Trinity International Education (referred to in this document as TIE) runs summer schools for international students.
Residential accommodation, board and a full activity programme are provided for all students.
This policy describes TIE ’s approach to child protection and safeguarding, which are of paramount importance to our company.
This policy applies to all adults working with children.
The promotion of the welfare of students under the age of 18 and their protection from any potential maltreatment.
The processes involved in protecting children from direct harmful behaviour or abuse either physical or psychological.
Child / Children
Anyone below the age of 18.
An assigned adult from the students’ home country who accompanies them and has joint responsibility for them during the programme.
Everyone who is employed by TIE and has contact with children.
TIE Designated Safeguarding Lead (DSL)
The designated member of staff responsible for the implementation of this policy and related training.
TIE Designated Safeguarding Staff (DSS)
Designated people who look after day-to-day matters, training and recording systems.
TIE recognises that the welfare of its students is paramount and is fully committed to safeguarding the welfare of all students studying at our summer schools.
We believe that safeguarding is the individual and collective responsibility of everyone working in the company and we recognise our responsibility to promote safe practices that reflect statutory and moral responsibilities, government guidance and accrediting bodies’ guidelines.
Under 18’s entitlement
This policy is for all children in our care, regardless of gender, ethnicity, disability, sexuality, or belief. They all have equal entitlement to be protected.
All staff working with children have a legal duty of care to safeguard them. They must:
• understand, adopt, adhere to and implement TIE Safeguarding Policy
• identify children who are suffering from, or likely to suffer from, abuse, and report any concerns about welfare to TIE DSS or TIE DSL immediately
• conduct themselves in accordance with the TIE Code of Conduct
All TIE Staff will have appropriate training.
Specific policies that should be read in conjunction with this document are:
• Covid Policy
• Criminal Record Policy
• Emergency Action Plan
• E-safety Policy
• First Aid Policy
• Health & Safety Policy
• Medicines Policy
• Prevent Policy
• Safer Recruitment Policy
• SEND Policy
• Staff Code of Conduct
• Student Code of Conduct
• Whistleblowing Policy
This policy was updated in December 2023
TIE is committed to reviewing it every year or whenever required in the light of new or updated guidance or recommendations from the UK Government, appropriate organisations, or accrediting bodies.
The review will draw on feedback from TIE staff, Groups Leaders and parents.
Roles and responsibilities
Specific responsibilities are as follows:
TIE Designated Safeguarding Lead (DSL)
• to take responsibility for safeguarding and child protection
• to keep staff updated regarding training and policies
• to ensure the Prevent Duty is met
• to manage and refer cases of suspected abuse to the Local Authority Designated Officer (LADO) as required
• to receive information from any staff, volunteers, children, parents or carers who have safeguarding concerns and
• to be ready to respond to any major incidents
TIE Deputy Designated Safeguarding Lead
• to deliver training
• to deputise for TIE DSL
TIE Designated Safeguarding Staff (DSS)
• to review and implement all aspects of the safeguarding policy
• to deal with any safeguarding concerns following the procedures documented in the safeguarding policy and liaising with TIE DSL as required
Students are encouraged to be responsible and vigilant in looking out for each other and raise concerns with an adult if necessary.
• Children Act 2004
• Sexual Offences Act 2003
• Keeping children safe in education, September 2023
• Working Together to Safeguard Children, July 2018
• Equality Act 2010
• The Prevent Duty, June 2015
• Guidance on handling a disclosure from a child
• Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers, July 2018
• Counter-Terrorism and Security Act 2015
• Child sexual exploitation, February 2017
• Female Genital Mutilation Act 2003
• Serious Crime Act 2015
• Children and Social Work Act 2017
• Education Act 2002.
Policy availability & formats
There is a simplified version for students, parents, and Group Leaders, whose first language may not be English, available on the TIE website.
The full policy is provided to all staff before they begin their employment.
Code of Conduct
Overview and principles
At TIE we aim to create a safe culture and to protect both students and staff members from behaving in a way that may be misconstrued.
TIE has a clear Code of Conduct for both staff and students, please refer to TIE Staff Code of Conduct and TIE Students Code of Conduct.
Staff Code of Conduct
Staff are provided with the Code of Conduct before beginning their employment and must set a good example by conforming to the Staff Code of Conduct.
Student Code of Conduct
Students are expected to follow TIE’s rules while attending our courses. They are provided with the Code of Conduct in their handbook and reminded of this again at induction and throughout their time with TIE.
Any incident or misbehaviour will be reported to the Centre Manager. After investigating the matter properly, together with TIE Senior Management, they will deal with the incident in the appropriate way, depending on how serious it is.
Students will be warned and possibly excluded from participation in our courses and more serious incidents might be reported to the authorities.
Whistleblowing is the term used when someone who works in or for an organisation wishes to raise concerns about malpractice or wrongdoing. It is regulated by The Public Interest Disclosure Act of 1998, also known as Whistleblowing Act.
Staff have a legal obligation to inform management of any concerns about colleagues not following the Code of Conduct. They will not be penalised for this, and the reporting of any concerns will remain confidential.
Please refer to TIE Whistleblowing Policy for further details.
TIE ensures that appropriate procedures and monitoring are in place for all accommodation to ensure the safety of the students. Additionally, host institutions generally have their own policies in place.
When allocating students, TIE will:
• place students of the same gender and close in age range in multiple-bedded rooms
• not place students of different genders in the same block, where possible (if it is not possible to separate by block, they will be separated by floor with appropriate supervision)
• under no circumstances place a student in the same room as an adult
• not accommodate students under 16 in the same room or apartment with 18-year-old students
TIE requires written confirmation that all employees of coaches and taxis companies are DBS checked.
TIE meets its child protection responsibilities by having a DSL, two deputy DLSs and ensuring that all TIE Staff are trained in Safeguarding and adhere to the Safeguarding Policy and all associated policies.
Nominated/ designated person
TIE DSL is:
Rosario Russo – Operations Manager
Tel: +44 (0)330 133 5138
TIE Deputy DSLs are:
Mark Cook – Managing Director
Tel: +44 (0)330 Tel: 0330 133 4988
Lewis Tonks – Group Academic Manager
There is also a DSS at each of our summer schools. The DSS is one of the management team at the school, generally the Centre Manager. TIE will ensure that all school staff, students, and Group Leaders are aware of who the DSS person is and what their role is.
When adults need to respond
TIE staff should immediately inform the DSS at their school or TIE DSL if they have concerns about a student’s safety or well-being. Scenarios might include:
• noticing or observing some strange or inappropriate behaviour, both student and staff
• being told about something by another person
• a student discloses an incident
Recognising symptoms of abuse
Identifying abuse can be difficult as the term is used to describe a wide range of ways in which people could harm children. Abuse is usually described as a form of maltreatment of a child and there are four main types of abuse:
• physical, a type of abuse that may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child
• emotional, the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on their emotional development
• sexual, a type of abuse that involves forcing or enticing a child or young person to take part in sexual activities
• neglect, 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.
Typical signs of abuse include:
• Unexplained injuries
• Aggressive behaviour
• Sexually explicit behaviour
• Serious distrust of adults or other students
• Isolation and difficulty in making friends
• Personality changes and behavioural changes
• Avoiding attending lessons or joining activities
• Not eating
All adults working with children should have an awareness of safeguarding issues that can put them at risk of harm.
In cases where any of the following issues are identified, TIE will follow the procedures listed below.
Child on child abuse
Child-on-child abuse, previously known “peer-on peer-abuse”, is any form of inappropriate behaviour between children that is abusive in nature. It may include, but may not limited to:
- bullying, including cyberbullying
- relationships abuse
- physical abuse
- sexual violence and sexual harassment
- consensual and non-consensual sharing of nude and semi-nude images and/or videos
- up skirting
Child sexual exploitation
Child sexual exploitation (CSE) is a type of sexual abuse which involves exploitative situations, contexts and relationships where young people receive something (money, gifts, drugs, alcohol) as a result of engaging in sexual activities.
Young people who are being sexually exploited may:
• go missing for periods of time from home, care or education
• have unexplained gifts or possessions that can’t be accounted for
• use drugs or alcohol
• have older partners
• be involved in petty crime such as shoplifting
• have unexplained physical injuries and a changed physical appearance
Domestic abuse can refer to a wide range of behaviours and may be a single incident or a pattern of incidents. It could be, but is not limited to: psychological, physical, sexual, financial or emotional.
FGM Female Genital Mutilation
Female Genital Mutilation (FGM) includes any mutilation of a female’s genitals, including the partial or total removal of the external genitalia for so-called cultural or other non-medical reasons.
It is illegal in England and Wales under the FGM Act 2003.
The Serious Crime Act 2015 introduced the duty for health and social care professionals and teachers in England and Wales to report to the police ‘known’ cases of FGM in under 18s which they identify in the course of their professional work.
Low Level Concerns
A low-level concern is any concern that an adult may have acted in a way that:
• is inconsistent with the staff code of conduct, including inappropriate conduct outside of work
• does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO
Examples of such behaviour could include, but are not limited to:
• being over friendly with children
• having favourites
• taking photographs of children on their mobile phone
• engaging with a child on a one-to-one basis in a secluded area or behind a closed door
• using inappropriate sexualised, intimidating or offensive language
It is crucial that any such concerns are shared responsibly and with the DSS at the school or TIE DSL, recorded and dealt with appropriately.
A child telling an adult (disclosure)
If a student discloses any information to a TIE representative suggesting that they have been abused in any way, this information should be acknowledged and taken seriously.
TIE staff should follow the “Four Rs framework”:
- listen carefully without assuming or jumping to conclusions
- ask open questions and avoid asking leading questions
- acknowledge how difficult it must have been to talk
- reassure the student that telling them was the right thing to do
- explain to the student that they have a legal obligation to report to someone else
- take notes, record dates and times and use the student’s exact words whenever possible
- inform immediately the DSS at their school or TIE DSL, who will record the disclosure using the Child Protection Incident Form
Staff should also be aware that the students may not feel ready or know how to tell someone that they are being abused, exploited, or neglected. This should not prevent them from having a professional curiosity and speaking to the DSS or TIE DSL if they have concerns about a child.
All records will be kept private and confidential by TIE DSL and Deputy DSL in secure electronic files and will be shared only with those who need access to it, whether to enable them to take appropriate steps to safeguard the pupil, or to enable them to carry out their own duties.
All records will be hold for two year and must contain the following:
• date of the incident
• date and time of the record being made
• name and date of birth of the child(ren) concerned
• a factual account of what happened and the location where the incident took place (include the actual words spoken by the child where possible)
• witnesses’ reports
• action taken
• printed name, signature and job title of the person making the record
If an adult is accused
Any concern over an adult’s behaviour towards a child must be reported to the DSS or the DSL.
If an adult is accused of abuse or inappropriate behaviour, the person receiving the complaint has to immediately inform the DSS or the DSL.
The person receiving the complaint will respond to any allegations following this procedure:
- listen and record the allegations using the Child Protection Incident Form
- investigate the allegations and decide what actions to take accordingly
- offer support to the student or take action to address any immediate concern for their safety
- if the adult accused is a staff member, TIE might suspend them throughout the investigation, if appropriate. If the adult accused is employed by a partner, TIE will inform the partner and require them to participate in or cooperate with the investigation
- contact the LADO, if necessary
- inform all parties involved of the investigation outcome
- referral to the Disclosure and Barring Service for consideration to be barred from working with children, if required
If TIE DSL is accused, the concern must be reported to Deputy DSL or the Local Safeguarding Children Partnership.
If a child is accused
If a child is accused of abuse or inappropriate behaviour, the person receiving the complaint has to immediately inform the Centre Manager or the Welfare Co-ordinator who will record the allegations using the Child Protection Incident Form and, in turn, inform the TIE DSL.
The DSL is responsible for ensuring that training is provided to all TIE Staff.
TIE Managing Director, the Operations Manager, the Operations Executive and the Group Academic Manager have Specialist Safeguarding (Level 3) for Designated Safeguarding Leads.
All TIE seasonal staff are required to have Basic Awareness (Level 1) and Prevent training and the DSSs are trained to Advanced Safeguarding (Level 2).
How training is delivered
Before commencing employment, this policy will be made available to all TIE seasonal staff, and they must complete:
- online Prevent Training by the Home Office
- Safeguarding Training
TIE recognises that Safer Recruitment practices are a vital part of creating a safe and positive environment and making a commitment to keep students safe from harm.
• applicants are informed of our commitment to safeguarding in the job advertisement and the invitation to interview
• all applicants must submit a CV with their application and all gaps in CVs must be explained satisfactorily
carrying out an online search for shortlisted candidates to identify any incidents or issues that have happened, and are publicly available online, and explore them with the applicant at interview, where required
• at interview, applicants are asked specific safeguarding questions to assess their suitability to work with children
• references are followed up in writing and/or verbally
• DBS or criminal record checks are performed on all successful candidates
• all job offers are conditional on a successful DBS check (or equivalent)
• proof of identity and (where applicable) qualifications will be required
• at least two written references are requested with specific questions whether there is any reason that prospective employees should not be employed in situations where they have responsibility for, or substantial access to, persons under 18
TIE will also ask for written confirmation from its partners and contractors that they will only deploy staff who have been DBS checked.
TIE’s commitment to safeguarding is stated in both the job advertisement and the invitation to interview through the below points:
• all gaps in CVs must be explained satisfactorily
• proof of identity and (where applicable) qualifications will be required
• references will be followed up with specific questions as to the applicant’s suitability to work with minors
• successful candidates will be required to undertake a DBS check (or equivalent)
• successful candidates will be required to complete Safeguarding and Prevent training before commencing employment
Applicants with a criminal record
TIE recognises the contribution that people with criminal records can make as employees and undertakes not to discriminate unfairly against any subject of a DBS check on the basis of a conviction or other information revealed.
If an applicant’s disclosure shows a criminal record, the information will be discussed with the applicant and an assessment will be undertaken to determine the relevance of any conviction to the particular post. The assessment criteria will include:
• seriousness and nature of the offence
• when the offence occurred
• circumstances and frequency of the offence/s
TIE Senior Management will make the final decision; If the prospective employee is allowed to work, a rationale will be provided and kept on file stating the reasons.
Applicants awaiting DBS
In the unlikely event that a staff member is required to commence work before the result of the DBS Disclosure has been received, TIE Senior Management may, at its absolute discretion, permit the individual to start work.
A risk assessment will be carried out to determine the level of risk posed to the welfare of the students by the individual in question. They will be allowed to work only if all other Safer Recruitment checks have been completed and additional mitigation measures may be implemented.
In the event that TIE is not satisfied with the DBS disclosure once received, the offer of employment may be revoked or, if work has commenced, employment may be terminated.
Group Leaders where criminal check was not possible
Agents are asked to provide beforehand a Working with Minor Declaration for any Group Leaders that travel with U18s.
Upon arrival, Group Leaders are requested to sign a self-declaration to confirm their suitability to work with children and there is no reason they should not be employed in situations where they have responsibility for, or substantial access to, persons under 18.
Single central record
Records will be kept with required headings to ensure that all necessary pre-appointment checks have been performed for TIE staff and Group Leaders.
Please refer to TIE Safer Recruitment Policy for further details.
Use of risk assessments
There are a general risk assessment and a fire risk assessment for each of our summer schools and risk assessments will be carried out for all activities and excursions.
All risk assessments will be signed, dated and filed.
As a minimum there is at least one adult per fifteen students, unless risk assessment may identify need for higher ratio.
The ratio comprises TIE Staff and Group Leaders.
Group Leaders are only responsible for their students.
TIE might accept independent students. If that is the case TIE will name one staff member who will act as a “Group Leader”, be responsible for their supervision, provide support and pastoral care.
It is the responsibility of TIE staff to search actively for students who are missing, including working with the authorities where appropriate. For the purposes of this policy, the term ‘missing’ refers to a student not being present without authorisation or explanation.
On occasions when a staff member identifies a student as missing, immediate action is required as outlined in the procedures below.
Group Leaders are required to communicate to the Director of Studies the name of students not attending lessons, before the beginning of the lessons. Individual students are required to communicate their absence to the TIE staff member responsible for their care. They will, in turn, inform the Director of Studies.
If a student is missing, the following procedure must be followed:
• teachers are requested to communicate unannounced absences to the Director of Studies as soon as possible and no later than 10 minutes after the beginning of the lesson
• the Director of Studies will call the Group Leader who will investigate the absence. In case of a missing individual student, the Director of Studies will inform the TIE staff member responsible for their care. They will call the student
• if the student is found, in absence of a valid reason, the student will be requested to attend
• if the student is not found within 15 minutes, the Director of Studies must inform the Centre Manager or the Welfare Manager immediately
• the Centre Manager and the Welfare Manager will initiate and oversee a search of the site, which may include the host institution security team
• if the student is not found within 30 minutes, the Centre Manager or Welfare Manger must inform TIE DSL. The Group Leader is requested to inform the parents
• all parties need to be informed as soon as the student is found.
• if the above stage is reached, a full record of all actions taken will need to be recorded
When on an excursion, TIE Staff are requested to frequently check that all students are present. If a student goes missing, staff must:
• ensure all other children are present and supervised
• contact the missing student
• if unsuccessful, they must contact the Activities Manager or the Welfare Manager(or the Centre Manager, if they are not contactable)
• ask other members of the group and the Group Leader when the student was last seen
• if there is an appropriate number of adults, one will look for the missing student
• if the student is not found within 30 minutes, inform TIE DSL. Request the Group Leader to inform the parents
• wait at the designated meeting point for as long as they can and if they are compelled to depart make sure another staff member stays there
• inform all parties as soon as the student is found
First aid & medical
At each of our schools, at least one staff member is first aid trained and there is at least one suitably equipped first aid box.
TIE Staff is also provided with details for the nearest medical centre and hospital and all Excursion Information Sheets include information about the nearest A&E.
Please refer to TIE First Aid and Medicines Policy for further details.
TIE will ensure, so far as reasonably practicable, to minimise the risks to staff and students, which may arise from fire whilst attending its courses.
This will be achieved by:
• carrying out a fire risk assessment of the premises and reviewing it regularly
• putting in place, and maintain, appropriate fire safety prevention measures and plans for emergencies
• ensuring that all staff, Group Leaders and students are aware of this policy and know how to behave in case of emergencies
• carrying out a fire drill at the premises within 48 hours of arrival and thereafter weekly
Please refer to TIE Health & Safety Policy for further details.
TIE arranges a transfer service on arrival and departure for all groups and individual students.
On arrival, an airport representative or TIE staff member will meet the students and accompany them to the coach bay or travel with them to the school. A member of TIE staff will meet the students at the school on arrival.
All under 18s are fully supervised from their point of arrival to their school and from their school to their points of departure.
All groups and individual students will be supplied with our pre-arrival information that contains the TIE emergency number.
In the case of individual students, TIE will arrange a transfer ensuring the driver has been DBS checked.
Unaccompanied Minors (UM)
On arrival, airline staff will pass the UM to a TIE representative or airport representative who will accompany the UM to their destination or hand them over to another TIE representative for transfer to their school.
On departure, an TIE representative will check in the student and will accompany the student until the airline staff member has taken the student through security, immigration and into the departure lounge.
The TIE representative must not leave the airport until the flight has left in case the flight is cancelled and the student is handed back to TIE for further supervision until a suitable replacement flight has been arranged.
TIE recognises that the Internet and social media are places where abuse can take place and is committed to ensuring that all students will be able to use all technologies safely.
TIE will put into place procedures to support and promote E-safety for its students and staff.
Radicalisation & Extremism
In line with the Counter-Terrorism and Security Act 2015 and as part of our responsibility to keep students safe, TIE is committed to preventing extremism and radicalisation.
TIE promotes a safe and supportive multi-cultural environment where students are educated about democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.
All TIE Staff are required to complete online Prevent training before commencing employment
Please refer to TIE Preventing Extremism and Radicalisation Policy for further details.
Provision for those more vulnerable
TIE will make special provision for more vulnerable students and staff are encouraged to be particularly vigilant to their well-being and needs.
Local Safeguarding Children Partnership
TIE Head Office
Kensington and Chelsea, Westminster Children Partnership
c/o 1st Floor (Purple Zone) Kensington Town Hall, Hornton Street, London W8 7NX
Telephone: 07739 315388
LADO – Aqualma Daniel
Telephone: 07870 481712
Prevent lead – Kiran Malik
Telephone: 01962 876364
Hampshire Prevent Partnership Board
Concerns can be discussed with the Local Safeguarding Team
Children: 0300 555 1384
Adults: 0300 555 1386