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Admissions, enrolment and documentation procedures

Introduction

The purpose of this document is to set out the procedures and provide further details of the documentation that Connect English Academy (‘the academy’) requires to successfully admit and enrol a student onto one of its courses.

Admissions procedure

STAGE ONE – STUDENT QUERY RECEIVED

An application to study at the academy is usually proceeded by an enquiry either from the student or representative.

  • Information should be provided by the academy within 24 hours of receiving an inquiry.
  • The academy should send the following information: the academy brochure, price list, terms and condtions and the student application form (and homestay application form if required).

STAGE TWO – COMPLETED APPLICATION FORM RECEIVED

Before any conditional offer letter can be issued by the academy, the following must be provided by all potential students:

  • A fully completed application form with contact details including the student’s home address, and emergency contact details.
  • A clear copy of the student’s ID card (EU students) or their passport showing their picture (non-EU students).
  • If the student needs accommodation, a completed homestay application form.

STAGE THREE – CONDITIONAL OFFER LETTER SENT

The administration team enters the student’s details on the student database. The academy then prepares and sends the following:

  • A conditional offfer letter; this letter includes the details for the course that the academy can offer and a breakdown off all fees included such as course fees, transfers and accommodation.

STAGE FOUR – STUDENT SIGNS AND RETURNS CONDITIONAL OFFER LETTER

Upon receipt of the coniditonal offer letter, if the student wishes to proceed with their application then student must provide:

  • A dated and signed copy of the offer letter.
Students under 18 must provide:
  • A competed copy of the academy’s Application Form for Under18s which includes the Medical Details and Declaration and Consent.
  • This form must be completed by the student’s parent or legal guardian

STAGE FIVE – CONFIRMATION OF STUDENT’S SUCCESSFUL APPLICATION

Once all the relevant documents have been received and checked, the student is informed of their successful application.

  • The student is then invoiced, which is to be paid in accordance with the academy’s payment terms as detailed in is terms and conditions.
  • The student’s information is updated on the academy’s database.

Pre-arrivals procedure

  • Pre-arrival checks are carried out by the administration team prior to a student’s start date.
  • A list of all expected arrivals will be sent to the management team two weeks in advance. This will highlight students who are under 18, sponsored/private students, and those requesting homestay accommodation.
  • The student is contacted by the administration team. If the student is coming via a representative, then they are copied into the email to confirm their arrival for the following week.
  • A record of expected arrivals and contact with representatives is shared on the server on a spreadsheet and can be accessed by the administration team and management team.

Under 18s

For expected arrivals of students under 18 years old:

  • All under 18s should be provided with homestay accommodation unless they are living with a parent or a close relative. 
  • Written permission from the parent/guardian confirming the arrangement for accommodation.
  • The administration team liaises with the housing officer to ensure everything is in order with regards to homestay for the student.
  • The student will not be able to enrol on their course if this information has not been received.

Arrivals and enrolment procedure

  • Students must start their course on the start date given on the offer letter, or by the latest start date agreed (usually 10 working days) if they are delayed.
  • If for any reason, there is a delay in a student starting at the academy, the student, or their representative, must inform administration team as soon as possible.
  • If an exception is made at the situation requires it, the academy will issue a new conditional offer letter.
  • The administration team updates any late arrivals on the student database soon as possible to inform the management team who ensures that they teaching provision is adjusted accordingly.
  • The administration team also ensures that the housing officer is informed.
  • The change is also recorded on the student’s file.
  • The administration team in most cases decides if the change of start date is acceptable. However, if the situation is deemed complex or for a prolonged period, then the management team is consulted.

Upon the student’s arrival at the academy, the administration team follows one of two procedures

  • Check the student’s ID/passport to make sure it corresponds with the initial application.
  • Sign and date the copy of the ID/passport used in the student’s application.
  • Complete the student enrolment and induction forms, ensuring that the student has received relevant briefings and documents from the relevant members of staff. 
  • On the student checklist spreadsheet, transfer the student from prospective students to current students. 
  • Ensure all fees have been paid and the pro forma is submitted to the finance office. 
  • For sponsored students, check and make a copy of the financial guarantee letter.


Under 18s
  • The academy takes special care when dealing with students who are under 18. During the enrolment process, students who are under 18 are given specific advice in line with the academy’s Safeguarding policy and procedures.


All students
  • The academy asks students to bring with them the originals certificates/transcripts that were used by the student during the application process. These are checked during enrolment and copies are signed by the academy.
  • Students are briefed on the academy’s expectations by the management team and the administration team.
  • If a student does not have a correct visa, the student will not be allowed to complete enrolment and start any course until the issue has been resolved or confirmation is received from the UKVI that the student can continue while the situation is resolved; this will be dealt with on a case-by-case basis.
  • If it is found that the student has supplied false information (despite the academy’s best efforts during the application stage to ensure that this is not the case) the student will not be allowed to enrol and will be reported to the relevant authorities such as the UKVI. The academy will update all relevant systems including those of the UKVI.
  • If a student is delayed starting a course due to unacceptable reasons, or if the student is delayed to such an extent that starting a course will not be practical, the student may forfeit their fees paid in accordance with the academy’s terms and conditions. All relevant authorities such as the UKVI will be informed. This will be dealt with on a case-by-case basis.

Non-arrivals and cancellation procedure

If the student fails to enrol by the start date, and it has not already been agreed with the academy, then the administration team will issue a cancellation letter, unless the delay is agreed by the academy. The student may not be entitled to any refund. The academy will consider each failure to enrol on a case-by-case basis.
The administration team issues a letter of cancellation when:

  • The student fails to register with the academy and has not satisfactorily responded to any contact from the academy. 
  • Where a student notifies the school that they wish to defer the commencement of their classes.

Students failing to register on arrival in the UK will be contacted over 10 working days, using the following methods:

  • Non-arrival letter (via email) – working day two  
  • Telephone call - working days two and three 
  • Follow-up email – working day five
  • Cancellation letter – working day ten


On the tenth working day, the administration team will cancel the student’s enrolment on the academy’s database and will transfer them to the cancelled student’s tab on the checklist.

Student Attendance and Homework Policy and Procedure

Introduction

1. The student attendance policy has been developed as part of Connect English Academy’s (‘Connect’, ‘the academy’) commitment to providing a supportive learning environment that enables all students who have chosen to study at Connect to achieve their full potential.

2. Connect recognises the investment that students make when a student enrols on a course and considers that is has responsibility to act on non-attendance so that students can be supported to complete their programmes of study successfully.

3. Connect also has a legal duty to monitor the attendance of students from non-European Economic Areas (non-EEA) who have Tier 4 visas and to report those who do not meet the required number of attendances to United Kingdom and Visas and Immigration (UKVI).

4. If a student is intending to be absent, they must seek authorisation from the Managing Director or Academic Manager in advance. If a student is absent, without having previously notified Connect, for example in the case of illness, they must contact Connect immediately via a text message, email or phone call with the reasons. On return, the student must also provide Connect with evidence of the reason for their absence which will be noted in the student file. If Connect is not satisfied with the reasons or evidence provided by the student, the absence will be treated as unauthorised. This process is made clear to all students when they enrol.

Responsibilities

1. It is important that you are on time and that you attend your classes every day your course runs. We can only issue certificates, documents and allow holidays for students who have an 80% attendance rate or higher.

2. If you cannot attend class, you must inform us BEFORE your class via text message, phone call or email.

3. If you are unable to attend because of illness you must complete a self-certification form as soon as you recover (available from management staff), or provide a doctor’s note if your absence is for more than 7 days.

4. We will also warn you that if you are absent for 10 days in a row in total, you will be automatically expelled (with no refund allowed).

5. If your attendance falls BELOW 80% you will be asked to attend a meeting with the Managing Director and/or the Academic Manager.

6. You must also complete all homework set by your teachers. If you continue to fail to complete your homework then you will be asked to attend a meeting with the Managing Director and/or the Academic Manager. This is what happens in each meeting:

First Meeting

1. We will check your contact details.

2. We will check your reasons for your absence or for your non-completion of homework, and ensure that you are happy in Cardiff and studying at Connect. If there is anything we can help you with, please let us know.

3. We will explain our attendance and homework policy, the warnings and what will happen if your attendance / completion of homework does not improve.

4. If your attendance / completion of homework does not improve, we will ask you to attend a second meeting.

Second Meeting

1. You will receive a verbal warning regarding your attendance or non-completion of homework (this will be recorded in your student file).

2. We will give you a deadline, which you must improve your attendance / completion of homework by. You will be asked to sign a statement to confirm that you will improve your attendance / completion of homework by this deadline.

3. If your attendance / completion of homework does not improve by the deadline, we will then give you a written warning (a copy will be filed in our student file).

First Written Warning

1. You will receive a written warning regarding your absence / non-completion of homework.

2. We will give you a deadline (usually one week), which you must improve your attendance / completion of homework by. You will be asked to sign a statement to confirm that you will improve your attendance / completion of homework by this deadline.

3. If your attendance / completion of homework does not improve you will received a final written warning.

Final Written Warning

1. You will receive a final written warning regarding your absence / completion of homework.

2. We will give you a deadline (usually one week), which you must improve your attendance / completion of homework by. You will be asked to sign a statement to confirm that you will improve your attendance / completion of homework by this deadline.

3. If your attendance / completion of homework does not improve your course will be cancelled.

Cancellation Of Your Course

1. Your name will be removed from the class register.

2. You will receive a written confirmation that your course has been cancelled, and that you will receive no refund as per our terms and conditions.

Complaints Policy and Procedure

Aims

The aims of the policy and procedure are:

  • To provide all clients (including students, group leaders and agents) or external service providers (including accommodation and transfer providers) with opportunities to give feedback and make complaints.
  • For all complaints about service to be addressed and resolved in a timely and professional manner.
  • To provide and operate a clear and useful complaints procedure for customers and providers.
  • To ensure clients and providers are aware that such a policy exists.
  • We actively and continuously monitor the quality of our service to ensure we maintain high standards.

We offer several options and opportunities for the client or provider to offer feedback and/or make complaints.
These include:

Student induction: Students are informed who they can contact regarding any issues they may have during their induction at the start of their course.

Initial feedback form: This form is given to all students during their first week studying at Connect. Any issues are noted by the management team and are resolved if required.

Mid-course feedback form:Students are given a mid-course feedback form halfway during their course. Any issues are noted by the management team and are resolved if required.

End-of course feedback form: Students complete this on the last day of the course. Any issues are noted by the management team and are resolved if required. Any issues and comments are also taken into account for future planning and teaching.

Anonymous feedback: Students and staff can write any suggestions/comments via paper slips in the Suggestions Box in the student lounge.

Weekly welfare check: Students are asked at the beginning of each week by their teacher if there are any issues or problems via the student welfare checklist. Any issues or comments are noted by the management team and resolved if required.

Informal contact: Speaking to or emailing students, group leaders and agents.

Complaints form:This form is available from reception.

Further to this, at least one member of Connect staff will be available for clients and providers to speak to in person, on the telephone, via email or via skype anytime during opening hours.

There is also a 24-hour emergency contact number, for outside of office hours, should the complaint need urgent and immediate attention.

Policy

Every client and provider has the right to provide feedback and/or make a complaint.

The following standards are in place to ensure our complaints procedure is readily available, easy to use, confidential and fair. Everyone who makes a complaint will be:

  • Treated with respect
  • Listened to
  • Thanked for bringing the matter to our attention
  • Assured that their complaint has been acknowledged and will be investigated and responded to every complaint will be:
  • Acknowledged
  • Fully investigated
  • Dealt with professionally and in a timely manner
  • Treated with confidentiality to avoid embarrassment or prejudice to those who complain

Complaint Procedure

Please note that a simplified version of this procedure can be found on page 5 of this document or on the website www.connect-english.co.uk‘Complaint Procedure 2019’.

Informal complaints

Many complaints can be approached, dealt with and resolved quickly and informally. Clients and providers can therefore approach any member of staff regarding any complaints they wish to make. Where possible, it is recommended that the complainant approach the member of staff they have already been dealing with as they are most likely to have the most complete understanding of the situation. In some cases, the complainant may be encouraged to talk to the following members of staff: Managing Director, Director of Studies, and the Administration Manager / Student Welfare Officer.

  1. The complaint will be acknowledged immediately at time of contact if the complaint is made in person. The complaint will be acknowledged within one working day of receipt, if the complaint is made via other methods of communication (clients and providers are respectfully reminded that the school office is open Monday to Friday, 09:00-17:00).
  2. The complainant may be asked further questions, to repeat and clarify information and/or to provide documentation to support the complaint.
  3. The complainant will be informed of when and how they shall receive a response to their complaint; this will be within two working days.
  4. The complainant may be provided with an ‘action plan’, outlining actions to be taken with a timescale and updated on the progress of these actions.
  5. The complainant will be asked to confirm if they are satisfied with the resolution of their complaint.
  6. Connect will keep a confidential record of the complaint and any action taken as a result.

Formal complaint

If the complainant is dissatisfied with the outcome of their informal complaint, they can make a formal complaint. To make a formal complaint:

  1. First stage
    • The complainant can complete a complaint form that is available from reception or the website: www.connect-english.co.uk
    • The complainant should provide as much detail about the situation as possible, including relevant facts such as names and dates if applicable, previous attempts to resolve their complaint, why they are dissatisfied, how they would like their complaint to be resolved.
    • The complainant should give their complaint form to the Managing Director, Director of Studies or the Administration Manager / Student Welfare Officer.
    • The complaint will be acknowledged via email or in writing within three working days of receipt of the form.
    • The complainant may be invited to discuss the issue further with the relevant members of staff as listed above.
    • The relevant member of staff will respond to the complainant via email or in writing within ten working days of receiving the form.
    • Connect will keep a confidential record of the complaint and any action taken as a result

  2. Second stage
    • In the unlikely event that the issue remains unresolved or the complainant is dissatisfied with the outcome of their formal complaint, they can make a second stage formal complaint.
    • To make a second stage formal complaint:
      1. The complainant may write directly to the Managing Director: info@connect-english.co.uk, Connect International English Academy, First Floor, 26-28 Churchill Way, Cardiff, CF10 2DY.
      2. The complainant should provide as much detail about the situation as possible, including names and dates if applicable, previous attempts to resolve their complaint, why they are dissatisfied and how they would like their complaint to be resolved.
      3. The complainant will receive an acknowledgment in writing with ten working days of receipt. If the complainant does not receive a response within the time, it is recommended that they telephone Connect to confirm their complaint has been received.
      4. You may be invited to a formal meeting to discuss your case further.
      5. The complainant will receive the outcome to their complaint within 30 working days of receipt.
      6. Connect will keep a confidential record of the complaint and any action taken as a result

  3. Third stage
  4. Having exhausted all internal options, in the unlikely event that the complainant believes their complaint has not been dealt with in accordance with the above procedure, they can request the assistance of an impartial third-party adjudicator.

    To make a complaint via an impartial third-party adjudicator:

    1. The complainant should submit their complaint in writing or via email to either British Council or English UK.
    2. British Council:Unit Bridgewater House 58 Whitworth Street Manchester M1 6BB UK

      Email: accreditation.unit@britishcouncil.org

      Website: http://www.britishcouncil.org/education/accreditation /information-students-agents/student-complaints \

      English UK:The Chief Executive English UK 219 St John Street London EC1V 4LY

      Website: http://www.englishuk.com/en/students/english-in-the-uk/student-complaints-procedure.

    3. The complainant should ensure their letter includes details of how they have already tried to resolve their complaint with Connect and any supporting documents, such as invoices, letter and the written outcome of your complaint.
    4. Please refer to the websites provided for detailed, up-to-date, procedure. Please note, the British Council and English UK can accept complaints from clients (i.e. students, group leaders and agents) but not from service providers.
    5. Please refer to the websites provided for detailed, up-to-date, procedure. Please note, the British Council and English UK can accept complaints from clients (i.e. students, group leaders and agents) but not from service providers.

Curriculum Policy

Connect English Academy is committed to providing our students with quality English language training which:

  • will engage and challenge learners;
  • is appropriate and relevant to their language level, needs and objectives;
  • builds on their prior knowledge;
  • helps them to make the most of their time in Cardiff and the UK;
  • helps them take responsibility for their own independent learning;
  • develops learning skills and prepares them for future learning;
  • provides attainable but challenging targets;
  • addresses speaking, listening, writing and reading skills;
  • is structured to provide a logical progression including preparation for outcomes which meet the definition of an approved qualification for UKBA purposes;
  • provides correction of errors and advice on learning;
  • provides learners with regular, rigorous, fair and reliable assessment of progress;
  • provides regular feedback on progress;
  • is organized with reference to CEFR;
  • is conducted by qualified and professional teachers using effective methodology;

Connect English language courses target learner outcomes which are:

  • displayed in classrooms on a weekly basis;
  • available in full in classrooms;

Connect welcomes suggestions from our learners, teachers and other stakeholders as to how we might be able to improve our educational offerings.

Equal Opportunities Policy And Procedure

Introduction

Since its formation, Connect English Academy(‘Connect’)has been committed to working towards the equality of opportunity for all staff and students.

This document represents our public declaration of our continued commitment. We will support any member of the Connect community who is subjected to discrimination or harassment, and we will not tolerate acts of discrimination, harassment or bullying anywhere in Connect. The achievement of our mission fundamentally requires that nobody should be denied their fair chance of success by the actions of others. We all have a responsibility to ensure that policy is implemented and to strive to achieve equality of opportunity throughout Connect.

Policy statement

  1. Connect exists to educate and train people to achieve their full potential.
  2. The Connect community comprises students, staff and host families. Connect requires all its members to treat others with fairness and respect and to show openness and honesty in their dealings with others.
  3. Connect aims to create the conditions whereby students and staff are treated solely on the basis of their merits, abilities and potential, without regard (except where the law specifically provides) to ethnicity, colour or national origin, gender, marital status or family circumstances, disability or learning difficulties, trade union membership or activity, criminal record, socio-economic background, religious or political beliefs, sexual orientation, or other irrelevant distinction.
  4. Connect recognises its statutory responsibilities under United Kingdom and European Union legislation and seeks to combat any form of discrimination, either direct or indirect (see Appendix A for a summary of the key elements of antidiscrimination legislation).

The broad principles

  1. Ethnicity, Colour or National Origin
  2. Connect is committed to a policy to eliminate discrimination on grounds of ethnicity, colour or national origin and to counter racist attitudes and behaviour.

    It is committed to a strategy of positive action, in accordance with the provisions of the Race Relations Act, to increase representation of hitherto under-represented ethnic groups in the workforce and in the student body.

  3. Gender, Marital Status and Family Circumstance
  4. Connect is committed to a policy to eliminate unlawful discrimination on grounds of gender, marital status or family circumstance and to increase equality of opportunity between the sexes for both students and staff.

  5. Disabilities and Learning Difficulties
  6. Connect is committed to developing positive employment policies in relation to people with disabilities and learning difficulties. It will strive to ensure that students with disabilities and learning difficulties maximise their learning potential and are able to participate fully and equally in all the learning and social activities on offer within Connect.

  7. Criminal Record
  8. Connect is committed to meeting its statutory responsibilities under the Rehabilitation of Offenders Act (1974) and will strive to ensure that no job applicant or potential student is unfairly disadvantaged on the grounds that they have a criminal record.

  9. Trade Union Membership and Activity
  10. Connect is committed to ensuring that no person is treated less favourably in employment because s/he is, or is not, a member of a trade union or on the grounds of trade union activity.

  11. Age
  12. Connect believes that prejudice and discrimination on the grounds of age (‘ageism’) have no place in an educational establishment. There should be no discrimination in employment on the grounds of age, subject to the normal arrangements for employees to retire at age 65. Connect will not discriminate against students on the grounds of age, except where age is an approved criterion for entry to a course.

  13. Socio-Economic Background
  14. Connect draws students and staff from widely differing social and economic backgrounds and will strive to ensure that no member of Connect’s community is unfairly disadvantaged because of their social or economic background.

  15. Religious or Political Beliefs
  16. Connect believes that lawful preferences, privately held, on any matter, including religion or politics, are a matter for the individual concerned and should not influence decisions relating to employment or educational opportunities.

  17. Sexual Orientation
  18. Connect believes that lawful sexual orientation is a matter for the individual concerned and should not influence decisions relating to employment and education. We will strive to ensure that no member of the Connect community suffers from discrimination as a result of stereotyping or homophobia because of their sexual orientation.

Responsibility for Implementation of the Policy

  1. Connect is responsible for the Equal Opportunities Policy and for ensuring that all Academypolicies and procedures comply with statutory requirements and promote good practice.
  2. Overall responsibility for ensuring the effective implementation of this policy lies with the Managing Director and Director of Studies.
  3. All members of staff are responsible for ensuring compliance with the policy within their own work area at all times.
  4. It is the duty of all members of Connect to be familiar with and to comply with the requirements of the law and of this policy. Each individual is expected to exercise personal responsibility for the implementation of the policy within their own area of activity. No member of Connect should ignore, condone or collude with acts of discrimination.

Equality of Opportunity in Education and Training

  1. Recruitment and Selection of Students
  2. Connect strives through the implementation of its Equal Opportunities Policy to ensure that prospective students are not discriminated against on any of the grounds referred to under the Broad Principles. Recruitment patterns across the whole academy will be reviewed and the recruitment of under-represented groups in particular programmes will be encouraged.

  3. Student Induction
  4. At induction, all students will be informed of the Equal Opportunities Policy in relation to their rights and responsibilities and what action to take in the event of perceived unfair treatment.

  5. Learner Support and Learning Support
  6. All students are entitled to receive appropriate learner support according to their individual needs.

  7. Counselling, Guidance, Advice and Welfare
  8. Students and prospective students will be provided with appropriate access to counselling, guidance and advice, welfare advice and support to meet their needs.

  9. Curriculum and Assessment
  10. Wherever possible, Connect will seek to ensure that both curriculum and assessment will reflect ethnic diversity and the cultural background and traditions of the different groups in our community. Learner management techniques will recognise diversity and will avoid stereotypical assumptions. All students will be encouraged to participate fully in the learning process.

  11. Discipline and Grievance
  12. Connect will ensure that in grievance and disciplinary procedures it complies with the laws regarding discrimination. Particular attention should be paid to ensure that no student is disadvantaged because of communication difficulties.

Academy Environment and Facilities

  1. Connect is committed to maintaining a working and learning environment which encourages all staff and students to contribute fully and on an equal basis to the life of the academy. Every effort will be made so that, insofar as is reasonably practicable, all parts of Connect are welcoming, accessible and safe for all members and potential members of the Connect community.
  2. In planning its accommodation and resources strategy, Connect will take account of the needs of all the groups listed under the broad principles.

Communications and School Publicity

In planning and implementing its communications strategy covering all forms of internal, external written, visual and verbal communications, the Academy will:

  1. promote the use of positive, non-stereotypical images of all the groups listed in the broad principles;
  2. show respect for all persons and sensitivity to their individual needs;
  3. avoid the use of inappropriate language or imagery which might constitute indirect discrimination;
  4. create an atmosphere in which all members of the Academy community feel needed and valued.

Other Users of Connect Premises and Facilities

  1. All users of Connect’s premises (e.g. those hiring facilities) will be expected to respect the law and to act in the spirit of this Equal Opportunities Policy.

Monitoring and Review of the Policy

  1. The Academy is committed to monitoring the effectiveness of its Equal Opportunity Policies and Procedures.
  2. The Policy will be reviewed periodically as required by the Corporation.

What to Do If You Have a Problem

  1. If any member of the Academy community feels that there has been a breach of the Equal Opportunities Policy, they should draw this to the attention of a member of School management.
  2. Information about the procedures to be followed in dealing with breaches of this Policy may be obtained from course tutors (for students) or Management (for staff).

Procedure

  1. Ensure a statement of our equal opportunities policy is included in the contract of employment, teachers’ handbook and staff handbook.
  2. Ensure that at all times we are acting legally, and avoiding any behaviour which is unlawful or unfair.
  3. Brief all staff who are in positions where they need to be aware of these issues
  4. Ensuring any staff interviewing or selecting staff, trainees, students or others are mindful of the company’s equal opportunities policy.
  5. Ensure opportunities for training and development are given according to need.
  6. Develop a culture where issues of equal opportunities are not seen as simply contractual or legal matters but are basic to the culture of the company, and to do this by regularly sharing our experiences.
  7. Draw up job descriptions and person specifications which avoid choices based on sex, sexual orientation, age (if under the age of retirement) race, colour, religion, political views.

Equal Opportunities Legislation

Appendix A

  1. Introduction

  2. The key elements of UK legislation which are relevant to this policy are: The Race Relations Act 1976 The Sex Discrimination Act 1975 The Equal Pay Act 1970 (as amended 1983) The Disability Discrimination Act 1995 The Rehabilitation of Offenders Act 1974 The Trade Union and Labour Relations (Consolidation) Act 1992

    In addition to these UK anti-discrimination laws, it is also important to be aware of the provisions of European Union law, whether or not they have been subsequently enacted in UK legislation. Examples of EU Directives on equal opportunities issues are those covering Equal Treatment and Pregnant Workers.

  3. The Sex Discrimination Act (SDA) and the Race Relations Act (RRA)

  4. The SDA and the RRA render unlawful two types of discrimination: Direct discrimination, where a person is treated less favourably than another person is, or would be, treated, on the grounds of sex or race. Indirect discrimination, where a condition is applied equally to both sexes, or all races, and cannot be justified except on the grounds of sex or race, and has the effect of disproportionately disadvantaging one sex or racial group(s) because the proportion of one sex or racial group(s) which can comply with the condition is considerably smaller than the proportion of the other sex or racial group(s) which can comply with it.

    The SDA and the RRA make it unlawful to discriminate, directly or indirectly, in employment, training and related matters, in the provision of education, in the provision of goods, facilities and services to the public; and in the disposal and management of premises.

    Under the Acts the following are also unlawful:

    • Instructions to discriminate
    • Pressure to discriminate
    • Segregation
    • Harassment
    • Knowingly aiding any unlawful act of discrimination
    • Victimization

    An employer is responsible for any act of discrimination done by an employee in the course of her/his employment, whether or not it was done with the employer’s knowledge.

    The Codes of Practice of the Commission for Racial Equality (CRE) and the Equal Opportunities Commission (EOC) contain recommendations and guidance for employers on how to avoid race and sex discrimination in employment. Although the codes do not have the force of law, they are approved by Parliament and their provisions are taken into account by industrial tribunals.

  5. The Disability Discrimination Act 1995 (DDA)

  6. The employment provisions of the DDA came into effect in December 1996. These provisions render it unlawful to discriminate against a disabled person either by refusing to offer employment on grounds of disability, or to discriminate against them in the course of employment (e.g. in respect of training, promotion, terms of employment, working conditions, etc.).

    Under the DDA employers have a duty to make reasonable adjustments to working arrangements or premises in order to accommodate the needs of disabled employees and job applicants.

  7. The Equal Pay Act 1970 (as amended 1983) (EPA)

  8. The EPA entitles an employee to equal pay (and other contractual terms and conditions) with an employee of the opposite sex if they are doing work which is the same or broadly similar; or which has been rated as equivalent by an analytical job evaluation scheme; or which can be shown to be of equal value in terms of the demands made on the worker.

  9. The Rehabilitation of Offenders Act 1974

  10. The Rehabilitation of Offenders Act 1974 gives ex-offenders the right to be rehabilitated and to regard their conviction as being ‘spent’ after a specified period of time, subject to certain conditions. It is illegal for an employer to discriminate against an ex-offender on the grounds of a spent conviction. However, various kinds of employment are exempted from the provisions of the Act and these include certain posts at the School which involve substantial unsupervised access to students under the age of sixteen or under eighteen with special needs.

  11. Trade Union and Labour Relations (Consolidation) Act 1992 (TULR(C)A)

  12. Under the provisions of the TULR(C) it is unlawful:

    • to refuse a person employment because s/he is, or is not, a member of a trade union
    • to dismiss an employee because s/he is, or is not, a member of a trade union, or has taken part in trade union activities
    • to take action short of dismissal against an individual employee with the purpose of preventing or deterring her/him from becoming a member of a trade union or taking part in trade union activities, or penalizing her/him for doing so (or compelling her/him to join a trade union)

Health and Safety

Statement of policy and school regulations

Connect English Academy(hereafter “Connect”)acknowledges its duty to ensure, so far as is reasonably practicable, the health safety and welfare of all who are affected by the way their undertaking is conducted. This refers to all academy staff, its students, contractors and anyone else who comes into contact with the academy and its activities.

Connect has a policy to provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to health. To this end, the Academy will allocate sufficient resources and sound management systems to the fulfilment of this policy.

Connect will comply with the Health and Safety at Work Act 1974, all its relevant statutory provisions and appropriate Approved Codes of Practice, and follow the best current practice in all aspects of its undertaking.

In particular, the Academy will, so far as is reasonably practicable:

  • provide and maintain safe and healthy working conditions and systems of work
  • provide and maintain safe plant and machinery
  • provide information, instruction, training and supervision to enable all staff and students to perform their work safely
  • provide suitable and appropriate protective equipment and supervise its use
  • maintain high standards of health, safety and welfare in all academy activities.

This policy statement will be made available on the Connect’s website and all academy staff will be given a copy to read as part of their induction at the Academy.

Copies will also be posted on appropriate notice boards around the school premises. In return, the school requires its staff and students to take reasonable care of themselves and other persons who may be affected by their acts or omissions whilst at work, and to abide by Connect Regulations.

This policy statement and the systems in place will be reviewed annually to ensure their effectiveness.

The following statement of policy for the health and safety at work of all employees is issued in accordance with section 2(3) of the Health and Safety and Welfare at Work Act 1974, for the information of the staff of the academy, its students, contractors and anyone else who comes into contact with the academy and its activities.

  1. The management recognises and accepts its responsibilities as an employer for providing a safe and healthy environment for all its employees and students, and conducting its undertaking without risk to the health and safety of others.
  2. The Management fulfils its responsibilities under the Act, paying particular attention to the provision and maintenance of:
    • Plant, equipment and systems of work that are safe
    • Sufficient information, instruction, training and supervision to enable all employees and students to avoid hazards and contribute positively to their own health and safety at work
    • A safe place of work with safe access
    • A healthy work environment
    • Adequate welfare facilities
  3. The Management expects all employees and students to appreciate that their responsibility for health and safety is no less than any other function.
  4. Employees and students are expected to take reasonable care for the health and safety of themselves and others.
  5. Employees and students are expected to co-operate with Connect to enable it to carry out its own responsibilities successfully.
  6. It is the employees’ and students’ responsibility to bring any deficiency in health and safety to the attention of the Management immediately.
  7. This statement will be reviewed and revised as required and any revision will be brought to the attention of employees and students.

Health and safety guidance

General

The following notes should be read in conjunction with the Health and Safety Policy statement:

  1. The member of staff responsible for health and safety is: Monika Morgans - Health Safety Officer, Connect International English Academy, First Floor, 26-28 Churchill Way, Cardiff CF10 2DY Tel: 02920232111.
  2. All accidents or dangerous occurrences that result in injury to employees, students or any other person on CIEA’s property, or cause damage to equipment should be reported to the above-named staff member.

Electricity

  1. Employees and students must not overload the socket outlets
  2. Employees and students must report to the HS Officer faulty plugs, leads and equipment.
  3. Employees and students must switch off equipment before unplugging and cleaning.

Safety

  1. Employees and students must not allow trailing leads to create tripping hazards.
  2. Employees and students must notify the HS Officer of faulty plugs, leads and equipment.
  3. Employees and students must not block corridors
  4. Employees and students must notify the HS officer of loose or torn floor coverings.

Health

  1. Employees and students must not attempt to handle, lift or carry heavy or bulky items without assistance from another person or by using a trolley.
  2. Employees and students must smoke in the designated area outside the building.
  3. When using the computers, employees and students must make full use of the adjustment facilities on the VDU and adjust the workstation to make the most comfortable working environment.

Dealing With Abusive Behaviour Policy And Procedure

Policy

  1. Connect always aims to be a happy and friendly community in which everyone respects, supports and cares about one another.
  2. Connect will take the firmest action against any abusive or negative behaviour.
  3. All abusive behaviour is unacceptable. No-one at Connect English Academy (hereafter ‘Connect’ or ‘the academy’) should ever be made to feel unhappy, undervalued or humiliated.
  4. Abusive behaviour can include, but is not limited to, verbal, physical or mental abuse, harassment, bullying, actual or threatened violence and damage to personal property.
  5. Deliberate unkindness or any action that causes hurt or upset will not be tolerated from any student, staff member or visitor.
  6. It is a form of abusive behaviour to write notes, make phone calls or send electronic messages that are offensive, hurtful, annoying or worrying.
  7. Abusive behaviour can also include cyberbullying; use of information technology to repeatedly harm or harass other people in a deliberate manner, e.g. sending, forwarding or posting harmful material using a cell phone or the internet. Cyberbullying can also take place in the workplace or on company web sites, blogs or product reviews.
  8. Students, staff members and visitors have a right to privacy of property and personal information in school. It is dishonest and can be a form of abuse to go into another person’s pocket or bag, read a private document or electronic message.
  9. Connect works hard to create an open atmosphere in which you are free to speak up about any concerns.  Any student, staff member of visitor who feels unhappy or threatened should seek the help of the Managing Director, Director of Studies, a friend, or a teacher.
  10. It is the duty of everyone who sees an instance of abusive behaviour – actual or potential – to act to stop it peacefully, and then to report it. This duty applies to all students and staff.

Procedure

The following steps may be taken when dealing with incidents:

  1. If abusive behaviour is suspected or witnessed it must be reported to the Managing Director and/or the Director of Studies.
  2. Once reported, the incident will be dealt with immediately by the Managing Director and/or the Director of Studies.
  3. A clear account of the incident will be recorded and given to the Managing Director and/or the Director of Studies.
  4. The Managing Director and/or the Director of Studies will interview all concerned and will record what is said.
  5. Parents, guardians and/or agents will be kept informed, where necessary.
  6. Punitive measures will be used as appropriate and in consultation with all parties concerned.
  7. Students, staff members or visitors who have been a victim of abusive behaviour will receive full support from Connect by:
    • offering an immediate opportunity to discuss the experience with Managing Director and/or the Academic Manager;
    • offering continuous support and reassurance;
    • working on restoring self-esteem and confidence;
    • taking measures to ensure no further abusive behaviour occurs.
  8. The accused student, staff member or visitor will also receive full support from Connect by:
    • being given the opportunity to discuss the events
    • discovering why s/he became involved
    • establishing the wrong doing and the need to change behaviour
    • advising and supporting him/her to seek professional help
  9. In the occurrence of any abusive behaviour, the following disciplinary steps will be taken:
    • The giving of an official verbal and written warning (outlining the second stage of disciplinary steps), in the hope to cease offending.
    • In the event of a second occurrence (even if the victim or offence differs from the first), permanent exclusion from the course and any other services (e.g. accommodation). No refund or alternative arrangements will be made. In the event of a staff member feeling/being victimised, they are advised to speak with the Managing Director or Director of Studies.
    • If the abuser is a staff member, the action to be taken will follow the ‘disciplinary procedures’ within the staff handbook.

    Connect will annually review and assess this policy, its implementation and effectiveness, after considering any occurrences and any feedback received from staff, students and/or visitors. The policy will be promoted through posters and implemented throughout the school.

First Aid Policy and Procedure

Duty to make provision for First Aid

In accordance with The Health and Safety (First-Aid) Regulations 1981, English Academy(hereafter” Connect”)is required to make sufficient first-aid provision for its employees in the event of injury or sudden illness while they are in the workplace.

In addition to this, Connect will also make provision for first-aid to be available to students and visitors, whilst on the premises.

Provision

Following assessment of first-aid needs, Connect identifies sufficient provision as:

  • 2 x Emergency First Aid at Work trained first aiders
  • 2 x First aid kits (1 large, 1 small)

Procedure

In the event that a member of staff, student or visitor is injured or becomes ill on Connect premises, a Certified First Aider should be found as soon as possible. The first aid poster with the list of First Aiders is displayed in every classroom and communal area.

First Aid kits can be found at the following locations:

Building

Floor

Location

Size

26-28 Churchill Way

First Floor

Office (Staff Room)

Small

26-28 Churchill Way

First Floor

Office (Staff Room)

Large

  • The First Aider will take responsibility of and assess the situation before treating the casualty in keeping with the training they have received.
  • The First Aider will offer advice, suggestions for further treatment, or to seek professional medical advice if deemed necessary.
  • The First Aider will not provide a diagnosis.
  • The First Aiders will not provide or suggest medication (including pills, potions and lotions).
  • The First Aider will treat the matter as confidential, unless this is not in the best interest of the casualty.
  • The scene of the casualty will be tidied as soon as possible. Clinical waste (such as blood or vomit) will be disposed of hygienically.
  • The Accident Report book will be completed by the First Aider, or other responsible person involved, as soon as convenient. Tear-off slips containing personal details will be removed from the Accident Report Book and filed in a lockable cabinet at Reception. Records will be kept for at least 3 years.
  • In accordance with Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), the following incidents will be reported to the HSE: deaths, dangerous occurrences, major injuries, injuries resulting in over seven days of incapacitation of a worker and injuries to non-workers where they are taken directly from the scene to hospital for treatment (not including precautionary visit).

Information for Employees

Employees shall be informed of first-aid arrangements (to including names and locations of personnel and location of equipment) with:

  • Explanation during induction by line manager
  • Easy to read, clearly displayed posters through the Connect premises – reception, all classrooms, Student Resource Centre, Kitchen and staff room
  • Any changes to be notified via email and/or addressed in bi-weekly staff meetings
  • (Reference - http://www.hse.gov.uk/pubns/priced/l74.pdf - Guidance 4)

Information for Students

Students shall be informed of first-aid arrangements (to include names and locations of personnel and location of equipment) with:

  • Explanation during induction by Academic Team
  • Easy to read, clearly displayed posters in: reception, all classrooms, Student Lounge, kitchen and staff room
  • Notification in Student Handbook

Revision of policy

This policy is to be reviewed annually, prior to the summer peak season, when there is a change in personnel or 6 months before the current First Aiders’ certificates are due to expire, whichever occurs first.

Privacy Notice

Connect English Academy (we, us, our) are committed to protecting and respecting your privacy.

This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.connect-english.co.uk (our Site) you are accepting and consenting to thepractices described in this notice.

Important information and who we are

Controller

For the purposes of the Data Protection Act, and the General Data Protection Regulation ((EU) 2016/679), the data controller is Connect English Academy Ltd, First Floor, 26-28 Churchill Way, Cardiff, CF10 2Dy, Wales, UK.

We do not sell, share or transfer personal information except as set out in this privacy notice.

We use up-to-date industry procedures to keep personal information as safe and secure as possible and to protect against loss, unauthorised disclosure or access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorisedaccess.

Contact details

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to the Management Team, at Connect English Academy, or email: info@connect-english.co.uk.

Changes to the privacy notice and your duty to inform us of changes

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-party links

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

It is not necessary for you to register with us in order to access this Site. However, we may collect, use, store and transfer some information from interactive features such as contact and registration forms and online surveys, which may include different kinds of personal data about you:

  • Identity Dataincludes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Dataincludes your UK and oversees address, email address and telephone numbers.
  • Financial Dataincludes bank account and payment card details.
  • Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
  • Profile Dataincludes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Dataincludes information about how you use our Site, products and services.

We also collect, use and share Aggregated Datasuch as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does notdirectly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic andbiometric data), nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide whenyou:

  • apply for our products or services;
  • create an account on our Site;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions.As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Other sources.We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

To perform the contract we are about to enter into or have entered into with you, and to provide you with the information, products and services that you request from us.

To notify you about changes to our service.

To ensure that content from our Site is presented in the most effective manner for you and your computer.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity

(b) Contact

(i) Performance of a contract with you

To process and deliver your order including:

Manage payments, fees and charges;

Collect and recover money owed to us.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(i) Performance of a contract with you

(ii) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy notice;

Asking you to leave a review or take a survey.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(i) Performance of a contract with you

(ii) Necessary to comply with a legal obligation

(iii) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(i) Performance of a contract with you

(ii) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity

(b) Contact

(c) Technical

(i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(ii) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(i) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences.

(a) Technical

(b) Usage

(i) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(i) Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

We may use the information you have provided to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.

Opting out

You can ask us to stop sending you marketing messages at any time by email us at info@connect-english.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Site may become inaccessible or not function properly.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

Our Site sets cookies which remain on your computer or device for differing times. Some expire at the end of each session and some remain for longer so that when you return to our Site, you will have a better user experience.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Cambridge University Press, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

International transfers

The data that we collect from you may be transferred to, and stored at, a location outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers or those of our service providers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal information for?

  • We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
  • We will normally store your information for at least one year following the last recorded transaction or interaction between us.


Your legal rights

You have the right to ask us to correct any incorrect personal information we store about you, to delete personal information, or otherwise restrict our processing, or to receive an electronic copy of the personal information you provided to us.

To ask for a copy of the information we hold, or to ask us to correct or otherwise alter our current processing, please email us at info@connect-english.co.uk.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you are not happy with the way your information is being handled, or with the response received from us, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) at Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

Prevent Policy And Procedures

  1. Policy statement

  2. Prevent is the government strategy to stop people becoming involved in violent extremism and/or in supporting terrorism.

    Connect English Academy (‘Connect’/‘the academy’) understands its responsibilities under the Counter Terrorism & Security Act 2015 as an English language provider to prevent people of all ages being radicalised or drawn into terrorism and seeks to meet its obligations in the ways shown below, after setting the context.

    This policy should be read in conjunction with the academy’s Safeguarding policy and procedures(see separate document).

    This policy has the following aims:

    • To explain the academy’s commitment toPrevent.
    • To set out the academy’s Prevent policy andprocedures.
    • To explain how the academy will help to uphold and promote core British values at all times.
    • To provide a clear procedure to be implemented in the event ofconcerns.
    • To ensure that everyone is protected from potentialradicalisation.

    The academy recognises that all members of staff, homestay providers, and students havea responsibility to uphold the principles and aims of thispolicy.

  3. Context

  4. Connect English Academy accepts students aged 16+ throughout the year andfrom many different countries around the world. The academy has always promoted a multi- culturalenvironmentwhererespectforandtoleranceofotherbeliefsisrequired.Theacademy is located in the city centre ofCardiff.

  5. Prevent duty leadership and responsibilities

  6. Monika Morgans, the managing director, is responsible for ensuring that the academy’s Prevent duty is met by all stakeholders.

    Lorraine Gardner, the academy’s Designated Safeguarding Lead (DSL) and Prevent lead, is responsible for the Prevent risk assessment, action plan and policy.

    Their duties are to ensure delivery of an effective risk assessment and action plan, and policy as outlined here.

    Their contact details are:

    Monika Morgans: info@connect-english.co.uk/ +44(0)2920 232 111

    Lorraine Gardner: +44(0)2920232111

  7. Risk assessment of current situation and action plan for future

  8. A risk assessment and action plan has been produced showing what is already being done and what still needs to be done (please see separate document); it will be reviewed and updated at least annually, or more regularly if necessary.

  9. Working with local partners

  10. The academy is committed to maintaining a positive and open communication channel with the police and relevant local authorities.

    The academy’s current point of contacts are:

    • Prevent Team, Cardiff Bay Police Station, James St, Cardiff, CF105EW

    Phone: 029 2022 2111

    Email: prevent@south-wales.pnn.police.uk

    • Carl Davies – Home Office Prevent Co-ordinator forWales

    Phone: 07742 931475

    Email: carl.davies@cardiff.gov.uk

    • Barrie Phillips – Higher Education and Further Education Prevent Lead forWales

    Phone: 07811 980031 / 07800 711318

    Email: barrie.phillips@cardiff.gov.uk

    The academy is also committed to working with other local English language and education providers to share information and best practice as appropriate.

  11. Key terminology

  12. Radicalisation: The act or process of making a person more radical or favouring of extreme offundamentalchangesinpolitical,economicorsocialconditions,institutionsorhabitsofthe mind.

    Extremism: Holding extreme political or religious views which may deny rights to any group orindividual.Itcanrefertoarangeofviews,suchasracism,homophobia,right-wingideology, aswellasanyreligiousextremism.Extremismcanbeexpressedinvocaloractive opposition tocoreBritishvalues,andmayincludecallsforthedeathofmembersofthegovernment,and the armed forces, whether in this country oroverseas.

    Core British values: The values that should be encouraged, promoted, upheld, and exemplified by all members of the academy. The values are:

    • Democracy
    • The rule oflaw
    • Individualliberty
    • Respectful tolerance of difference faiths orbeliefs

    Prevent duty also includes an expectation that staff, students and homestay providers will be encouraged to respect other people with particular regard to the protected characteristics set out in The Equality Act 2010. These are:

    • Age
    • Disability
    • Sex
    • Race
    • Religion orbelief
    • Gender reassignment
    • Marriage
    • Civilpartnership
    • Pregnancy andmaternity

    Prevention: Inthecontextofthispolicy,preventionmeansreducingoreliminatingtheriskof individuals becoming involved in terrorism. Prevent involves the identification and referral of thosesusceptibletoviolentextremismintoappropriateinterventions.Theseinterventionsaim to divert the susceptible from embarking down the path toradicalisation.

  13. Understanding the risk of extremism

  14. It is important to understand that extremism is not isolated to any specific type of person or nationality; e.g. a student from Europe could be as easily radicalised as a student from the Middle East.

    Extremist views may be held by students, staff members, group leaders, or homestay providers.

    A person may arrive at the academy already holding extremist views, or they may be influenced by a range of factors during their stay in the UK.

    These factors may include:

    • Global events
    • Local events
    • Peerpressure
    • Media
    • Family views
    • Extremist materials via hardcopies oronline
    • Inspirationalspeakers
    • Friends or relatives beingharmed
    • Social networks

    Peoplewhoarevulnerablearemorelikelytobeinfluenced.Theirvulnerabilitycouldstemfrom a range of causes, suchas:

    • Loss of identity or sense ofbelonging
    • Isolation
    • Exclusion
    • Mental healthproblems
    • Sense ofinjustices
    • Victim of hate crime ordiscrimination
    • Bereavement
  15. Ways to counter act risk

  16. Although risk can never be eliminated, there are many ways in which we can reduce the risk ofpeoplebeingradicalised,andhelptoprotectandpreventpeoplefromextremism.Someof the ways to counteract risksare:

    • To promote a safe and supportive international environment via clear expectations of accepted behaviours and those, including radicalisation and extremism, that will not be tolerated. Rules about acceptable behaviour are listed in the following documents: Student’s handbook, Staff handbook,and Safeguardingpolicy.
    • Uphold and exemplify core British values through information given to students, notices displayed around the school, examples set to students by staff and homestay providers, and via classes and discussions that include topics about British culture, traditions, and beliefs.
    • Where possible, help students and staff to develop critical awareness and thought to counter accepting extremism without question, especially of onlinematerial.
    • Challenge radical or extremist views in any context, formal or informal, following stated procedures and reportingduties.
    • Be ready to react when local, national, or international events cause upset; being aware of the likelihood of conflicting feelings being expressed, and alert to potential acts of recrimination.
    • Have strong filters on IT equipment and clear rules on accessing extremist websites, as well as the use of social networks to exchange extremistviews.
    • Ensure that extremist speakers do not use the premises to distribute material orexpound views.
    • Gettoknowstudents,theirhomecircumstancesandfriendshipgroups.Throughknowing students well, it is easier to spot changes inbehaviour
    • Staff and homestay providers to be observant and vigilant in noticing any signs of radical or extremist behaviour.
    • All staff and homestay providers to work hard to support any students identified as vulnerable and atrisk
  17. Signs that may cause concern

  18. There are often no obvious signs of extremism. Signs that are often cited as signs of extremism will often be signs of perfectly normal behaviour, particularly among youngpeople in their late teens and early20s.

    Therearesomephysicalsignsthatwouldindicateconcernsrelatingtoextremismsuchasthe tattoos that far-right organisation supporters will sometimes display. You are not expected to be aware of the significance of tattoos but if you are worried about someone with what youthink may be far right tattoos you should pass the details on to the Prevent lead (Lorraine Garnder).

    Any concerns you have will usually be similar to other safeguarding concerns. These may include changes in the student’s behaviour; you should use your judgement to decide when these are worrying and when they are within the normal range.

    Concerns might include:

    • Students talking about exposure to extremist materials or views outside the academy (in theeventofthishappening,informationmustbesharedwiththerelevantlocalauthorities).
    • Changing attitude, e.g. intolerant of differences / having a closedmind.
    • Changing behaviour, e.g. becoming isolated.
    • Falling standard of work, poor attendance,disengagement.
    • Asking questions about topics connected toextremism.
    • Offering opinions that appear to have come from extremistideologies.
    • Attempting to impose one’s own views / beliefs onothers.
    • Using extremist vocabulary to exclude others or incite violence.
    • Accessing extremist material online or via social networksites.
    • Performing overt new religiouspractices.
    • Possessing drawings or posters showing extremist ideology / views /symbols.
    • Voicing concerns aboutanyone.

    It should be noted that individuals taking their religion more seriously, choosing to grow a beard or wearing a headscarf for religious reasons are NOT signs of extremism.

    Any concerns about under 18 students should also be dealt with in line with the academy’s Safeguarding policyand procedures.

  19. How and when to react to concerns

  20. Please always dial 999 in an emergency.

    The 999 number should be used in emergency situations, so when a crime is in progress, a suspect is nearby, there is danger to life or when violence is threatened.

    Any other concern or incident, however small, must be reported to the Managing Director (Monika Morgans) or the Prevent Lead (Lorraine Gardner) immediately.

    Monika Morgans: info@connect-english.co.uk/ +44(0)2920 232 111

    Lorraine Gardner:+44(0)2920 232 111

    Any report will be dealt with sensitively and in confidence.

  21. Training and awareness

  22. The aim of the academy’s training is to provide more knowledge and confidence to all.

    Staff training and awareness

    Staff training is provided through documents, face-to-face and online training (provided through https://www.foundationonline.org.uk).

    This training aims to help staff to:

    1. understand the context and expectations ofPrevent;
    2. understand their duty to implement the academy’s Preventpolicy;
    3. understand the terminology and the risks associated with radicalisation andextremism;
    4. understand how to identify and support vulnerablestudents;
    5. understand the ways the academy will counteractrisks;
    6. recognise the signs that may causeconcerns;
    7. know the lead Prevent person and the procedure for communicatingconcerns;
    8. know the importance of their own behaviour and professionalism in being (i) exemplars of British values, and (ii) not discussing inflammatory subjects withstudents.
    9. Homestay provider training

      Homestay provider training is provided through information in documents (such as Information for homestay providers) and online training

      ( https://www.foundationonline.org.uk)

      Training materials are adapted to ensure that homestay provides understand the sections of policy that they need to be aware of, especially (i) how to identify and support vulnerable students, and (ii) how to recognise the signs that may cause concerns, and (iii) how to report a concern.

      Students and group leaders

      Student and group leaders must be made aware of the key parts of this policy:

      1. understanding terminology;
      2. the importance of maintaining a supportive and tolerant society within theacademy;
      3. what core British values are and why they are consideredimportant;
      4. the academy’s rules, particularly those regarding acceptable behaviour, ande-safety;
      5. that they must report any concerns or incidents, and the procedure to do so.

E-safety and Acceptable use of Information and Communications Technology (ICT) Policy

Context

Connect English Academy (‘Connect’, ‘the academy’) recognises that the use of internet technologies and communication devices are now seen as a vital life skill and that the use of these can help to enhance communication and the sharing of information. However, Connect is also aware that the use of these technologies has the potential to challenge the definitions and boundaries of learning and teaching.

Current internet technologies and electronic communications used by students and staff, inside and outside of the academy include:

  • Internet websites
  • Virtual learning environments (VLE)
  • Instant messaging (IM)
  • Social networking sites (such as Facebook, Twitter)
  • E-mails
  • Blogs
  • Video broadcasting sites
  • Chat rooms
  • Gaming sites
  • Music downloading sites
  • Smart phones with e-mail and web applications
  • Tablets and mobile phones with digital cameras

Connect recognises that all of these have the potential to help improve standards of learning and teaching, but may equally present challenges to both students and staff in terms of keeping safe. The challenges include:

  • Exposure to inappropriate or illegal material
  • Cyberbullying via websites, social media or mobile phones
  • Identity theft or invasion of privacy
  • Downloading copyrighted materials
  • Exposure to inappropriate advertising or financial scams (phising)
  • Safeguarding issues, such as grooming of under 18s or vulnerable adults
  • Other illegal activities

Key terminology

Acceptable Use Policy (AUP)

An acceptable use policy (AUP) is document that outlines a set of rules to be followed by all users of a set of computing resources, which could be a computer network, website or computer system. An AUP clearly states what the user is and is now allowed to do with these resources.

Child Protection

This is part of safeguarding and promoting welfare. This refers to the activity that is undertaken to protect specific children who are suffering, or likely to suffer significant harm.

Children and under 18s

The Children Act 1989 states the legal definition of a ‘child’ as a ‘person under the age of 18’. The terms ‘child’ and ‘under 18-year-old’ are used interchangeably in this policy.

Cyberbullying

This refers to bullying that takes place using electronic technology. Electronic technology includes devices and equipment such as mobile phones, computers and tablets, as well as communication tools including social media sites, text messages, chat and websites.

Examples of cyberbullying include mean text messages or emails, rumours sent by texts, email or social networking sites, embarrassing pictures or videos posted on websites, and the creation of fake profiles.

Designated Safeguarding Lead (DSL)

This person takes overall responsibility for safeguarding at the academy. The DSL at Connect is Monika Morgans (info@connect-english.co.uk).

Duty of care

This is the legal obligation to safeguard others from harm while they are in your care, using your services or associated with your activities.

Digital media

Digital media is digitized content that can be transmitted over the internet or computer networks. This can include text, audio, video, and graphics.

E-safety

The safe and responsible use of internet technology and other electronic communications.

Information and Communications Technology (ICT)

ICT (information and communications technology - or technologies) is an umbrella term that includes any communication device or application, encompassing: radio, television, cellular phones, computer and network hardware and software, satellite systems and so on.

Stakeholders

All students, staff, volunteers, visitors and contractors who attend, visit or provide services for Connect.

Safeguarding

Safeguarding and promoting the welfare of children is:

  • protecting children from harm
  • protecting children from that which is not in their best interests
  • preventing the impairment of children’s health and safety

Social media

Websites and applications that enable users to create and share content or to participate in social networking.

Social networking

The use of websites and other internet services to communicate with other people and make friends.

Vulnerable adults

A person can be considered to be ‘vulnerable’ if they are “in need of community care services by reason of mental or other disability, age or illness; and is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation” (Lord Chancellor’s Department, 1997). This definition of adult covers all people over 18 years of age.

Policy statement

This policy relates to all stakeholders of Connect (including students, staff, volunteers, visitors and contractors) who have access to, and are users of internet technologies and electronic communications both in and out of Connect venues where actions relate to Connect activities, or the use of Connect ICT systems.

Connect seeks to maximize the educational benefit that can be obtained by internet technologies and electronic communication devices, while at the same time minimising any associated risks.

Safety and well-being is the collective and individual responsibility of all its stakeholders.

Connect aims to ensure that regardless of age, gender, race, ethnicity, religion or beliefs, sexual orientation, socio-economic background, all stakeholders have a positive and safe learning, teaching and working experience.

As part of this policy, Connect will:

  • Promote and prioritise e-safety for all members.
  • Establish an understanding of roles and responsibilities in respect of e-safety and ensure everyone is provided with appropriate learning opportunities to recognise, identify and respond to any concerns regarding to the use of internet technologies and other electronic communications.
  • Ensure that appropriate action is taken in the event of any e-safety concerns and support is provides to individual(s) who raise or disclose the concern.
  • Ensure that confidential, detailed and accurate records of all e-safety concerns are maintained and securely stored.
  • Ensure that robust e-safety arrangements and AUPs are in operation. This policy is available to all stakeholders of Connect.

Failure to comply with this policy and procedures will be addressed immediately and may ultimately result in instant dismissal or exclusion from Connect.

Associated policies

This policy operates in conjunction with Connect’s Safeguarding policy and procedures and Prevent policy and procedures.

Policy review

This policy will be reviewed once a year in October, or following any updates in relevant policies or procedures. Feedback is collected bi-annually from all stakeholders. The policy will be reviewed by the DSL and the Managing Director.

Roles and responsibilities

Managing director (Monika Morgans)

  • The managing director has a duty of care for ensuring the safety and e-safety of all stakeholders, though the day-to-day responsibility for e-safety will be delegated to the e- safety coordinator.
  • The managing director and least another member of the management team should be aware of the procedures to be followed in the event of a serious e-safety allegation being made against a member of staff.
  • The managing director is responsible for ensuring that the e-safety coordinators and other relevant staff receive suitable training to enable them to carry out their e-safety roles and to train other colleagues.
  • The managing director will ensure that there is a system in place to allow for monitoring and support of those who carry out the e-safety monitoring role.

E-safety coordinator (Patrick Rushforth)

The role of the e-safety coordinator includes:

  • Leading e-safety training and awareness-raising sessions.
  • Having day-to-day responsibility for e-safety issues, as well as reviewing the academy’s e-safety policies.
  • Ensuring that all staff are aware of the procedures that need to be followed in the event of an e-safety incident.
  • Making sure that they have an up-to-date awareness of e-safety matters and of current e- safety policy and practices

Staff

All teaching and non-teaching staff (volunteers, suppliers, contractors and temporary staff) are responsible for supporting safe behaviour and e-safety procedures.

All staff should be familiar with this policy, as well as their relevance to Connect’s code of conduct and safeguarding and prevent policies.

As well as the above, all staff should do the following:

  • Participate in any e-safety training and awareness-raising sessions.
  • Ensure they have read, understood and signed the E-safety and acceptable use of ICT policy.
  • Act in accordance with this policy.
  • Report any suspected misuse or problems to Managing Director or E-safety coordinator.
  • Refrain from making negative comments about Connect and its stakeholders via any electronic communications (e.g. social networking sites, messaging apps).
  • Ensure that any electronic communications with other stakeholders are on a professional level and adhere to the policy.
  • Help to educate students in keeping safe, especially under 18s and vulnerable groups.
  • Help students to understand and follow the e-safety and acceptable use of ICT policies and procedures.
  • Monitor students’ use of electronic devices, such as mobile phone and tablets, in lessons and other relevant activities, and implement current policies with regards to these devices.

Students

  • All students are responsible for using Connect’s ICT systems in accordance with this policy.
  • All students need to understand the importance of reporting abuse, misuse or access to inappropriate materials and know how to do so.
  • All students need to understand the importance of adopting good e-safety practice when using electronic communications outside of Connect, and realise that this policy covers their actions outside the academy if related to their membership of the academy.

Code of conduct

This code of conduct:

  • Assists stakeholders in working safely and responsibly, and monitor their own standards and practice
  • Sets clear expectations of behavior and codes of practice relevant to e-safety and use of ICT.
  • Supports stakeholders by giving a clear message that unlawful or unsafe behavior is unacceptable and that, where appropriate, disciplinary or legal action will be taken.

Managing internet access and information systems

To ensure that Connect’s information systems remain safe:

  • The security of Connect’s information systems will be reviewed regularly.
  • Virus protection will be updated regularly.
  • Firewalls and filters will be used at all times.
  • Unapproved software will not be allowed in work areas or attached to emails. Connect’s equipment and systems must not be used:
  • For any form of harassment of individuals, including colleagues, clients and other stakeholders.
  • To download, access, record and / or store material that could be considered racist, sexist, homophobic, or likely to be in contravention of discrimination, bullying or harassment legislation.
  • To access adult or pornographic material.
  • To upload any inappropriate content (including copyrighted or indecent material).
  • To install any programs without the prior permission of a designated member of staff.
  • To attempt to circumvent or ‘hack’ any systems.

Connect reserves right to view all material (including emails of a personal nature) stored in its computer system.

Email

  • Students and staff must immediately tell a designated member of staff if they receive an offensive email.
  • Staff will only use official work-provided email accounts to communicate with other stakeholders (including students, parents /carers, and third parties).
  • Emails must not be used to forward inappropriate messages or content to any individual.

Emerging technologies

  • Emerging technologies will be examined for educational benefit and a risk assessment will be carried out before use in Connect is allowed.

Filtering

  • Connect’s broadband access will include appropriate filtering.
  • If a student or a member of staff discovers an unsuitable site, the URL will be reported to the e-safety coordinator who will record the incident and escalate the concern as appropriate.
  • The e-safety coordinator will ensure that regular checks are made to ensure that the filtering methods selected are effective.

Mobile phones and personal devices (including laptops and tablets)

  • The use of mobile phones and other personal devices by students and staff in school will be decided by Connect.
  • Mobile phones and personal devices will not be used by students during lessons unless as part of an approved and directed curriculum-based activity with consent from a member of staff.
  • Electronic devices of all kinds that are brought into school are the responsibility of the user. The school accepts no responsibility for the loss, theft or damage of such items.
  • Staff and other stakeholder must not use their personal phones or devices to contact any students under 18.

Protecting personal data

  • Personal date will be recorded, process, transferred and made available according to the Date Protection Act 2018.

Published content and Connect’s website

The contact details on the website should be the school address, email and telephone number. Other stakeholder personal information will not be published.

  • The managing director will take overall editorial responsibility and ensure that content is accurate and appropriate.

Publishing images of students aged under 18

  • Photographs of students aged under 18 will be selected carefully and will not enable individual students to be identified.
  • The full names of students who are under 18 will not be used anywhere on the website or social media networks.
  • Written permission from parents or carers will be obtained before photographs of students aged under 18 are published on the website or on social media networks.
  • Written consent will be kept by Connect where the images of students aged under 18 are used for publicity purposes.

Social media and social networking

  • All students will be advised never to give out personal details of any kind which may identify them and/or location. Examples would include real name, address, mobile number, school attended, IM and email address.
  • All students and staff will be advised on security and privacy online and will be encouraged to set passwords, deny access to unknown individuals and to block unwanted communications.
  • All students and staff will be advised not to publish specific and detailed private thoughts, especially those that may be considered threatening, hurtful or defamatory.
  • Staff are required to not post entries that are publicly accessible, which contain negative references to the company, its staff, business activities, clients or products.
  • Staff must not conduct themselves in a way that is detrimental to the company.
  • Staff must take care not to allow their interaction on social networking websites to damage working relationships between member of staff and the company’s clients or third parties.
  • Staff must not ‘add’ any students aged under 18 to their personal social networks.
  • Concern regarding students’ use of social networking, social media, and personal publishing sites (in or out of Connect) will be raised with their parents / carers, particularly when concerning students underage use of sites.

Policy decisions

Authorising internet access

  • All students and staff will be asked to read and sign the relevant e-safety and acceptable use of ICT policy at their induction.
  • All visitors to Connect who require internet and/or ICT access will be asked to read and sign this policy before they are given access.

Assessing risks

  • Connect will take all reasonable precautions to ensure that users access only appropriate material. However, due to the international and connected nature of internet content, it is not possible to guarantee that access to unsuitable material will never appear on a computer that belongs to Connect. Connect cannot accept liability for the material access, or any consequences resulting from internet use.
  • The e-safety coordinator will regularly audit the use of ICT to establish if this policy is adequate and that the implementation of the policy is appropriate.

Responding to e-safety concerns and incidents

  • All Connect stakeholders will be informed about the procedure for reporting e-safety concerns (such as breaches of filtering, cyberbullying, downloading of illegal content, etc.).
  • The e-safety coordinator will record all reported incidents and actions taken using the academy’s incident form.
  • The DSL will be informed of any e-safety incidents involving safeguarding concerns and will be dealt with appropriately.
  • Connect will inform the parents or carers of under 18s of any incidents or concerns as and when required.
  • Any complaint about staff misuse must be referred to the Managing Director.
  • Any sanctions will be issued in accordance with Connect’s disciplinary procedures. Sanctions can include: interview and counselling by e-safety coordinator / teacher, informing parents or carers, and removal of access to internet for a period of time.
  • Where there is cause for concern that illegal activity has taken place, the police will be contacted.

Managing cyberbullying

  • Cyberbullying of any member of Connect will not be tolerated.
  • All incidents of cyberbullying need to be reported to the e-safety coordinator.
  • Any sanctions will be issued in accordance with Connect’s disciplinary procedures.

Communication policy

Informing students

  • All students will read and sign to show that they have read the policy at induction.
  • E-safety rules will be posted in all classrooms.
  • Safe and responsible use of the internet and technology will be reinforced across the curriculum.
  • Students will be informed that internet use will be monitored.
  • Particular attention to e-safety awareness will be given to students under 18 and students who are considered to be vulnerable.

Informing staff

  • All staff (including contractors, visitors and volunteers) will read and sign the policy on induction.
  • Staff will be made aware that internet use will be monitored and can be traced to the individual user.
  • Up-to-date and appropriate staff training in e-safety and acceptable use of ICT will be provided for all members of staff.
  • All staff will be made aware that their online conduct in and out of the academy could have an impact on their role and reputation within the academy. Civil, legal or disciplinary action could be taken if they are found to bring the academy into disrepute, or if something is felt to have undermined confidence in their professional abilities

SAFEGUARDING POLICY AND PROCEDURES

POLICY STATEMENT

A1. Context

Connect English Academy (‘Connect/ ‘the academy’) is an English language academy that specializes in small classes and flexible course schedules.

Connect is located in the centre of Cardiff and accepts students from 16 years of age, except during the summer course and/or closed group Junior Programmes when we accept students from 12 years of age upwards.

All regular year-round courses provide an adult-learning environment and so the academy is careful to make it clear via its publicity, and prior contact with agents and parents/guardians, that students aged 16 or 17 will not receive a junior course level of supervision, and that they will be in classes with students aged 18+. The academy requires that students and their parents/guardians consider this carefully before any 16 or 17-year-old enrolls on the course.

The academy recognizes its responsibility with respect to safeguarding the welfare of any child, vulnerable adult, and indeed all students that may be attending the academy, against abuse and believes that it is always unacceptable for any student to experience abuse of any kind.

The academy seeks to maintain a safe and supportive environment, and to ensure that all employees and homestay providers working with the academy accept and recognise their individual and shared responsibilities for safeguarding. The academy also recognises that it has a responsibility to protect staff from unfounded allegations of abuse.

A2. Key terminology

Children and under 18s

The Children Act 2004 states the legal definition of a child as a person under the age of 18 and the Health and Safety at Work Regulations 1999 defines the term children/child to apply to persons between birth and 16 years. Individuals of 16 and 17 years are young persons; anyone over the age of 18 is an adult. In this policy, the terms under 18s, children and child are used interchangeably.

Safeguarding

This is the action that is taken to promote the welfare of children, and to protect them from harm. It means caring for children appropriately and protecting them from that which is not in their best interests; it includes health and safety, child protection and pastoral care.

Child protection

This is a part of safeguarding and promoting welfare, and means protecting children from abuse. Child abuse can be defined as: ‘Child maltreatment, sometimes referred to as child abuse and neglect, includes all forms of physical and emotional ill-treatment, sexual abuse, neglect, and exploitation that results in actual or potential harm to the child’s health, development or dignity. Within this broad definition, five subtypes can be distinguished: physical abuse, sexual abuse, neglect and negligent treatment, emotional abuse and exploitation’ (World Health Organization, who.int).

Duty of Care

This the legal responsibility held by all adults who work with children, that they individually and collectively have a duty to look after them properly. Children depend on adults for their safety and well-being. All staff hold this responsibility.

Regulated activity

These are roles ‘involving responsibility for or substantial access to under 18s’ (Care of under 18s: Guidance for ELT Providers, gov.uk, 2019). This includes any position that has direct contact with children, or a position which manages staff who work with children.

Regulated activities include teaching, leisure programme supervision, and homestay provision when they are carried our frequently (once a week or more), intensively (four times or more in a 30-day period) or overnight.

Regulated activity also includes any activity of any kind carried out by an individual visiting a school frequently or intensively, or in connection with the school, and which gives the individual any opportunity to have unsupervised contact with children. Any person that is engaged in regulated activity must have an enhanced disclosure check.

Early help

Early help means providing support as soon as a problem emerges at any point in a child's life. (Working together to safeguard children, July 2018).

Safer recruitment

This refers to all recruitment procedures and practices which aim to prevent the appointment of people who are a risk to children.

Designated Safeguarding Lead (DSL) and Designated Safeguarding Staff (DSS)

The Designated Safeguarding Lead (DSL) is the person who takes overall responsibility for safeguarding and leading the team of all Designated Safeguarding Staff (DSS) and other staff members.

The Managing Director has overall responsibility for these staff, and for safeguarding policies and procedures.

  • Managing Director: Monika Morgans
  • Designated Safeguarding Lead (DSL): Lorraine Gardner

Please also refer to section A8. Roles and responsibilities for further details regarding the roles of the DSL.

Vulnerable adult

The definition of a vulnerable adult is a ‘person aged 18 years or over who may be in need of community care services by reason of their mental or other disability, their age or illness, and who is or who may be unable to take care of himself or herself, or is unable to protect him or herself against significant harm or exploitation’ (1997 Consultation ‘Who Decides?’ issued by the Lord Chancellor’s Department).

A3. Connect’s commitment to safeguarding

Connect is committed to the definition of safeguarding and promoting the welfare of children as defined in Working Together to Safeguard Children, July 2018. The academy believes that safeguarding is the individual and collective responsibility of everyone working in the academy. Our policy recognises that the welfare and interests of children, and vulnerable adults, are the top priority in all circumstances and is committed to ensuring its safeguarding practices reflect Accreditation UK requirements, as well as all legal obligations.

The academy’s aim is to prevent abusive behaviour in all forms. Disrespectful or abusive behaviour towards co-students or staff members will not be tolerated.

Connect is aware that some children, including disabled children and young people, or people of any age from ethnic minority communities, can be particularly vulnerable to abuse and we accept the responsibility for taking reasonable and appropriate steps to ensure their welfare.

A4. Under 18s and principles of entitlement

Connect’s safeguarding policy aims to ensure that, regardless of age, gender, race, ethnicity, religion or beliefs, sexual orientation, or socio-economic background, all students have a positive and enjoyable experience in a safe and child-centred environment. All children have an entitlement to be protected.

Under 18s principles of entitlement

  1. All children have rights. No one can take away a child’s right to be safe.
    1. All children have the right to say ‘No’ if any person tries to do something to them which they feel is wrong.
      1. All children must feel they can tell an adult of any incident that frightens, confuses them or makes them unhappy.
      2. All children must know that if they go to an adult for help, they will be believed and supported.
      3. All children have the right to be treated with respect and to be safeguarded from harm.

A5. Adult responsibilities

All staff and any other adults involved with Connect are expected to accept and recognise their safeguarding responsibilities.

All adults must:

  1. Understand, follow and implement this safeguarding policy and its procedures.
  2. Safeguard the welfare of all under 18s and vulnerable adults at Connect.
  3. Continually develop their awareness of any safeguarding issues through the sharing of good practice, and the completion of regular safeguarding training.
  4. Follow child protection guidelines and accepted procedures.
  5. Provide children with expected codes of behaviour and help children to understand what those are when necessary.
  6. Report any concerns about any safeguarding and/or child protection issues with the relevant member of staff, and/or relevant outside organisations.
  7. Ensure that all appropriate action is taken in the event of any safeguarding concerns or incidents, and appropriate support is provided to the individual(s) who discloses the concern.
  8. Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored.
  9. Prevent the unemployment of any unsuitable individuals.
  10. Ensure that continuous safeguarding arrangements and procedures are in operation at all times.
  11. Be vigilant at all times to any safeguarding and child protection issues.

A6. Associated policies and documents

Connect has additional policies and documents that are associated with the safeguarding of children, and should be read in conjunction with this policy. These policies and documents include:

  1. E-safety and acceptable use of ICT policy
  2. Prevent policy and procedures / Prevent risk assessment
  3. Information for homestay providers
  4. Guidelines for students in homestay
  5. Health and safety policy
  6. First aid policy
  7. Fire safety risk assessment
  8. Student handbook
  9. Student code of conduct
  10. Staff handbook
  11. Connect risk assessments (on premises and off site)
  12. Safer recruitment and induction policy

A7. Policy review and availability

Connect is committed to reviewing its safeguarding policy and procedures at least every 12 months, or sooner if there are relevant changes to the law, or to the courses offered, and in the interests of best practice. The policy is written by the DSL/Managing Director. However, all staff are welcome to comment and to make suggestions for the policy at any time.

A full copy of this policy, and its updates, is given to every member of staff recruited at Connect. Each member of staff is asked to sign a declaration to confirm that they have received and read the policy, and are aware of the academy’s procedures that are in place to help them to understand and carry out their safeguarding roles and responsibilities.

A full copy of this policy is also available on the Connect’s public website: www.connect-english.co.uk

Group-specific safeguarding procedures are also available for the following: homestay providers, group leaders, and under 18s.

A8. Roles and responsibilities

All staff and students at Connect are required to take shared responsibility for the safeguarding and safety of any children and vulnerable adults. All staff and students must be aware of and abide by Connect’s code of conduct. This includes all staff and students being aware of safeguarding issues and knowing how to raise concerns or issues with the relevant member of staff.

All Connect staff are in a position of trust, in particular those staff who teach, support, and guide, or in any way interact with students, children and adults in need of safeguarding. All staff should be aware of this and act accordingly at all times.

The Managing Director has overall accountability and strategic responsibility for safeguarding vulnerable groups within Connect.

The Designated Safeguarding Lead (DSL) has operational responsibility for safeguarding vulnerable groups within Connect and carries out a leadership and coordination role.

The DSL’s job roles and responsibilities include the following:

  • referring cases of suspected abuse to the local authority children’s social care as required;
  • supporting staff who make referrals to local authority children’s social care;
  • referring cases to the Channel programme, which is a confidential safeguarding programme that supports people who are vulnerable to radicalisation;
  • supporting staff who make referrals to the Channel programme;
  • referring cases where a person is dismissed or left due to risk/harm to a child to the Disclosure and Barring Service (DBS) as required;
  • referring cases where a crime may have been committed to the police as required;
  • liaise with the Managing Director regarding ongoing enquiries under section 47 of the Children Act 1989 and police investigations;
  • as required, liaising with the “case manager” and the designated officer(s) at the local authority for child protection concerns (in all cases which concern a staff member);
  • liaising with staff on matters of safety and safeguarding and deciding whether to make a referral by liaising with relevant agencies;
  • acting as a source of support, advice and expertise for staff;
  • ensuring each member of staff has access to and understands the academy’s child protection policy and procedures, especially new and part time staff;
  • is alert to the specific needs of children in need, those with special educational needs and young carers
  • is able to keep detailed, accurate, secure written record of concerns and referrals;
  • understands and supports the school or college with regards to the requirements of the Prevent duty and are able to provide advice and support to staff on protecting children from the risk of radicalisation;
  • obtains access to resources and attend any relevant or refresher training courses;
  • encourages a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures the academy may put in place to protect them.
  • ensures the academy’s child protection policies are known, understood and used appropriately;
  • ensures the academy’s child protection policy is reviewed annually (as a minimum) and the procedures and implementation are updated and reviewed regularly, and work with governing bodies or proprietors regarding this;
  • ensures the child protection policy is available publicly and parents/guardians are aware of the fact that referrals about suspected abuse or neglect may be made and the role of the academy in this;
  • links with the local LSCB to make sure staff are aware of training opportunities and the latest local policies on safeguarding.

The DSL/Managing Director will be available at all times the academy is open for staff to discuss concerns and will always be contactable via the academy’s 24-hour emergency phone number which is given out on arrival.

A9. The involvement of under 18s in safeguarding policy review

Connect ensures that its safeguarding policy and procedures are made clear to all students at the time of induction.

The under 18s code of conduct is explained to all relevant students with the reasons why they have to follow special rules and regulations.

Weekly forums are held with all under 18 students to discuss any concerns or issues, but also for staff to receive feedback from the students about the academy’s safeguarding policies and procedures. All comments are recorded and reviewed by the DSL/Managing Director and action is taken when appropriate.

Furthermore, topics regarding safeguarding issues, such as internet safety and cyberbullying, are regularly introduced into lessons for all students to discuss and to provide feedback on.

A10. Policy references

The following documents and policies have been consulted in writing this policy:

  1. The Children Act, 1989
  2. The Children Act, 2004
  3. Working Together to Safeguard Children, 2018
  4. Accreditation UK Handbook, 2016-17
  5. Accreditation UK “Care of Under 18s: Guidance for ELT Providers, January 2016
  6. The Independent School Inspectorate’s framework, 2015
  7. Protecting from Radicalisation: The Prevent Duty, 2015
  1. Keeping Children Safe in Education, updated - 19 September 2018
  2. Keeping Children Safe in Education 2016, Update Information, Andrew Hall, Safeguarding in Schools
  1. Safeguarding Policy Review Checklist (September 2016 v.2.0), Andrew Hall, Success in School.

A11. Useful contact numbers

Cardiff and Vale Local Safeguarding Children Board

http://www.cardiffandvalelscb.co.uk 029 2233 0880

029 2233 0883

NSPCC (National Society for the Prevention of Cruelty to Children)

https:// www.nspcc.org.uk 0808 800 5000

NSPCC whistleblowing helpline

This is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285; the line is available from 8:00 AM to 8:00 PM, Monday to Friday.

CODE OF CONDUCT

B1. Overview and principles

Connect’s priority is to establish a safe and trusting environment for all our staff and students. This helps to ensure that all under 18s feel secure and happy, and also reduces the risk of any actions by adult members of staff being misconstrued.

This code of conduct:

  1. Assists staff working with under 18s to work safely and responsibly, and to monitor their own standards of practice.
  2. Sets clear expectations of behaviour and codes of practice.
  3. Makes clear that Connect does not tolerate unlawful or unsafe behaviour and will use disciplinary, or legal action, where appropriate.

B2. Position of trust

As a result of their knowledge, position and their authority invested in their role, all adults working in schools are in positions of trust in relation to under 18 year olds.

This means that all adult staff members should:

  1. Not use their position to gain access to information for their own or others’ advantage.
  2. Not use their position to imitate, bully, humiliate, threaten, coerce or undermine under 18s.
  3. Not use their status and standing to form or promote relationships which are of a sexual nature, or which may become so. Any person in a position of trust who engages in any sexual activity with a child is breaking the law, even if the child is above the legal age of consent of 16 (Sexual Offences Act 2003).

B3. Setting standards

We expect the best possible conduct from our staff when working with under 18s.

All staff must:

  1. Be excellent role models at all times to under 18s.
  2. Consider at all times how their actions will be interpreted by under 18s.
  3. Be aware, approachable and understanding.
  4. Always maintain appropriate professional boundaries and avoid behaviour which might be misinterpreted by others.
  5. Report to the DSL/Managing Director anything that might be have been done or said accidentally (by themselves or another member of staff) which may have been misconstrued by an under 18-year-old or may turn into an allegation (e.g. if the under 18- year-old seems to have become infatuated with a member of staff).
  6. Raise all concerns or incidents to the DSL/Managing Director. This is a legal obligation. Any staff member who raises a concern, or makes an allegation, can do so without fear of being penalised and can be assured that any information will be treated as confidential.
  7. Accept that if a colleague raises such a concern they have good reason for having done so, and should be respected and listened to.

B4. Adult interaction with under 18s

Connect staff members will abide by the following rules when interacting with under 18s.

All staff must ALWAYS:

  1. Work in an open environment. Avoid private or out-of-sight locations and encourage open communication.
  2. Speak clearly, without whispering so that students do not need to come close to hear.
  3. Avoid spending time with individual students away from others.
  4. Treat all students, regardless of race, disability, religion or belief, gender, or sexual orientation equally and with respect and dignity.
  5. Ensure the student’s welfare comes first.
  6. Be aware of the impact of proxemics (know where and how to place your body and maintain safe and appropriate distances).
  7. Maintain professional boundaries (e.g. using a specific mobile number or email address for work purposes)
  8. Present as an exemplary role model by not smoking or drinking alcohol, swearing, allowing suggestive conversations or jokes when in the company of a child.
  9. Seek to be enthusiastic and constructive when giving feedback rather than making negative or critical remarks.
  10. Record any injury that occurs and seek attention from a qualified First Aider. 11. Record any incident of concern involving a student’s welfare.

All staff must NEVER:

  1. Allow allegations made by a child to go unrecorded or not acted upon (this applies to any form of abuse or bullying).
  2. Challenge or dispute with a child who is making an allegation.
  3. Lock doors, cover windows or use ‘Do Not Disturb’ signs.
  4. Impose humiliating or power-based punishments on a student, or reduce a child to tears.
  5. Engage in rough, physical or sexually-provocative games, including horseplay.
  6. Allow or engage in any form of inappropriate touching.
  7. Share a bedroom with a child.
  8. Allow children to use inappropriate language unchallenged.
  9. Make sexually-suggestive comments to a child, even in fun.
  10. Do things of a personal or intimate nature for children or disabled young people that they can do for themselves.
  11. Invite or allow children to stay with you at your home unsupervised. 11. ‘Friend’ a child on their social media or yours.
  12. Take photographs or videos of children unless written and signed consent has been obtained from the parent / guardian.
  13. Seek physical contact of any kind.
  14. Give a child a lift in your car alone.

B5. Appropriate appearance

Adults should dress in ways that are appropriate to their role and this may need to be different to how they dress when not at work. Tight, short or revealing clothing is not appropriate for men or women.

Adult staff members who work with under 18s should ensure they are dressed appropriately for the tasks and the work they undertake. Those who dress in a manner could be considered as inappropriate could render themselves vulnerable to criticism or allegations.

This means that all staff members should:

  1. Wear clothing that is appropriate to their role.
  2. Wear clothing that is not likely to be viewed as offensive, revealing, or sexually proactive.
  3. Wear clothing that does not distract, cause embarrassment or give rise to misunderstanding.
  4. Wear clothing that is compliant with professional standards.

B6. Communication with under 18s (including the use of technology and social media)

Communication with under 18s both in the ‘real’ world and through web-based and telecommunication interactions should only take place within explicit professional boundaries. This communication is not only face-to-face, but includes the use of computers, tablets, phones, texts, e-mails, instant messages, social media such as Facebook and Twitter, chat- rooms, forums, blogs, websites, gaming sites, digital cameras, videos, web-cams and other hand-held devices.

This means that all staff should:

  1. Not seek to communicate/make contact or respond to contact with pupils outside the purposes of their work.
  2. Not give out their personal contact details to under 18s; for example, their e-mail address, home or mobile numbers, or details of any social media or digital identities.
  3. Immediately inform the DSL/DSS if an under 18-year-old attempts to contact or correspond with them via their personal contact details, including via social media networks. The adult should not respond to the contact. The child should be firmly and politely informed that this is not acceptable (the DSL or DSS will tell the child).
  4. Follow Connect’s E-safety and acceptable use of ICT policy.
  5. Ensure that their use of technologies and social media could not bring Connect into disrepute.

B7. Homestay providers

Homestay providers are given specific guidelines on how to deal with under 18s, covering issues such as curfews, alcohol, and internet restrictions.

All adult household members, and regular visitors, must have an up-to-date enhanced DBS certificate which must be checked by the housing officer.

For full guidance, please refer to the booklet Information for homestay providers.

B8. Transporting under 18s

If a staff member is required to transport an under 18-year-old as part of their work then the need for this has to be agreed by the DSL, and a risk assessment must be carried out to manage any known risks.

Staff should never offer to transport pupils outside of their normal working duties, other than in an emergency or where not doing so would mean the child may be at risk. In these rare circumstances, the matter should be immediately recorded and reported to the DSL/Managing Director, preferably in advance.

Wherever possible and practicable it is advisable that transport is undertaken other than in private vehicles and with at least one adult additional to the driver acting as an escort.

Staff must make sure that their behaviour and all arrangements for transporting the child ensure vehicle, passenger and driver safety. This includes having proper and appropriate insurance for the type of vehicle being driven.

B9. Whistleblowing

Connect expects all its staff to express any concerns they may have with regards to the conduct of any individual. All staff must feel safe and supported in order to express their concerns, and can do so without fear of victimisation or discrimination.

Confidentially

All concerns will be treated in confidence; however, there may be a need for the member of staff to give evidence e.g. if they have witnessed a crime or in regard to disciplinary procedures if this is the outcome.

Anonymous allegations

Staff who raise concerns should be encouraged to identify themselves as part of their professional role and responsibility. However, anonymous allegations will be investigated as thoroughly as possible.

False allegations

If staff raise a concern in good faith which is not confirmed by an investigation, no action will be taken. However, if a concern is raised maliciously, disciplinary action may be taken.

How to raise a concern

  1. Report it to the DSL/Managing Director as soon as possible.
  1. The DSL/Managing Director will immediately ensure that the child involved in the concern is safe.
  1. A record of the concern must be made, including a record of anyone else who has witnessed the incident or allegation.
  2. The DSL/Managing Director will contact the local authorities immediately and no further decisions will be made without the consultation of the local authorities.
  3. If the concern is about the DSL/Managing Director, then a member of the DSS must be informed immediately instead.

Please refer to sections C6 and C7 of this policy for detailed guidelines on how to report a concern or allegation.

The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally.

Staff can call 0800 028 0285; the line is available from 8:00 AM to 8:00 PM, Monday to Friday.

C CHILD PROTECTION

C1. Overview and principles

Connect meets its child protection responsibilities by ensuring a full copy of this policy, and its updates, is given to every member of staff recruited at Connect.

Each member of staff is asked to sign a declaration to confirm that they have received and read the policy (and any updates), and are aware of the academy’s procedures that are in place to help them to understand and carry out their safeguarding roles and responsibilities. This includes regular face-to-face training and email updates.

All staff members are also given an electronic copy of this policy, and can read the hard copy of Keeping children safe in education, Part 1: Information for all school and college staff, September 2019, and a hard copy is kept in the Safeguarding folder in the Teachers’ room.

C2. Nominated designated person

The Designated Safeguarding Lead (DSL)/Managing Director Monika Morgans, must be informed of any child protection issues in the first instance. Their contact details are available at the front of this document. The academy’s 24-hour emergency contact number will be given out on arrival.

C3. Types of abuse and neglect

Abuse can appear in many forms. Staff also need to be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another.

Abuse is a form of maltreatment of a child. Somebody can abuse a child by inflicting harm or by failing to act to prevent harm.

Children can be abused by an adult or adults, or by another child or children. These abusers may or may not be known to them.

There are four broad categories of abuse:

  1. Physical,
  2. Emotional,
  3. Sexual, and
  4. Neglect.

Physical abuse

A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning or otherwise causing physical harm to a child.

Physical harm may also be caused when a parent / guards fabricates the symptoms of, or deliberately induces, illness in a child (Munchhausen Syndrome by Proxy).

Signs to look for:

  • Frequent and / or unexplained injuries
  • Bruising (look for symmetry e.g. two black eyes, brushing on both shoulders) or bite marks
  • Burns or scalds that have a clear edge (usually caused deliberately, not accidentally)
  • Wearing clothes to cover injuries, even in hot weather



Emotional abuse

This is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development.

Signs to look for:

  • Delayed physical or emotional development
  • Extreme passivity or aggression
  • Sudden speech disorders
  • Overreaction mistakes or continual self-deprecation
  • Neurotic behaviour (hair-twisting, self-harm)
  • Signs of radicalisation (see the guidelines Preventing radicalisation and extremism (Prevent)

Sexual abuse

This 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, or 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.

Signs to look for:

  • Acting in inappropriate or bizarre ways with objects or peers
  • Nightmares, sleeping problems
  • Becoming withdrawn or clingy
  • Personality changes, including feeling insecure
  • Changes in eating habits
  • Becoming secretive

Please also see Child sexual exploitation in section C5. Safeguarding issues.

Neglect

This is 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.

Signs to look for:

  • Badly dressed in clothes that need washing
  • Poor appearance and personal hygiene; unwashed or unbrushed hair
  • Lacks needed medical or dental care
  • Often tired and / or hungry
  • Unused to supervision or authority

C4. Safeguarding issues

All staff need to be aware of safeguarding issues, some of which are listed below. If a member of staff is made aware of any issue, either through disclosure by the victim, or another adult or child, then the staff must respond as per our reporting procedures.

Children missing from education

A child missing from education is a potential indicator of abuse or neglect and such children are at risk of being victims of harm, exploitation or radicalisation. Staff should monitor attendance and error, and address when it is poor or irregular.

Child sexual exploitation

This is a form of sexual abuse where children are sexually exploited for money, power or status. In some cases, young people are persuaded or forced into exchanging sexual activity for money, drugs, gifts, affection or status.

Some of the following signs may be indicators of sexual exploitation:

  • Children who appear with unexplained gifts or new possessions
  • Children who associate with other young people involved in exploitation.
  • Children who have older boyfriends or girlfriends.
  • Children who suffer from sexually-transmitted infections or become pregnant.
  • Children who suffer from changes in emotional well-being.
  • Children who misuse drugs and alcohol.
  • Children who go missing for periods of time or regularly come home late.
  • Child who regularly miss school or education.

So-called ‘honour based’ violence (HBV)

So-called ‘honour-based’ violence (HBV) encompasses crimes which have been allegedly committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing.

All forms of so called HBV are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubt, staff should speak to the DSL.

FGM mandatory reporting duty

FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is a criminal act in the UK, and is a form of child abuse with long- lasting harmful consequences.

Staff have a statutory duty to report to the police where they discovered (either through discourse by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Staff must personally report to the police cases where they discover that an act of FGM appears to have been carried out.

Failure to report such cases can result in disciplinary sanctions.

The duty does not apply in relation to at risk or suspected cases (i.e. where the member of staff does not discover that an act of FGM appears to have been carried out, either through disclosure by the victim or visual evidence) or in cases where the woman is 18 or over. In these cases, staff should follow local safeguarding procedures.

More information can be found here: https: //www.gov.uk/government/publications/mandatory- reporting-of-female-genital-mutilation-procedural-information

Forced marriage

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example).

Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools and colleges can play an important role in safeguarding children from forced marriage. More information can be found here:

https://www.gov .uk/government/uploads/system/uploads/attachment_data/fi le/322307/ HMG_MULTI_AGENCY_PRACTICE_GUIDELINES_v1_180614_FINAL.pdf

The Forced Marriage Unit can also give advice and information: 020 7008 0151 or fmu@fco.gov.uk

Other safeguarding issues can include:

  • Bullying including cyberbullying
  • Domestic violence
  • Drugs
  • Fabricated or induced illness
  • Faith abuse
  • Gangs and youth violence
  • Gender-based violence
  • Violence against women and girls
  • Violence against identified racial groups
  • Mental health
  • Relationship abuse
  • Sexting
  • Trafficking

For more information on any of these issues then please refer to the Keeping children safe in education, Part 1: Information for all school and college staff, September 2019, or please ask the DSL or DSS.

C5. Peer-on-peer abuse

All staff should be aware that safeguarding issues can manifest themselves via peer-on-peer abuse. This is most likely to include, but may not be limited to, bullying (including cyberbullying), gender-based violence, sexual assaults and sexting.

It is likely when considering a safeguarding allegation against a pupil, some of the following features will be found.

The allegation:

  • is against an older student and refers to their behaviour towards younger student;
  • is of a serious nature, possibly including a criminal offence;
  • indicates that other pupils may have been affected by this student;
  • indicates that young people outside the school may be affected by this student.

Examples of safeguarding issues against involving peer-on-peer abuse could include:

Physical abuse

  • Violence, particularly pre-planned
  • Forcing others to use drugs or alcohol

Emotional abuse

  • Blackmail or extortion
  • Threats and intimidation

Sexual abuse

  • Indecent exposure, indecent touching, or serious sexual assaults
  • Forcing others to watch pornography or take part in sexting

Sexual exploitation

  • Encouraging other children to attend inappropriate parties
  • Photographing or videoing other children performing indecent acts

C6. How to respond during a disclosure from a child

It is important that all staff members know how to respond if a child decides to disclose to them that they are being abused.

DO

  1. Allow the child to do the talking
  2. Make sure that you talk to the child in a classroom with a large window and with the door open
  3. Tell another member of staff that you are having a private meeting with the student
  4. Listen quietly and encouragingly
  5. Remain calm and supportive
  6. Allow the child to finish
  7. Explain that you may have to tell someone
    1. Record the conversation (what was actually said) as soon as possible and give the report to the DSL

DO NOT

  1. Panic
  2. Examine the child
  3. Promise to keep secrets
  4. Ask leading questions
  5. Interrupt
  6. Express any opinions about what you have been told
  7. Discuss the disclosure with anyone other than the relevant staff

C7. How to manage a concern or ‘immediate danger or at risk of harm’ to a child

All staff should be aware of the difference between ‘immediate danger or at risk of harm’ and a ‘concern’ and the process that follows.

  1. If a child is in immediate danger or is at risk of harm, ensure that the child is safe (e.g. remove the child from the unsafe situation). A referral should be made to children’s social care and/or the policy immediately (anyone can make a referral). The DSL then should be informed.
  2. If a staff member has a concern (as opposed to a child being in immediate danger), then tell the DSL as soon as possible.
  3. Record all the details in writing by completing the Safeguarding concern form (available from reception or from the DSL) which needs to be signed and dated.
  4. The DSL will respond depending on the nature of the concern. The DSL will do one of the following:
    1. monitor the situation on a regular basis until no further action can be recorded;
    2. investigate further to gather more information;
      1. discuss the matter with the group leader, parent or host, where appropriate prior to any action.

C8. How to manage an allegation against an adult

An allegation is information which indicates that an adult may have:

  1. Behaved in a way that has/may have harmed a child.
  2. Possibility committed a criminal offence against or related to a child
  3. Behaved towards a child in such a way that indicates that they would pose a risk of harm if working closely or regularly with a child.

An allegation could be made directly to the DSL or via another. Following an allegation, the steps to be taken are:

  1. If a child is in immediate danger or is at risk of harm, ensure that the child is safe (e.g. remove the child from the unsafe situation). A referral should be made to children’s social care and/or the police immediately (anyone can make a referral).
  2. Inform the DSL. They will ensure that the child is safe and supported.
  3. The Managing Director should be informed immediately. (If the allegation is against the Managing Director, then another member of the senior management team will be informed. If the allegation is against the DSL, then Director of Studies will take the responsibility for the situation).
  4. If/when safe and/or appropriate, the child should be returned to their normal routine.
  5. The child’s parents will be contacted an informed that an allegation has been made.
  6. The person making the allegation must complete the Safeguarding concern form (available from reception or from the DSL/Managing Director).
  7. The DSL/Managing Director will then report the allegation to the Local Safeguarding Children’s Board (LSCB). No decisions will be made without a referral to the LSCB.
  8. Suspension of the accused will only be considered where children are at risk of serious harm or the concern is so serious it would result in instant dismissal. If the employee is suspended, the reason will be communicated to them within one day.
  9. Connect will provide adequate support and the employee with a named contact if they are suspended.
  10. The DSL/Managing Director and the relevant local authorities will discuss and agree what actions are to be taken next. This may involve disciplinary action, dismissal and/or prosecution.
  11. If the staff member is dismissed due to their unsuitability to work with under 18s (following an external investigation) the DSL/Managing Director will inform the Disclosure and Barring Service (DBS).
  12. All details regarding the identity of the accused will remain confidential.
  1. If an allegation is unsubstantiated, unfounded or malicious, Connect will support the member of staff, especially if they have to return to work as a result of suspension. Any reports will be removed from their staff files. Disciplinary action will be taken against the perpetrators of the malicious allegation.

C9. How to manage an allegation against another child

Occasionally, allegations may be made against students by others in the academy which are of a safeguarding nature. Following an allegation, the steps to be taken are:

  1. If a child is in immediate danger or is at risk of harm, ensure that the child is safe (e.g. remove the child from the unsafe situation).
  2. Inform the DSL/Managing Director.
  3. The DSL will make sure that the child is safe and supported.
  4. The DSL will contact the LSCB immediately to discuss the case.
  5. The DSL will follow through the outcomes of the discussion and make a social services referral where appropriate.
  6. The DSL will make a record of the concern, the discussion and any outcome and keep a copy in the files of both students’ files. A factual written record of the allegation will also be signed and dated, either by the person who made the allegation or the adult who heard the allegation from the child.
  7. The DSL will support the alleged victim and if/when safe and appropriate, the alleged victim will be returned to their normal routine.

8. The accused will also be appointed a DSS to help support them through what happens next.

9. If the allegation indicates a potential criminal offence has take place, the police should be contacted and parents informed (of both the student being complained about and the alleged victim).

10. It may be appropriate to exclude the student being complained about for a period of time according to the academy’s behaviour policy and procedures.

11. Where neither social services nor the police accept the complaint, a thorough investigation by the academy will take place using the academy’s usual disciplinary procedures.

12. In situations where the academy considers a safeguarding risk is present, a risk assessment will be prepared along with a preventative, supervision plan.

13. This plan will be monitored and reviewed after a sufficient amount of time.

C10. Record keeping

  1. The DSL is responsible for maintaining all safeguarding records, including concerns and allegations, and training.
  2. All concerns, discussions and decisions made and the reasons for those decisions should be recorded in writing.
  3. All records regarding concerns and allegations are kept locked away, and can only be accessed by the DSL/Managing Director.
  4. The DSL ensures that recruitment records and the Single Central Registers are fully and accurately kept.
  5. Copies of this safeguarding policy and all other relevant documents, including the concern and allegation forms, are kept in a folder at reception. Staff are able to access these at all times.
  6. The DSL/Managing Director will meet annually to discuss the following:
  1. The number of concerns and/or allegations made over the past year.
  2. Staff training
  3. Any major safeguarding issues
  4. Feedback from staff and students
  5. Any areas of weaknesses
  6. Any new initiatives to be implemented over the next year.
  1. An annual safeguarding report will be produced after this meeting and will be used to review the academy’s safeguarding policy.

D TRAINING AND AWARENESS

D1. Responsibility

1.The DSL is responsible for the training of all staff.

2.The Managing Director is responsible for ensuring that the training needs of the DSL and other staff members are met.

3. All staff who have access to under 18s must receive Basic Awareness (Level 1) Safeguarding training. This training is either delivered online or in-house.

4. The DSL must have Advanced Safeguarding for the Designated Lead (Level 3) training.

D2. Training requirements

Training for all staff must begin before that they have contact with under 18s; training of staff usually takes place at the staff induction.

Early training must include:

  1. Raising awareness that everyone is involved in safeguarding; all staff members and adults connected with the academy have a duty of care to safeguard.
  2. Ensuring that everyone knows who the DSL and DSS are and how they can be contacted.
  3. Knowing the systems for reporting concerns and/or allegations.
  4. Information on how to recognise signs of abuse, including child sexual exploitation, peer-on- peer abuse, and so called ‘honour violence’ that includes FGM and Forced Marriage.
  5. Information on what happens if an allegation is made.
  6. Receive a copy of the safeguarding policy and know where all safeguarding documents are kept.
  7. Know about the staff code of conduct regarding adult interaction with under 18s.
  8. Awareness that all staff have a duty to look out for each other’s behaviour and report anything inappropriate, and that they will be supported and treated in confidence if they do.
  9. Prevent training.
  10. Receive and read a copy of Keeping Children Safe in Education - Part 1, September 2019.

All staff must receive safeguarding training at least annually.

The DSL/Managing Director must receive formal training every two years. In addition, their knowledge and skills should be updated, (for example via e-bulletins, meeting other designated safeguarding leads, or taking time to read and digest safeguarding developments), at regular intervals, but at least annually, to keep up with any developments relevant to their role.

D3. Training delivery

  1. Basic Awareness (Level 1) Safeguarding training can be delivered in house by the DSL or online.
  2. Online training needs to be supplemented with face-to-face training.
  3. Staff will updated regularly through weekly safeguarding e-bulletins.
  4. Formal refresher training will be delivered face to face three or four times a year by the DSL.

D4. Visitor awareness

All visitors to Connect on arrival at reception are required to read the Guidelines for visitors, which informs visitors that there are under 18s in the academy and gives clear expectations regarding suitable behaviour. Visitors are also required to wear a ‘visitor’ lanyard so they can be easily identified.

D5. Homestay provider training

  1. Homestay providers who wish to host under 18 students will be made aware of the academy’s safeguarding policy at the application stage.
  2. All homestay providers and household members will be required to read the academy’s safeguarding policy, and to complete self-declaration forms to say that they have received the policy and accept the requirements.
  3. Guidance will be given by the housing officer on safeguarding under 18 student guests from any adult visitors to the the home, as well as on keeping any homestay host’s children safe from when hosting older students.
  4. The housing officer will ask appropriate questions at the inspection stage and further visits to ensure that homestay providers and their family members are compliant with regards their duty to safeguard.
  5. Homestay providers will also be asked to read, understand and promise to abide by the homestay provider’s rules and regulations for students under 18 (please see section F4. Welfare provision).

E SAFER RECRUITMENT

E1. Overview

The academy pays due regard to its legal obligation in respect to the recruitment and selection of staff members and homestay providers and has recruitment procedures and practices which aim to deter, reject or identify people who might abuse children.

  • E2. Recruitment materials

Recruitment materials for all job roles (including homestay providers) contain reference to the academy’s commitment to working with and safeguarding children. Recruitment materials will also inform applications that:

  1. Reference requests will be followed up.
  2. Reference requests will specifically ask whether there is any reason why the applicant should not be engaged in situations where they have responsibility for, or substantial access, to persons under 18.
  3. All gaps in an applicant’s employment history must be explained satisfactorily.
  4. Appropriate suitability checks will be required prior to confirmation of appointment.
  5. Proof of identity and qualifications will be required.

This information will be provided as part of the application pack but will be provided to all applicants before they attend an interview.

E3. Recruitment stages

  1. The academy will shortlist applicants according to the relevance and applicability of their professional attributes and personal qualities to the role.
  2. Short-listed candidates will then be invited to attend in person a formal interview at which the application’s skills and experience will be discussed in more detail.
  3. All formal interviews will have a panel of at least two people chaired by the Managing Director and/or the Director of Studies, and/or members of the senior management team.
  4. It is recommended that at least one person on the interview panel will have undertaken safer recruitment training.
  5. The candidate will be asked questions that will explore their suitability to work with children. Examples of such questions are as follows:
    1. What attracted you to teaching / this post / this school?
      1. Give an example of how you dealt with bullying behaviour between students.

What did you do? What made it successful? How could you have done it better?

  1. What motivates you to work with young people?
  2. How do you define an appropriate teacher-student relationship?
  3. What would you do if were concerned about a colleagues’ behaviour towards children?

E4. Pre-appointment checks

  1. Any offer to a successful applicant will be conditional upon:
  1. receipt of at least two satisfactory references (the references will request confirmation that the candidate is suitable to work with children);
    1. verification of identity and qualifications, including evidence of the right to work in the UK;
      1. an enhanced Disclosure and Barring Services (DBS) check, and if appropriate, a check of the Barred List, maintained by the DBS;
        1. a completed self-declaration form of the candidate’s suitability to confirm that they are safe to work with children.

E5. Applicants with a current DBS

  1. If a potential member of staff or homestay provider has a current enhanced DBS for the ‘child workforce’ that is less than three years old, then Connect will not request a new DBS check, as long as there is no other reason for concern.
  2. The DBS certificate will be checked online via the DBS update service by an appropriate member of staff and with the applicant’s permission.
  3. The applicant must provide the original document and this will be checked and recorded by an appropriate member of staff.

E6. Applicants awaiting a DBS check

  1. If an employee is due to start work and the enhanced DBS check has not yet arrived, there should be exceptional and justifiable circumstances for employment to commence prior to receiving criminal clearance.
  2. If a decision is made for the employee to commence work before the DBS check has arrived, it should only be made if is unavoidable. The key questions for consideration are:
  1. What are the reasons for considering commencement of employment prior to receiving clearance?
    1. What are the consequences to service delivery of waiting until clearance is received?
      1. If the employee commenced in their role, what would be their normal level of access to children i.e. unsupervised or supervised access to children?
  1. If a decision is made for the employee to commence work before the DBS check has arrived, the decision must be recorded and signed off by the relevant senior manager.
  2. The new employee must have signed a self-declaration form and their access to under 18s should be supervised at all times. There should be a clear record of what alternative risk mitigation has been put in place to cover this period.
  3. The employer must check that the candidate is not on the Barred List before they start work.
  4. The employee should not start work prior to the submission of their completed application or paperwork to obtain criminal clearance.

E7. Applicants where a DBS check is not possible

  1. If a prospective employee is an overseas national, then Connect will ask for a police certificate of good conduct from the county of the prospective employee’s most recent residence.
  2. If a record check is not possible for an overseas national, then Connect will document what action has been taken to obtain a check, and why this has not been possible. Special care will be taken with the overseas national’s identity and qualification checks, and with exploring their employment history and obtaining references. A judgement will be made by senior management with regard to suitability for the role and level of supervision. A written record of this judgment will be made.
  3. If the new employee is a British national who has been living overseas, even for a long period of time, then an enhanced DBS check will still be asked for, in order to check their UK records.
  4. All applicants will be asked to provide proof of their identity and their right to work in the UK.
  5. References and employment history will also be asked for as per Connect’s pre-appointment checks requirements.

E8. Policy on the recruitment of ex-offenders

  1. Connect actively promotes equality of opportunity for all with the right mix of talent, skills and potential and welcomes applications from a wide range of candidates, including those with criminal records. We select all candidates for interview on the basis of their aptitude, skills, qualifications and experience in relation to the requirements of the post.
  2. It is a requirement that all registered bodies must treat DBS applicants who have a criminal record fairly and do not discriminate because of a conviction or other information revealed.
  3. This policy on the recruitment of ex-offenders is made available to all disclosure applicants at the outset of the recruitment process.
  4. As an organisation using the DBS to assess applicants’ suitability for positions of trust, the academy aims to comply fully with the DBS code of practice and undertake to treat all applicants for positions fairly. The academy undertakes not to discriminate unfairly against anyone who is the subject of a disclosure on the basis of conviction or other information revealed.
  5. The academy is committed to the fair treatment of our staff, potential staff or users of our services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical/mental disability, or offending background.
  6. This policy will be made available to all DBS applicants at the outset of the recruitment process.
  7. A DBS check is only requested when it is both proportionate and relevant to the position concerned. For those positions where a DBS check is required, the recruitment information will contain a statement that a DBS check will be requested in the event of the individual being offered the position.
  8. Where a DBS check is to form part of the recruitment process, we encourage all applicants called for interview to provide details of any criminal record at an early stage in the application process. The academy guarantees that this information is only be seen by those who need to see it as part of the recruitment process.
  9. We ensure that all those who are involved in the recruitment process will have suitable guidance to enable them to identify and assess the relevance of the offence in relation to the position applied for. We also ensure that they receive appropriate guidance on the relevant legislation relating to the employment of ex-offenders, e.g. the Rehabilitation of Offenders Act 1974.
  10. At interview or in a later separate discussion, we ensure that an open and measured discussion takes place on the subject of any offences or other matter that might be relevant to the position. Failure to reveal information that is directly relevant to the position applied for could lead to withdrawal of an offer of employment.
  11. We undertake to discuss any matter revealed in a DBS check with the person seeking the position before withdrawing a conditional offer of employment.
  12. We make every subject of a DBS check aware of the existence of the DBS code of practice and make a copy available on request.
  13. Having a criminal record will not necessarily bar you from working with the academy. This will depend on the offence and the relevance of the offence in relation to the position applied for. The factors taken into account will include:
    1. the seriousness and nature of the offence(s)
    2. nature of appointment
    3. age of offence(s)
    4. frequency of offence(s)
    5. any concealment of offences during the application process
  14. Any decision regarding the suitability of the prospective employment will be discussed among relevant members of senior management and in conjunction with advice from the LSCB.
  15. A clear written record of the decision will be made; this record will not contain details of the offences.

E9. Group leaders

  1. Group leaders are not able to undergo a DBS check if they are an overseas national. Police certification of good conduct should be provided if available instead.
  2. A formal agreement should also be place between the academy and the agent to ensure suitability checks have taken place on all adults accompanying under 18s.
  3. In addition, all group leaders will be asked to complete a self-declaration form and will be made aware of the academy’s safeguarding policy and procedures before they arrive.
  4. Connect staff will also be aware of having to provide adequate supervision and vigilance of all group leaders during their time with the academy.

E10. Contractors

  1. Connect will ensure that any contractor, or any employee of the contractor, who is to work at the academy, has been subject to the appropriate level of DBS check.
  2. Contractors engaging in regulated activity will require an enhanced DBS certificate (including barred list information).
  3. For all other contractors who are not engaging in regulated activity, but whose work provides them with an opportunity for regular contact with children, an enhanced DBS check (not including barred list information) will be required.
  4. Under no circumstances will a contractor in respect of whom no checks have been obtained be allowed to work unsupervised, or engage in regulated activity. The academy is responsible for determining the appropriate level of supervision depending on the circumstances.
  5. If a contractor working at a school or college is self-employed, Connect will obtain the DBS check if necessary, as self-employed people are not able to make an application directly to the DBS on their own account.
  6. Connect will always check the identity of contractors and their staff on arrival at the academy’s premises.
  7. All contractors will also be made aware of the academy’s safeguarding policy and procedures before they arrive at the premises.
  8. Connect staff will also be aware of having to provide adequate supervision and vigilance of all contractors while they are working for the academy.

E11. Volunteers and trainees

All volunteers and teacher trainees will not be left unsupervised when taking part in regulated activity at Connect.

E12. Homestay providers

  1. All household members over the age of 18 of the homestay accommodation must have an enhanced DBS check with barred list check before they can have any under 18 student accommodated with them.
  2. References will also be requested with specific reference to safeguarding issues, and appropriate questions will be asked at the initial inspection by the housing officer that will explore their suitability to work with children and to check their understanding of safeguarding.
  3. All other household members over the age of 18 must sign a self-declaration form to confirm that there is no reason why they cannot be in contact with under 18s.
  4. All household members will be made aware of the academy’s safeguarding policy and practice and will be asked to confirm that they have read and accepted them.

E13. Handling of DBS certificate information

  1. As an organisation using the DBS checking service to help assess the suitability of applicants for positions of trust, the academy complies fully with the code of practice regarding the correct handling, use, storage, retention and disposal of certificates and certificate information.
  2. It also complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of certificate information and has a written policy on these matters, which is available to those who wish to see it on request.
  3. Certificate information is always kept in a secure, lockable filing cabinet with access strictly controlled and limited to those who are entitled to see it as part of their duties.
  4. In accordance with section 124 of the Police Act 1997, certificate information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom certificates or certificate information has been revealed and it is a criminal offence to pass this information to anyone who is not entitled to receive it.
  5. Certificate information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.
  6. Once a recruitment (or other relevant) decision has been made, we do not keep certificate information for any longer than is necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep certificate information for longer than six months, we will consult the DBS about this and will give full consideration to the Data Protection and Human Rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
  7. Once the retention period has elapsed, the academy will ensure that any DBS certificate information is immediately destroyed by secure means, for example by shredding, pulping or burning. While awaiting destruction, certificate information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).
  8. We will not keep any photocopy or other image of the certificate or any copy or representation of the contents of a certificate. However, not withstanding the above, we may keep a record of the date of issue of a certificate, the name of the subject, the type of certificate requested, the position for which the certificate was requested, the unique reference number of the certificates and the details of the recruitment decision taken.

E14. Single Central Record

  1. The academy keeps a Single Central Record (SCR) for all staff.
  2. The information that is recorded in respect of staff members is whether the following checks have been carried out or certificates obtained, and the date on which each check was completed/certificate obtained:
    1. an identity check
    2. a barred list check
    3. an enhanced DBS check/certificate
    4. a prohibition to teach check (if required)
    5. further checks on people who have lived or worked outside the UK
    6. a check of professional qualifications
    7. a check of references
    8. a check to establish the person’s right to work in the UK
  3. A copy of the documents used to verify the successful candidate’s identity, right to work and required qualifications will be kept in each staff member’s personnel file.
  4. The homestay officer keeps a separate central record for all homestay providers that records that all required checks have been made, including DBS and barred list checks when required.

F1. Use of risk assessments

1.A risk assessment must be carried out prior to any planned or organised activity that:

  • is being coordinated specifically for under 18s;
  • will involve attendance/participation by under 18s.

2.The full extent of the assessment will depend on the nature of the activity. A generic assessment will suffice for most areas, but specific assessments should be carried out for entry into locations where there are known hazards.

3.Trips and activities away from the academy are likely to represent one of the most serious health and safety concerns for children and young people. All external trips and activities require careful examination before the visit goes ahead. It is the responsibility of one of the DSS to ensure that a risk assessment is conducted before the event. Students will be informed of any risks before the trip or activity begins.

4.A risk assessment is provided for journeys to and from the academy. Students are given a map, address of the academy and the academy’s phone numbers (including the emergency phone number). Both the student and the homestay provider are informed on what precautions to take when travelling to and from the academy, This information is included in the information pack given to homestay students.

5.The social event coordinator must ensure that all social activities are also appropriate for the age, interests and abilities for under 18s.

6.Before a child is allowed to attend an off-site social activity, the coordinator must ensure that the academy has parental/guardian permission for the child to attend such activities. The coordinator must complete a risk assessment form when planning an activity.

7.If there is an activity that is planned that in any way is unsuitable for students under 18 (such as certain films, places) then this must be clearly stated and no under 18s to be allowed to attend under any circumstances.

8.Homestay providers complete an initial risk assessment form which is reviewed with them at the time of their house inspection by the housing officer. It must be updated on subsequent inspections or earlier if there are any changes to the building.

F2. Supervision ratios

  1. The academy ensures there is sufficient adult supervision for scheduled lessons and activities, both on site and off-site.
  2. The 2018 DfEE publication Health and Safety of Pupils on Educational Visits advises the following supervision adult to student ratio: 1 adult for every 15 to 20 students who are aged 11 plus.
  3. All trips with under 18s organised by Connect should observe this ratio as a minimum.
  4. However, for each event, the social coordinator and risk assessors need to assess the risk and are expected to exceed this ratio if the safety and welfare of the students require it. For example, the ratios for swimming in the sea would be very different.
  5. There should be enough supervisors to deal with an emergency.
  6. In some circumstances group leaders may be included in this ratio, but this will be assessed according to the activity, location and circumstances, and will be recorded in relevant risk assessments.

F3. Absent students Missing students from class

  1. At induction, all students are told that they must attend 100% of the classes. If for any reason a student cannot attend a class due to an emergency or illness, then they are asked to contact the academy by phone or by email as soon as possible.
  2. All under 18 students are also required to sign in at reception for each morning and afternoon session.
  3. If a student has not signed their name by 09:15 (morning session) or by 14:15 (afternoon session), then the DSL/Managing Director will check the relevant classroom to see if the student is there.
  4. If the student is not on the premises, and has not contacted the academy regarding their absence or lateness, then the DSL/Managing Director will telephone and email the student. A message will be left on the student’s voicemail to contact the academy as soon as possible.
  5. If the student has not contacted the academy by 12pm for the morning session, and by 4pm for the afternoon session, then the DSL/Managing Director will contact the named legal guardian, homestay provider and/or the student’s agent.
  6. If contact cannot be made be made with the any of the above, and/or the student’s whereabouts cannot be verified, then the police will be contacted either by the DSL/Managing Director.
  7. The parents of the students will be kept updated by the DSL/Managing Director.

Missing students from homestay

  1. Students under 18 have a strict curfew of 10:30pm to return to their homestay.
  2. If a student does not arrive home by the curfew, and has not informed the homestay provider that they will be late, the homestay provider is asked to call the student via their mobile.
  3. If the student does not answer their mobile, the homestay provider will contact one either the DSL/Managing Director via the academy’s emergency contact number.
  4. The DSL/Managing Director will try to contact the student.
  5. If the student cannot be contacted, then the DSL/Managing Director will contact the police.
  6. The student’s parents and/or agent will also be informed as soon as possible.

Missing students from activities and excursions

  1. If a student under 18 is late, or goes missing, during an off-site activity/excursion, then the social activity coordinator and/or group leader will try to contact the student via telephone.
  2. If the student cannot be contacted after three attempts then the police will be informed.
  3. The student’s parents and/or agent will also be informed as soon as possible.

F4. Welfare provision Booking stage

  1. Parents/guardians are requested to complete a consent form that covers arrival details, medical details, accommodation details (if not in homestay), emergency contact details and arrival details.
  2. Parents/guardians are made aware that the academy does not accept responsibility for the supervision of 16 to 17 year olds outside of scheduled class times and students will not be supervised when travelling between their accommodation and Connect.
  3. Under 18 students cannot enrol at Connect unless the parental/guardian consent form has been completed and signed.
  4. Parents/guardians are asked to provide Connect with a contact number that they can be contacted on at all times.
  5. Connect will provide the parent/guardian with the details of the academy’s 24-hour emergency contact number.

Student induction

During their induction, students will be informed of the following:

  1. the under 18 students’ code of conduct and why safeguarding is important
  2. the policy on having student ID and wearing lanyards
  3. the accommodation officer contact details (if in homestay)
  4. how to contact the DSL/Managing Director
  5. when to sign in and out at reception
  6. the 24-hour emergency contact number
  7. the time and frequency of the under 18 meetings
  1. how to find their way around Cardiff; how to travel safely between their accommodation and the academy
  1. how to register with the police (if required)
  2. how to register with a GP

Studying at the academy

  1. All students, staff and visitors are required to wear a lanyard which is colour-coded according to their role and age. Under 18s wear a special-coloured lanyard so they can be easily identified around the premises. All teachers and staff members must ensure that students wear their lanyards at all times.
  2. Under 18 students are required to sign in at reception every morning and every afternoon.
  3. Under 18 students are highlighted on class registers so all teachers are aware of who is under 18 in their class.
  4. Teachers will consider the ages of the students when planning lessons topics and choosing materials to teach to under 18s.
  5. A list of all under 18s in the academy are emailed weekly to all management staff.
  6. Under 18s are expected to attend weekly meetings (usually Wednesday at 12:00pm) with the DSL/Managing Director to discuss any issues or concerns. All meetings are recorded with follow-up points to be actioned.
  7. A code of conduct for under 18 students is displayed in each classroom and the student lounge.

Toilet facilities

  1. Toilet facilities are checked regularly by members of staff during break and lunchtimes to ensure that any under 18s are safe.
  2. If a student who is under 18 needs to go to the bathroom during lesson time, then they must tell the DSL/Managing Director (who will be at reception) who will escort the student to the bathroom and wait outside, and will then escort the student back to their classroom when finished.

Accommodation

  1. All under 18 students are required to stay in homestay accommodation provided by Connect.
  2. However, under 18 students can stay with a family member over 18 if written permission is obtained from the parent/guardian before the student arrives.
  3. If an under 18 student wants to stay overnight, or spend the weekend, at any other location than their usual accommodation, then the academy must have written permission from the parent/guardian at least one week in advance, and must have details of where the student will be staying.

Homestay provider rules and regulations

For host families who take students under the age of 18, all family members over the age of 16 must, without exception, be DBS checked. This includes all visitors including grown-up children visiting from university.

  1. All household members over the age of 18 of the homestay accommodation must have an enhanced DBS check before they can have any under 18 student accommodated with them.
  2. References will also be requested for homestay providers with specific reference to safeguarding issues, and appropriate questions will be asked at the initial inspection by the housing officer that will explore their suitability to work with children and to check their understanding of safeguarding issues.
  3. All other household members over the age of 18 must sign a self-declaration form to confirm that there is no reason why they should not be in contact with under 18 students.
  4. All household members will be made aware of the academy’s safeguarding policy and practices and will be asked to confirm that they have read and accepted them.
  5. Homestay providers need to carry out a fire risk assessment at their household and complete a fire risk assessment form.
  6. Homestay providers must have an up-to-date gas safety certificate. This will be checked by the housing officer and a copy of the certificate will be required.
  7. Connect must be informed immediately by the homestay provider of any changes concerning the people living in the household (new tenants, new partner, visitors that sleep over, a police conviction etc.).
  8. Students under the age of 18 will not be housed with students of 18 years or older.
  9. No more than one student will be accommodated in the same bedroom unless specifically requested written permission has been given by the parent/guardian and/or the agent.
  10. Homestay providers will ensure that there is an adult available to greet students on arrival.
  11. A responsible adult will always be present overnight and normally present when students under 18 are at home.
  12. Under 18s should not be left unsupervised except for short periods.
  13. Homestay providers are responsible for providing a laundry service and meals on a half-board basis to students aged 16 and 17 unless other agreements have been made by parents/ guardians.
  14. Students under 18 have a strict curfew of 10:30pm to return to their homestay. If a student does not arrive home by the curfew, and has not informed the homestay provider that they will be late, the homestay provider is asked to call the student via their mobile. If the student does not answer their mobile, the homestay provider must contact the DSL/Managing Director via the academy’s emergency contact number (+44(0)7908 583109).
  15. Students who are under 18 are not allowed to be involved in any activities that are not suitable to their age and might be harmful. Students who are under the age of 18 are not allowed by law to drink/buy alcohol, buy tobacco, or use drugs. Homestay providers are responsible for ensuring that under 18 students adhere to these regulations.
  16. Homestay providers are asked to work together with Connect to ensure that all under 18 students are safe when they travel between their home and the academy by providing students with up-to-date travel information. Homestay providers are encouraged to accompany students to the academy on their first day.
  17. All homestay providers must take all steps to ensure the privacy of any under 18 student when they use the bathroom, or when they are in their own bedroom.
  18. Contact between adults (including adult visitors) and under 18 students should not be extended beyond the kitchen, sitting room, garden, or any other open and non-private space(s) when at home.
  19. All adults (including visitors) need to be always appropriately dressed when in the common areas of the house (e.g. sitting room, kitchen, garden).
  20. All homestay providers are asked to monitor under 18 students’ use of the internet and digital technology in the home, and to report any concerns immediately to the academy’s DSL \Managing Director.
  21. All homestay providers must be aware of Connect’s Prevent policy and procedures, and to report any concerns to the academy’s DSL/Managing Director.
  22. All homestay providers must be aware of, understand and abide by Connect’s safeguarding policy, including the academy’s child protection policy. Any incidents of child abuse at the homestay will be immediately addressed by the academy’s safeguarding team and will be reported to the police.
  23. All homestay providers have a legal obligation to report any concern or allegation to the DSL /Managing Director.
  24. If a homestay provider is hosting students aged over 18 and has children in the household, then it is highly recommended that they follow the same guidelines with regards to privacy, dress code and adult/under 18 interaction.

F5. First aid and medical

  1. Connect has two first aiders: Monika Morgans and Julia M. Crockett
  2. Two first-aid kits can be found in the teacher’s room. One kit is to be taken on all off-site activities.
  3. Students are advised at induction on how to register with a GP.
  4. Parents/guardians have to complete a medical consent form before the student arrives in the UK.
  5. If students fall ill at their home, then the student or homestay provider is required to phone and tell the DSL/Managing Director.

Pre-existing medical conditions

When applying for a place at Connect, all applicants will be asked to complete a medical disclosure form giving details of any pre-existing medical conditions. Any disclosures must be brought to the attention of the DSL, the DOS/ADOS, and housing officer (if relevant).

The condition(s) must be discussed and decisions must be made regarding the safety and welfare of such a student whilst they may possibly be with us.

Points to consider are:

  • Will the student be staying on their own and is this viable bearing in mind their condition?
  • Is the homestay provider (if any) prepared and able to care for the individual concerned?
  • Does the student understand how to take their medicine and request some more if needed?
  • The student will in all probability be coming from abroad; is coming to Cardiff to study in their best interests with their medical condition?

It is recommended that all relevant risk assessments (studying at academy, travel to and from the academy, homestay, social activities) be carried out for such students, and if they do come to study, all relevant parties (DSL, Managing Director, Director of Studies, homestay provider) are all made aware of the student’s condition.

F6. Under 18s behaviour and discipline (code of conduct)

All under 18 students are asked to read and sign to accept that they understand the under 18s code of conduct. These are additional and specific rules in addition to the general student code of conduct. These rules are included in the student handbook and are displayed on notice boards in every classroom, and in the student lounge.

Student code of conduct for under 18s

Connect only accepts students who are aged 16 and over, except during the summer Junior Programme. Students who are 16 or 17 attending adult classes will not receive a junior course level of supervision and will be in classes with students who are aged 18+. Students and their parents/guardians should consider this before any under-18-year-old enrols on this course.

If you are under 18 then you must follow some special rules and guidelines.

  1. Stay in groups: When you travel outside of the academy, please try to travel in groups of at least two students
  2. Charge your mobile: Make sure that you keep your mobile phone charged.
  1. Tell us where you are: You must sign in at reception when you arrive for lessons and sign out when you leave Connect. If you are late for lessons, then you MUST ring, text or email us.
  2. If you are feeling ill: If you are not feeling well, then you must tell a member of staff as soon as possible. If you cannot come to lessons, then you MUST ring, text or email us.
  1. Get home in time: If you are staying with a homestay, then you must be home by 10:00 pm every night. You must call and tell your homestay host if you are going to be later than this, or will not be home for your evening meal.

6. Know the law: It is illegal to buy cigarettes or tobacco if you are under 18. It is illegal to buy or drink alcohol, or for anyone else to buy alcohol for you if you are under 18.

7.Wear your lanyard: You must wear your lanyard at all times when at the academy.

Posters are displayed in each classroom to clearly show who students need to go to if they feel unhappy or unsafe.

If a disciplinary issues arises, then the usual academy disciplinary procedures for students will be followed. However, special care and sensitivity will be taken to ensure that there are no underlying safeguarding issues or causes of concern.

F7. Fire safety

Fire safety information is displayed in all the classrooms and throughout the academy, and all students under 18 are shown the fire exits during their induction. Escape routes are clearly visible and students are informed of the fire drill process and shown where the fire drill meeting area is.

Regular fire drills are carried out and with the help of the DSL to make sure that all under 18 students know what to do. Teachers are also responsible for accompanying all under 18 students during a fire drill and a role call is completed at the meeting area. Fire drills are carried out at least twice a year.

All homestay providers are required to complete a fire risk assessment and have a current gas safety certificate. These documents are checked by the accommodation officer.

F8. Travelling to the UK / Airport transfers

Before travelling to the UK, students and their parents are contacted by a member of the team at Connect to be informed that it is preferred that an airport transfer by Connect is arranged (all our transfers are done by a member of staff or by taxi drivers who are DBS checked). However, parents/guardians can give their written permission for alternative arrangements if required. Connect will provide appropriate guidance and support if necessary.

Students and parents will also be advised to visit the following website to ensure that they meet the UKBA requirements for travelling to the UK if under 18 (with or without an adult):

https:// www.gov.uk/study-visit-visa/documents-you-must-provide

F9. E-safety

All students are given advice regarding the use of the internet, and are asked to sign an e-safety code of conduct on their arrival at the academy. More information about the rules and regulations can be found in the academy’s E-safety and Acceptable Use of Information and Communications Technology (ICT) Policy.

Homestay providers are asked to monitor under 18s use of the internet and digital technology at home and to report any concerns to the DSL/DSS at Connect.

F10. Prevent

Connect recognises its responsibilities under the Counter Terrorism and Security Act 2015 & 2019 to prevent people of all ages, including under 18s, being radicalised or drawn into terrorism. Prevent is about safeguarding people and communities from the threat of terrorism. Prevent is one of the four elements of CONTEST, the Government’s counter-terrorism strategy. It aims to stop people becoming terrorists or supporting terrorism. The school promotes a multicultural environment where respect for, and tolerance of, other people’s beliefs is required at all times. For more information about the academy’s policy and procedures, please refer to the academy’s Prevent policy and procedures.

F11. Provision for those more vulnerable, including vulnerable adults

The definition of a vulnerable adult is a ‘person aged 18 years or over who may be in need of community care services by reason of mental or other disability, age or illness and who is or may be unable to take care of himself or herself, or unable to protect him or herself against significant harm or exploitation’ (2008 Consultation ‘Who Decides?’ issued by the Lord Chancellor’s Department).

Connect is aware that disabled children or adults may be especially vulnerable to abuse, including because they may have an impaired capacity to resist or avoid abuse. They may have speech, language and communication needs which may make it difficult to tell others what is happening.

Although the academy is constantly on the lookout for vulnerable adults among the students, the academy rarely receives students who fall into this ‘official’ category; however, at Connect, all students are consider to be potentially vulnerable adults as they are all away from home and in a foreign country. The academy particularly looks out for those who have learning difficulties, special needs or physical disabilities. Others may be vulnerable for a whole range of reasons, and particularly if they have a very low level of English, if they are lacking confidence, if they find it difficult to integrate and make friends, or if they come from a troubled background at home.

Sometimes issues are flagged up by our agents before the students arrive. However, often it is a teacher who identifies these issues once a student is here. The teacher should report this immediately to the Director of Studies who informs the rest of the safeguarding team, and is then dealt with following the academy’s safeguarding practices.

F12. Early help

Staff members have a paramount role to play in the early help process. Teachers and other members of staff are encouraged to keep an eye on the underage students in order to identify early any potential signs of abuse, discomfort or worry. If such signs are identified teachers and other members of staff need to report immediately to the DSL/Managing Director.

All staff members should be alert to the potential need for early help for a child who:

  • is disabled and has specific additional needs;
  • has special educational needs;
  • is a young carer;
  • is showing signs of engaging in anti-social; or criminal behaviour;
  • is in a family circumstance presenting challenges for the child such as substance misuse, adult mental health problems or domestic violence and abuse;
  • is showing early signs of abuse or neglect.
  • F13. Private fostering

Connect currently does not accept students under the age of 16, except during the summer term and on closed group Junior Programmes, and is aware that the local social or children’s services must be informed at least six weeks in advance about all private fostering situations, i.e. when a child or young person under 16 years old (or 18 if they have a disability) will be looked after for 28 days or more by someone who is not a close relative, guardian or person with parental responsibility.

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