education 2018.


Good practise guidelines


To ensure the objectives of this policy are met, a certain level of conduct is required from all our staff:


  • Treat all staff, learners, business partners and learners with respect.
  • Recognise that challenging behaviour or changes in behaviour may be an indicator of abuse.
  • Avoid befriending learners on a personal level or sharing any personal information i.e. personal telephone numbers, email addresses, social media.
  • Ensure dignified and positive conduct with learners at all times even when faced with challenging behaviour.
  • Avoid all physical contact with learners and unnecessary time alone.
  • Respect professional boundaries with other staff when learners are present.
  • Careful use of reasonable force and only in times of physical danger. All instances of force used must be reported to the DSL and recorded. 
  • Deal with any issues of learner infatuation and misconduct in a professional way and report it to the HR Manager at the first opportunity.
  • Refer all concerns about a learner’s safety and welfare to the DSL, or, if necessary, directly to police or children’s/adult’s social care.
  • Limit the use of photography of other staff and learners and with their consent. Photos must not be taken of learners unless the purpose has been previously identified and agreed with the DSL.
  • Avoid all inappropriate behaviour towards learners under the Sexual Offences Act (2003). It is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual.



Procedure for reporting concerns


Staff working with children and adults at risk will be issued with guidance and training on safeguarding procedures as part of Gradvert Ltd’s induction. The reporting process is as follows:


  • If the situation reported is life threatening or an individual is in a harmful situation, then contact the police on 999 immediately.
  • Immediate notification to the Facilitator or Line Manager who will notify the organisation’s DSL for all safeguarding matters (this is followed by notification to their Team Leader who will report the incident to the National Programme Manager).
  • DSL will advise and feedback to the member of staff reporting the concern.
  • In the absence of any of the Designated Contacts, if at any point there is a risk of immediate harm to a child or adults at risk, staff are responsible for reporting the concern directly to Social Care and/or the Police immediately.
  • The DSL will be responsible for ensuring there is effective liaison with schools to ensure that appropriate arrangements are made for the learners.
  • This policy should be read in conjunction with Gradvert Ltd’s Whistleblowing Policy, Prevent Policy, Equality and Diversity Policy and Health and Safety Policy.
  • All allegations must be reported whether disclosures are on or off the record. Nothing must be kept a secret.

Reporting and dealing with allegations of abuse against members of staff

In rare instances, professionals involved in the training of children and adults at risk have been found responsible for abuse.  Due to their frequent contact with children and adults at risk, staff may have allegations of abuse made against them.  Gradvert Ltd recognises that an allegation of abuse made against a member of staff may be made for a variety of reasons. However, Gradvert Ltd will respond to all allegations on the basis that they are true until proved otherwise. It is a matter for professional investigators and not Gradvert Ltd to determine the truth of an allegation.  It is imperative that those dealing with an allegation maintain an open mind and that investigations are thorough and not subject to delay.


Gradvert Ltd recognises that the Children Act 1989 and 2004 states that the welfare of the child is the paramount concern.  It is also recognised that hasty or ill-informed decisions regarding a member of staff can irreparably damage an individual’s reputation, confidence and career.  Therefore, those dealing with such allegations within Gradvert Ltd will do so with sensitivity and will act in a careful, measured way.


A member of staff who receives an allegation about another member of staff from a child or adult at risk should follow the guidelines in Appendix 3 for dealing with disclosure.

The allegation should be reported immediately to the DSL, unless this manager is the person against whom the allegation is made, in which case the report should be made to the Learning Solutions Manager (Deputy DSL).


 The Designated Safeguarding Lead (DSL) or Managing Director (Deputy DSL) must:


  • Conduct a speedy initial investigation, gathering relevant facts from both parties.
  • Make an initial assessment of the need to report the allegations to the school, employer or appropriate external agencies.


Where the allegation is considered to be either a potential criminal act or indicates that the child or adult at risk has experienced, is experiencing or is likely to experience significant harm, the matter should be reported immediately to the appropriate agencies. 

The appropriate external agency (Police/Social Services) will then be expected to conduct an investigation. 


The DSL or Deputy DSL in consultation with Local Authority Designated Officer (LADO) at Newcastle upon Tyne’s Safeguarding Children Board or Safeguarding Adults Board, will also assess the case for suspension of the member of staff.


Should this action seem advisable, the Lead (DSL) or Deputy DSL will decide whether to recommend suspension under the terms of the Disciplinary Policy. 


Suspension may be recommended in the following cases:


  • where a child or ‘adult at risk’ is at risk;
  • to alleviate stress on the member of staff concerned during investigation;
  • where necessary, for the good and efficient conduct of the investigation.


In all cases involving an investigation by an external agency, even when the Gradvert Ltd’s Disciplinary Policy has been invoked, Gradvert Ltd’s internal investigation procedures will be held in abeyance, pending advice from the investigating agency that Gradvert Ltd procedures will not compromise the external investigation.


Where the allegation is NOT considered to warrant an immediate report to the Newcastle upon Tyne’s Safeguarding Children Board, Safeguarding Adults Board or appropriate agencies, an internal investigation under the Gradvert Ltd’s Complaints Policy should be undertaken.  Several outcomes from this investigation are possible:


  1. The investigation concludes that although it is neither potentially a crime nor a cause of significant harm to the child or adult at risk, the allegation represents inappropriate behaviour or poor practice by the member of staff. The matter should then be addressed in accordance with Gradvert Ltd’s Disciplinary Policy.
  2. The investigation concludes that the allegation cannot be substantiated on the balance of probabilities and no malpractice can be apportioned to the member of staff. No formal disciplinary action should be taken. However, in some circumstances, it may be considered appropriate to hold a discussion with the member of staff to agree expectations of future conduct, offer advice and support for the member of staff and/or training.
  3. The investigation concludes that the allegation can be shown to be false. In these cases, when the allegation has been made by a child or young person, the designated senior manager will liaise with the employer or relevant organisation or Student Discipline Policy may be invoked where appropriate. 


In cases of false allegations, the DSL should also take the following actions:

  • Inform the member of staff against whom the allegation is made, orally and in writing, that no further disciplinary or safeguarding action will be taken. Consideration may be given to offering counselling/support to the member of staff.
  • Inform the parents/carers of the alleged victim of the outcome of the investigation.
  • Where the allegation was made by a child or adult at risk other than the alleged victim, consideration should be given to informing the parents/carers of that young person/ adult at risk.
  • Prepare a report outlining the allegation and giving reasons for the conclusion that it had no foundation and confirming that the above action had been taken. A record of the allegation must be kept and, since false allegations may be indicative of problems of abuse elsewhere, consideration should be given to a referral to other agencies who may act upon the information.
  • All staff will be issued with a guide for Safer Working Practices.

Monitoring effectiveness

Where an allegation has been made against a member of staff, the DSL and other colleagues as appropriate, should, at the conclusion of the investigation and any disciplinary procedures, consider whether there are any matters arising from it that could lead to the improvement of Gradvert Ltd’s procedures.  Consideration should also be given to the training needs of staff.

Equality Impact Assessment

This policy has been assessed for its impact on equal opportunities and has been informed by the aim to eliminate all forms of discrimination in all strands of the equal opportunities legislation.

Review of policy

The above policy will be reviewed annually or as required subject to legislative changes.







Appendix 1

Definitions of Child Abuse – Working Together to Safeguard Children – 2018 (HM Gov)

Safeguarding and promoting the welfare of children is defined in this Statutory Guidance as:

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


Child abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children.


Physical Abuse

A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.



The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

  • provide adequate food, clothing and shelter (including exclusion from home or
  • abandonment);
  • protect a child from physical and emotional harm or danger;
  • ensure adequate supervision (including the use of inadequate care-givers); or
  • ensure access to appropriate medical care or treatment.
  • It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Sexual Abuse and Child Sexual Exploitation (CSE)

Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.


Child Sexual Exploitation (CSE)

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:

  1. in exchange for something the victim needs or wants, and/or
  2. 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.



Emotional Abuse

The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.


Bullying and Harassment

There is no legal definition of bullying. However, the Government’s Bullying at School website says it is usually defined as behaviour that is repeated:


  • Intended to hurt someone either physically or emotionally;
  • often aimed at certain groups, e.g. because of race, religion, gender or sexual orientation.

It takes many forms and can include:

  • physical assault;
  • teasing;
  • making threats;
  • name calling;
  • cyberbullying is bullying via mobile phone or online (e.g. email, social networks and instant messenger).



Bullying and/or harassment expressed verbally or through electronic media (SMS, social networking, texts, etc.) can be regarded as a form of abuse in its own right, or may feature in any of the main forms of abuse outlined above.  Peer on Peer abuse will also be considered within bullying and any cyber bullying, sexting, hate crimes should be reported in the correct manner. 


Children with sexually harmful behaviour


A child who demonstrate harmful sexual behaviour may be victims of abuse themselves and the child protection procedures will be followed for both victim and perpetrator.  Staff who become concerned about a learner’s sexual behaviour should speak to the DSL in line with this Policy.


Peer on Peer Abuse

Keeping Children Safe in Education 2018 states in Para. 48:

All staff should be aware that safeguarding issues can manifest themselves via peers on peer abuse. This is most likely to include but is not limited to:

  • Bullying (including cyber bullying);
  • Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm;
  • Sexual violence and sexual harassment;
  • Sexting (also known as youth produced sexual imagery); and
  • Initiation/hazing type violence and rituals.

Peer on peer abuse is abuse and will never be tolerated or passed off as ‘banter’, ‘just having a laugh’ or ‘part of growing up’.  All allegations of peer on peer abuse should be recorded as a child welfare concern with the DSL/DDSL liaising with the school. The matter will be dealt with in line with the school behaviour policy and anti-bullying policy in addition to Gradvert’s Code of Conduct.



Youth Produced Sexual Imagery/Sexting

Youth produced sexual imagery/sexting is when someone shares sexual, naked or semi naked images or videos of themselves or others. It includes the sending of sexually explicit images, or text messages. The images or messages can be sent by mobiles, tablets, smart phones or laptops or any device that enables messages and images to be shared or sent.


Sexting and the Law:

  • A young person is breaking the law if they;
  • Take an explicit photo or video of themselves or a friend;
  • Share an explicit image or video of a child, even if is shared between children of the same age;
  • Possess, download or explore an explicit image or video of a child, even if the child gave their permission for it to be created.


As of January 2016, if a young person is found creating or sharing images, the police can choose to record that a crime has been committed but that taking formal action is not in the public interest.

All incidents involving youth produced sexual imagery should be responded to in line with the safeguarding procedure.

Honour Based Violence (HBV) eg Female Genital Mutilation/Forced Marriage

1.1.1          Female Genital Mutilation (FGM)

This practice is illegal and a form of child abuse.  It involves a procedure to remove all or some of the female genitalia or any other injury to these organs. Staff who are aware of this are under a duty to report it to the DSL and police. 


1.1.2         Forced Marriage

It is illegal and a form of child abuse for an individual to be forced into marriage against their will.  Staff with knowledge or suspicions that forced marriage has occurred or is causing concern for a learner are under a duty to disclose it to the DSL.




Prevent Duty 2015

From 1st July 2015 Gradvert Ltd’s staff are under a duty to have due regards to prevent children and adults at risk from being drawn into terrorism. It is essential that staff are able to identify learners who may be vulnerable to radicalisation and know what to do when they are identified. Gradvert staff should follow the normal safeguarding procedures and report such concerns to their local Police Force Single Point of Contact’ (SPOC).



Being aware of indicators that may indicate a child or young person is being drawn into terrorism/violent extremism is part of our wider safeguarding duty. We need to intervene where possible to prevent learners being radicalised. 

The signs can be as follows;

  • Spending increasing time in the company of other suspected extremists.
  • Changing their style of dress or personal appearance to accord with the group.
  • 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).

Transition (Care Leavers)

Where someone is over 18 but still receiving children’s services and a safeguarding concern is raised, this should be dealt with as a matter of course through adult safeguarding procedures. Where appropriate, the DSL/DDSL will involve the Local Authority’s children’s safeguarding colleagues as well as any relevant partners (e.g. police or NHS) or other persons relevant to the case. This also applies where someone is moving to a different Local Authority area after receiving a transition assessment but before moving to adult social care.

Appendix 2

Definitions of Adult Abuse – Care and Support Statutory Guidance issued under the Care Act 2014 https://www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance

Adult Abuse and Neglect

This section considers the different types and patterns of adult abuse and neglect and the different circumstances in which they may take place. This is not intended to be an exhaustive list but an illustrative guide as to the sort of behaviour which could give rise to a safeguarding concern. 


Physical abuse

including assault, hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.


Domestic violence

including psychological, physical, sexual, financial, emotional abuse; so, called ‘honour’ based violence.

Sexual abuse

including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.

Financial or material abuse

including theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.

Psychological abuse

including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment,  verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.

Modern slavery

encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to   coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

Organisational abuse

including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home. This may range from one off incidents to on-going ill-treatment. It can be through neglect or poor professional practice as a result of the structures, policies, processes and practices within an organisation.

Discriminatory abuse

including forms of harassment, slurs or similar treatment; because of race, gender and gender identity, age, disability, sexual orientation or religion.

Neglect and acts of omission

including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.


this covers a wide range of behaviour; such as neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.

Abuse by another adult with care and support needs

Where the potential source of risk is also an adult with care and support needs, the safety of the person who may have been abused is paramount. Organisations may also have responsibilities towards this person, and certainly will have if they are both in a care setting or have contact because they attend the same place (e.g. a day centre). In this situation it is important that the needs of the adult who is the alleged victim are addressed separately from the needs of the potential source of risk.

It may be necessary to reassess the adult who is the potential source of risk. This may involve a meeting where the following could be addressed: the extent to which this person is able to understand his or her actions; the extent to which the abuse or neglect reflects the needs of this person not being met (e.g. risk assessment recommendations not being met); the likelihood that this person will further abuse the adult or others.

The principles and responsibilities of reporting a crime apply regardless of whether this person is deemed to be an adult with care and support needs



Guidelines for Dealing with Disclosure

If a child or adult at risk tells a member of staff about possible abuse, the member of staff should:

  • Listen carefully and stay calm, never promise confidentiality.
  • Not interview the alleged victim, but question normally and without pressure, in order to be sure that the member of staff understands what the alleged victim is telling them.
  • Not put words into the alleged victim’s mouth.
  • Reassure the alleged victim that, by telling the member of staff, they have done the right thing.
  • Inform the alleged victim that the information must be passed on, but that only those that need to know about it will be told. Inform the alleged victim whom the matter will be reported to.
  • Record the main points carefully.
  • Make a detailed record of the date, time, place, what the alleged victim said, did and the questions asked by the member of staff etc.


Staff should not investigate concerns or allegations themselves but should report them immediately to the Designated Safeguarding Manager.  For 2018-19 this is:

Andrea Satterthwaite – Quality and Compliance Manager (see flowchart Page 16).


In her absence, the report must be made to a member of the team of designated managers listed below.  The group comprises:

  • Niamh Finlay, Learning Solutions Manager (Deputy Safeguarding Manager)


Contact details for Gradvert’s designated safeguarding managers and key external agencies will also be included in the Business Continuity Plan.



Definitions of Children and adults at risk


1.1.1     Definition of Child – Working Together to Safeguarding Children – HM Gov 2018

The policy and procedures apply to all children up to the age of 18 years. Within the document the terms “children” or “child” refer to all children and young people up to the age of 18 years.


The fact that a child has become sixteen years of age, is living independently or is in further education, is in the armed forces, in hospital, or in prison or a young offender’s institution, does not change their status or their entitlement to services or their protection under the Children Act 1989.

1.1.2          Definition of an Adult at risk of abuse or neglect – Care Act 2014

When a young person reaches the age of 18 the responsibility for their well-being may transfer to adult service providers. Although they cease to be subject of the Safeguarding Children Procedures, some adults may continue to be at risk of abuse or neglect.

The safeguarding duties apply to an adult who:

  • has needs for care and support (whether or not the Local Authority is meeting any of those needs) and;
  • is experiencing, or at risk of, abuse or neglect; and
  • as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.


Since the publication of the Care Act 2014, the range of people considered to be vulnerable has been widened to include victims of trafficking and modern slavery, adults encountering domestic abuse, substance misusers, asylum seekers and those who self-neglect.





Safeguarding Legislation and Guidance


1.1.1          Education Act 2002

Section 157 and 175 cover arrangements for safeguarding and promoting the welfare of children and learners. 

1.1.2         Care Act 2014 (statutory guidance)

The core purpose of adult care and support is to help people to achieve the outcomes that matter to them in their life. Throughout this guidance document, the different chapters set out how a local authority should go about performing its care and support responsibilities. Chapter 14 ‘Safeguarding’ provides guidance on sections 42 to 46 of the Act 2014.



1.1.3         Counter Terrorism and Security Act 2015

Section 26 Applies to schools and other providers; to prevent children and learners being drawn into terrorism. 

1.1.4        Working Together to Safeguarding Children (2018)

 Covers the requirements of Local Safeguarding Partnership Arrangements to monitor the effectiveness of safeguarding in schools and details how learning establishments should safeguard child welfare.


1.1.5         Keeping Children Safe in Education (2016)

 is issued under Section 175 of the Education Act 2002, the Education (Independent School Standards) (England) Regulations 2014 and the Education (Non-Maintained Special Schools) (England) Regulations 2011. This covers Guidelines for schools and collages for safeguarding.   https://www.gov.uk/government/publications/keeping-children-safe-in-education--2

1.1.6         Prevent Duty Guidance – England and Wales

These Guidelines cover section 29 Counter Terrorism and Security Act 2015, to prevent terrorism. https://www.gov.uk/government/publications/prevent-duty-guidance


1.1.7         Teaching Standards

The Teacher Standards 2012 state that teachers, as part of their professional duty, should safeguard children’s wellbeing and maintain public trust for their profession.  

1.1.8         Children and Social Care Act 2017

This act includes a wide range of measures, to give greater clarity to the role of Councils as “corporate parents” of children and young people in care, and care leavers, as well as to what Councils and other agencies should do in safeguarding cases. https://www.legislation.gov.uk/ukpga/2017/16/contents

1.1.9         Child Sexual Exploitation Guidance – Gov UK 2017

It should be read alongside Working Together to Safeguard Children (most recent updates available on gov.uk) which continues to provide statutory guidance covering the legislative requirements on services to safeguard and promote the welfare of children, including in relation to child sexual exploitation.


















Gradvert Ltd takes all reasonable steps to promote and safeguard the welfare of all individuals engaged in any activity.  Robust safeguarding arrangements are in place at Gradvert Ltd and these are regularly reviewed to keep all learners safe.  Gradvert Ltd is committed to the promotion of an inclusive learning community which does not allow any individual or group of individuals to be marginalised, stigmatised or excluded.


We have a responsibility to promote values of openness and respect and to facilitate free debate which is characteristic of being a British citizen.


In accordance with our standard practice the Gradvert Ltd Policy will be updated annually in line with emerging government information, advice and guidance or before that should the necessity arise. 


Government Policy


Prevent is the key part of the Contest Strategy which aims to stop people from becoming terrorists or supporting terrorism.  Early intervention is a the heart of Prevent in diverting people away from being drawn into terrorist activity as Prevent happens before any criminal activity takes place.  It is about recognising, supporting and protecting individuals who might be susceptible to radicalisation.


The 2011 Prevent Strategy objectives are as follows:-


  • Respond to the ideological challenge of terrorism and the threat we face from those that promote it
  • Prevent people from being drawn into terrorism and ensure that they are given appropriate support
  • Work with sectors and institutions where there are risks of radicalisation that we need to address


Section 21 of the Counter Terrorism 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”.  The government’s Prevent Strategy was published in 2011 and forms part of an overall Counter Terrorism Strategy known as CONTEST.  The Contest Strategy has four elements which are detailed below:


  • Pursue
  • Protect
  • Prepare
  • Prevent



The government’s Prevent Strategy was explicitly changed in 2011 to deal with all forms of terrorism and target not only violent extremism but also non-violent extremism which can create an atmosphere conducive to terrorism and can popularise the views which terrorists exploit.


The United Kingdom currently faces a range of terrorist threats.  All terrorist groups who pose a threat to the UK seek to radicalise and recruit people to their cause.  A system of threat levels has been created which represents the likelihood of an attack in the near future.  The current government threat level from international terrorism in the UK is ‘severe’ which means that a terrorist attack is a strong possibility.





The following definitions have been adopted for use within this document:


Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, 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.


In the Common Inspection Framework September 2015, inspectors make their judgement on safeguarding under the ‘Effectiveness of Leadership and Management’ based on whether “learners are suitably protected from the risks associated with radicalisation and extremism”.


Key Documents


This policy should be read in conjunction with the following documents and guidance:


Gradvert Ltd Policies and Procedures:


  • Safeguarding Children & Young Adults Protection Policy
  • Gradvert Ltd Single Equality Scheme
  • Health & Safety Policy
  • Data protection Policy & Procedure
  • Social Networking Policy


External documentation:


  • Prevent Duty Guidance – updated in July 2015
  • Keeping Children Safe in Education – September 2018
  • HM Government Prevent Strategy (2015)
  • The role of Further Education Organisations in Preventing Violent extremism: Next Steps (DIUS 2009)


Aims and Objectives


The aim of the Gradvert Ltd Prevent Policy is to ensure that we are able to monitor, manage and deal effectively with the threat posed by any individual or group of individuals engaging in violent extremism in the name of ideology or belief.


  1. To develop staff and consortia members knowledge of Prevent.
  2. To ensure that learners, and all employees of Gradvert Ltd are aware of their roles and responsibilities in preventing violent extremism and radicalisation.
  3. To promote and reinforce shared values, to create space for free and open debate, and support the learner voice.
  4. To document and recognise current practice across the company which effectively manages the risk of learners being exposed to extremism and becoming radicalised.







Gradvert Ltd Responsibilities


To ensure that Gradvert Ltd effectively manage risks and is able to deal appropriately with issues around radicalisation and extremism the company will:


  • Understand the nature of the threat from extremism and how this may impact directly or indirectly on the company.
  • Understand and manage potential risks within the organisation and from external influences including the display of extremist materials and the hiring of external premises
  • Respond rapidly and appropriately to events in local, national or international news that may impact on the organisation.
  • Ensure measures are in place to minimise the potential for acts of extremism within the organisation.
  • Ensure plans are in place to respond appropriately to a threat or incident within the organisation.
  • Adopt effective IT security and promote this to all staff and learners



Teaching, Learning & supporting Learners


Gradvert Ltd is committed to providing a curriculum which promotes knowledge, skills and understanding in order to build the resilience of all learners, by undermining extremist ideology and supporting the learner voice.  This will be achieved through:


  • Embedding equality, diversity and inclusion across the curriculum and promoting community cohesion
  • Promoting wider skill development such as social emotional wellbeing Developing a curriculum which recognises local needs, challenges extremism and promotes universal rights
  • Teaching and learning strategies which explore controversial issues in a way which promotes equality, diversity and inclusion
  • Use of external organisations to support learning and promote respect


To ensure that the organisation community remains safe the following support will be in place for learners:


  • Effective support services which provide clear information, advice and guidance on preventing learners from being drawn into extremism and radicalisation
  • Literature written in clear and simple language which promotes equality, diversity and inclusion and undermines extremist ideology
  • Support for learners and staff and guidance on how to access support through community partners
  • Clear channels of communication to listen to the voice of the local community and understand local tensions
  • Support for at risk learners through safeguarding and mentoring processes
  • A focus on closing the achievement gaps for all learners



Staff Responsibilities


The Quality and Compliance Specialist of Gradvert Ltd, Andrea Satterthwaite (who is a Designated Safeguarding Officer) holds overall responsibility for ensuring that the Prevent policy is implemented across the company and any concerns are shared with the relevant organisations in order to minimise the risk of learners becoming involved with terrorism.  She is assisted by the Deputy Safeguarding Lead (Niamh Finlay) in this task.


The Designated Safeguarding Officer will ensure that staff and learners are aware of the Prevent Agenda and appropriate training is in place.  She will also ensure that as far as is possible all consortia members undergo consistent training from reputable training organisations, including Counter Terrorism units.


All staff have been trained to L2 in Understanding Prevent and Safeguarding Strategies.


All staff at Gradvert Ltd have a responsibility to:


  • Provide an ethos which upholds the organisation’s mission, vision and values and promote respect, equality and diversity and inclusion
  • Report any concerns around extremism or radicalisation via the safeguarding reporting channels
  • Report and remove any literature displayed around the organisation that could cause offense or promote extremist views
  • Support the development of staff and learner understanding of the issues around extremism and radicalisation and participate in training when requested
  • Participate in engagement with local communities, schools and external organisations as appropriate.




Where there is an identified/potential risk that a learner may be involved in supporting or following extremism, further investigation by the police will be requested, prior to other assessments and interventions.  The Designated Safeguarding Officer is responsible for contacting the local Police or the Local Children’s Safeguarding Board for further advice and guidance.


Any member of staff who identifies such concerns must report these to the Designated Safeguarding Officer or deputies as soon as possible for action – this will be recorded in the usual manner on the Gradvert Ltd ‘Safeguarding Report Form’.


Incidents in relation to extremism are expected to be very rare but immediate action will be adopted when there is information that a violent act is imminent, or where weapons or other materials may be in the possession of a learner or a community member.  In this situation, a 999 call will be made and the organisation’s Leadership and Management team informed as soon as practicably possible.


Where a child or vulnerable adult is thought to be in need or at risk of significant harm or where investigations need to be carried out a referral to Social Services will be made in line with the organisation’s safeguarding procedures following advice from the appropriate agencies.





  • Training on PREVENT will be delivered as and when there is a necessity to ensure that all staff have up to date information and briefings. This will be delivered by either the Designated Safeguarding Officer or a variety of partners known to the organisation – such as College of Policing PREVENT Channel training (which staff complete).  We also have links with the G7-Prevent Regional lead for the DFE and Newcastle City Council Prevent Lead and briefings/updates have been delivered to staff.
  • All new staff to the organisation will receive Prevent training as part of their Induction programme, and certificates are kept by the Designated Safeguarding Officer.
  • All staff (to whom it is relevant) are asked to register with the DBS update Service.
  • All staff will be trained on Education and Training ‘Prevent for Practitioners’ and also Safeguarding in FE’.
  • The statutory guidance – Keeping Children Safe in Education – September 2018 –
  • The DSO updates and plans training for all staff in line with requirements and ensures that Hot Topics are delivered to all staff in relation to Prevent and Safeguarding.
  • As part of our ongoing commitment to the consortia members whom we sub-contract


Access & monitoring of IT systems


In order to safeguard individuals from accessing extremist materials while using company equipment Gradvert Ltd will ensure:


  • There is the ability to log and retain records of all electronic communication (web browsing, email exchanges etc.,) by users on the organisation network.
  • Appropriate staff are able to monitor any aspects of its telephone, mobile phones and computing facilities that are made available to staff, learners and visitors
  • Only organisation approved software will be supported by the organisation and allowed to be used
  • All unauthorised software that breaches organisation policy or presents a risk to staff or learner safety will be removed and appropriate action taken
  • All unusual or suspicious events, and any breaches of security are reported via the safeguarding reporting channels for further investigation.


Partnership Working


Gradvert Ltd maintain well-established partnerships; including Police CTU, Local Children’s Safeguarding Board for the boroughs and councils within the areas of delivery and established agencies throughout the area, this enables a network of support to be created and for information exchange where possible to take place.




A Risk Assessment for the Prevent Strategy accompanies this Policy as Appendix 1.


A Policy exists for Freedom of Speech, Events and British Values and is available on our website alongside all other policies and documents referring to Safeguarding.



Complaints Policy

This policy summarises the procedure to be followed to process complaints received from clients regarding the quality of service delivered by Gradvert Ltd:

  1. Complaints may originate from learners, employers or assessors directly or indirectly.  Complaints may be received either verbally or in writing.


  1. Each instance of complaint must be reported/directed to the relevant Line Manager. Upon  receipt of the complaint the individual will complete the appropriate sections of a

      Complaints Record Form for appropriate action. 


  1. Every effort will be made to resolve the complaint and to provide a full response to the complainant within 7 working days.


  1. Once the complaint has been resolved the employee will complete the relevant sections of the Complaints Record Form, which will then be signed off by the line manager.


  1. The Managing Director (Michaela Reaney) will be responsible for maintaining all records relating to a complaint, using an appropriate Complaints Record Form as the basis for monitoring the progress made in resolving the complaint. Records will include all written complaints received, and copies of all statements from relevant parties.


  1. Completed Complaints Record forms will be reviewed on a regular basis for apparent adverse trends in service quality as part of the Management Review of the Quality System and to monitor equality and diversity.




  1. Complaint received
    • All complaints will be treat on an individual basis and, depending on how a complaint is received, will dictate the appropriate course of action.


  1. Telephone complaint


  • Upon receipt of a telephone complaint the person dealing with the call should in the first instance pass the complaint on to the Managing Director (Michaela Reaney) and in the event of them being absent the call should be passed on to the most appropriate person. If neither is available, then the person taking the call should take details of the complaint and complete the Complaint Record Form.


  • The complaint will be logged into the Complaints register by the Line Manager and a copy of the complaint form will be forwarded to the appropriate person.


  • Once the complaint has been resolved the complaint form will be completed accordingly and a final letter / email sent to the complainant with the outcome.



  1. Written complaint
    • Upon receipt of a written complaint, either postal or via email, the complaint will be forwarded to the Managing Director (Michaela Reaney) who will contact the complainant by phone and complete the Complaints Form. In the event of the Managing Director (Michaela Reaney) not being available and it is known they will not be so within the next 24 hours, the most appropriate person should then make the call and complete the Complaints form. If neither is available the person who picked up the email should take the action to call the complainant and complete the Complaints form.


  1. Review
    • Complaints will be reviewed on a yearly basis by the Managing Director (Michaela Reaney) and an analysis of complaints will be compiled.


  • The Managing Director (Michaela Reaney) will liaise with the staff to discuss continuous improvements and identify trends. Any actions to be put into place to ensure business practices are having a positive impact on complaints.