The purpose of this policy is to help create a safe and positive environment for children, it clarifies what is required of Study Links, in relation to the protection of children.
This policy helps to demonstrate Study Links’ commitment to safeguard children from harm, whilst deterring those who would wish to abuse children from joining Study Links. It sets out standards of behaviour expected at Study Links, and what to do if they notice, or are told about inappropriate behaviour.
This policy also provides a basis of protection for Study Links employees and persons acting on behalf of Study Links.
The welfare of children at Study Links is paramount, every employee is committed to do everything possible to ensure that children are protected from harm at all times.
For the purposes of this Child Protection Policy (CPP), all references to ‘child’ or ‘children’ – whether singular or plural – are used and are taken to refer to students enrolled at a school or other educational institution in the United Kingdom who are in the care of Study Links.
‘Guardianship Organisation’ or STUDY LINKS INTERNATIONAL LTD (Study Links) are used and are taken to refer to the company or organisation or individual employed by parents to be the Educational Guardians of a child in the UK.
‘Guardianship personnel’ means an educational guardian having any responsibility for a child as defined in the contract during that contractual period. This may also refer to any personnel at Study Links, whether paid or unpaid, whether under a contract of service or apprenticeship, under a contract for services, or otherwise than under a contract, who has similar responsibility for a child and may be interacting with children for or on behalf of Study Links. The normal duties of guardianship personnel include caring for, supervising or being in sole charge of children; they also involve unsupervised contact with children under arrangements made by a responsible person.
Study Links’ principles for the protection of children
Study Links recognises that child protection is not only a legal obligation but also an organisational and individual’s responsibility.
Study Links expectations, in terms of behaviour and good practice for working with children. Study Links believes that everyone involved must accept responsibility and take precautions to help create a safe environment for children. This requires every employee to be well informed and aware of child protection issues. Children, their parents and house staff should know that there is always a responsible adult within Study Links whom they can approach if they are worried or in difficulty. Study Links ensures that everyone involved is well informed and aware of child protection issues. Study Links ensures there is an ethos where children feel secure and are encouraged to talk.
Study Links has guidelines for responding appropriately if abuse of a child is alleged, disclosed, discovered or suspected. Study Links encourages openness about concerns relating to child protection matters, because child abuse thrives on secrecy. Guidelines in this policy explain what should be done about those concerns.
Types of abuse and neglect:
Study Links ensures everyone is 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 and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or by another child or children. Types of abuse include:
- Physical abuse: this can involve hitting, shaking, throwing, poisoning burning or scalding, drowning, suffocating, female genital mutilation (FGM), gender based violence or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
- Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, hated, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, faith abuse or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.
- Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
- 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. 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.
A full list of government definitions of abuse can be found on the official government website.
Study Links has a Child Protection Co-ordinator (SLCPC) / Lead Safeguarding Officer, Ailie Fan who can be contacted on [email protected] and 01274 679710. If you are unable to reach Ailie Fan, you can contact the deputy, Dianne Senior on [email protected] and 01274 679710.
Study Links Child Protection Co-ordinator, and the deputy are responsible for:
- being conversant with all legislation including regulations relevant to the law of Child Protection.
- holding and being fully conversant with the Guidance and Regulations of the Children Act 1989, or any legislation subsequent to that Act.
- briefing guardianship personnel on the contents of the guidance and
procedures and on the procedures. This includes the briefing of new guardianship personnel as part of their induction after joining Study Links.
- ensuring the procedures below are followed within Study Links.
- liaison over child protection procedures with the Social Services Department.
- receiving reports of alleged or suspected child abuse within Study Links or reported by a child relating to incidents at home or outside Study Links, contacting where appropriate the relevant Local Safeguarding Children Board and taking other action in response, as set out below.
- ensuring that all records of concern about a child, even if there is not a need to take any immediate action, are kept confidentially and securely.
All who work at Study Links should be aware of:
The need to report allegations or suspicions of child abuse to the relevant person at Study Links. Children often tell other children, rather than guardianship personnel or other adults, about abuse.
Study Links should keep accurate and unchanged/unchangeable records of alleged or suspected abuse, even if such abuse is only a minor incident.
The CPC has responsibility for receiving complaints of abuse, investigating those complaints and reporting any complaints to the appropriate authority.
Safeguarding and Child Protection Training of Study Links Employees and Homestays
Study Links complies with Local Safeguarding Children Boards, established by the Children Act 2004, which gives statutory responsibility to each locality to have in place a mechanism whereby each local Safeguarding Children Board ensures that key agencies work together to keep children safe.
Local Safeguarding Children Boards are also key to supporting and enabling Study Links to adapt their practice and become more effective in safeguarding children.
For these reasons, Study Links has established and maintains links with its local Safeguarding children Board: Bradford.
Bradford Council provide the requisite level of safeguarding and child protection training for Study Links.
Lines of communication within Study Links
Who should you speak to if you believe there is a problem?
If you are able you should speak with Study Links Child Protection Co-ordinator, or their deputy.
If a child has disclosed anything to you, then you need to advise SLCPC, as soon as you are able.
If you are at all concerned, about a child you can speak directly to your Local Safeguarding Children Board, or Bradford Safeguarding Children’s Board: they can be contact on 01274 437500, if you have contact the Local Safeguarding Children Board directly please also speak to SLCPC as soon as you are able.
Parents, in a similar way, should report alleged abuse to one of the guardianship personnel or the Child Protection Co-ordinator at Study Links or one of the house staff at school, depending on whom the alleged abuser is.
Any person responsible for the welfare of a child has a duty under English law to report any suspicions of abuse to the relevant authority.
How Study Links should respond to any suspicion of abuse
Any employee of Study Links who is told of any incident or has strong suspicion of any abuse must report the information to the SLCPC. (In the absence of the SLCPC, an immediate report should be made to the deputy).
If a child or group of children disclose the fact that they are upset or worried, or if a child or group of children give the appearance of being upset, every effort should be made to keep the individual or group of individuals calm and not distressed. It is not appropriate to try to force conversation whilst there is an emotive atmosphere. The individual(s) concerned should be
taken to a private place where, if the situation warrants it, a second responsible adult should be asked to be present. The following guidelines should be observed:
- Confidentiality should never be guaranteed. Study Links employees or anyone acting on behalf of Study Links should guarantee only that they will pass on information to the minimum number of people who must be told to ensure that the proper action is taken to sort out the problem, that they will never tell anyone who does not have a clear ‘need to know’ and that they will personally take whatever steps they can to protect the informing child/children or guardianship personnel from any retaliation or unnecessary stress that might be feared after a disclosure of alleged abuse has been made.
- Any questioning should be limited to the minimum necessary to seek clarification only, strictly avoiding ‘leading’ the child or adult who has approached them by making suggestions or asking questions that introduce their own ideas about what may have happened. (Questions such as, ‘Did he do X to you?’ should not be used; instead a minimum number of questions of the ‘Tell me what happened?’ type may be asked.)
- The alleged perpetrator should not be criticised because the child’s emotions may already be horribly mixed. The child should not be asked to repeat everything that s/he has already disclosed to another member of the guardianship personnel.
- As soon as the child or adult has disclosed that he or she believes that something abusive has happened to him or her, or to someone else, no further questions should be asked of him or her. Further questioning could cause more damage and prejudice possible criminal proceedings.
- The informing child or adult should be asked what steps s/he would like taken to protect him/her now that the allegations have been made and should be given an assurance that Study Links will try to follow these wishes.
- The matter should be referred immediately, with all relevant details, to the CPC at Study Links.
- The adult to whom the disclosure has been made should make a written record as soon as possible of what s/he has been told. The record should not include the writer’s own assumptions and interpretations but solely what s/he has heard and seen. Original notes should not be destroyed, even if the record may be written up more neatly and fully at a later stage. The record should comprise dates, times, places, plus any non-verbal behaviour as well as words used, including sexual words (if any used). If injury is apparent, a diagram should be appended in order to give exact location.
- An allegation of abuse should never be discounted simply on the grounds of the child’s location or because the alleged abuser is someone well known to and trusted by the individual to whom the disclosure has been made.
Action by Study Links
When the SLCPC at Study Links receives an allegation of abuse they should:
- take any steps needed to protect any child involved from risk of immediate harm. Furthermore, Study Links should take any necessary steps for the longer-term protection and support of each child who has made allegations of abuse, or who is alleged to have suffered from abuse, taking his or her wishes fully into account. This may involve the child receiving continuing support and protection from the guardianship personnel chosen by him or her, or changing accommodation, or returning to his or her parents temporarily.
- not interview or investigate the allegation further but refer the matter immediately to the Children’s Social Services at the local Social Services office. Study Links should speak personally to the Duty Team Leader and not rely on leaving a message.
- consult with the Duty Team Leader regarding contacting parents, other guardianship personnel, police, doctor or the alleged perpetrator or witnesses directly. Whilst Study Links has a duty first and foremost to the child, it must at all times respect the rights of parents and keep them informed of all matters relating to the child.
- contact the Team Manager in the Social Services Department (SSD) who will initiate an independent investigation if this proves to be necessary. The Team Manager will arrange, within pre-set limits, the involvement of the relevant specialist police personnel and, if necessary, a meeting of the agencies who may need to be involved, together with Study Links.
- inform the child or guardianship personnel who made the initial allegation of what the next steps are to be, having agreed these with the Team Manager. It is helpful for the call to the Team Manager to be made while the child or adult is in attendance, so that he or she can be told the likely next steps immediately after the call.
- inform the Head teacher of the school the child is attending (unless s/he is the subject of any of the allegations or suspicions) of the allegation and the action as taken above and, if the allegation is concerning an incident within the School context, agree necessary further action in line with these standards.
- if necessary, cease to use, pending investigation, any member of its guardianship personnel who is alleged to have abused a child or children. Study Links will not hesitate to cease to use any member of the guardianship personnel, without prejudgement of guilt and as a precautionary measure, where there is a concern about possible abuse.
- take any necessary steps to protect and support a child who is alleged to have abused another and inform his/her parents immediately.
- ensure that any child being interviewed by the police has available supportive guardianship personnel of his or her own choice to accompany him or her if this becomes necessary.
- make arrangements, where feasible, for any child who has been the subject of abuse to receive any necessary continuing counselling and support, by agreement with his or her parents where appropriate.
Allegations of abuse against an employee or any one working with or for Study Links.
Following investigation, Study Links should consider taking, and if necessary and appropriate, should take the necessary measures to safeguard the child against any member of the guardianship personnel or of his/her household, where it believes children are at risk of abuse from that member of the guardianship personnel or of their household, even in cases where there may be no criminal prosecution. Cessation from a role within the guardianship personnel (without prejudice) may be necessary to protect all concerned, including the guardianship personnel or his/her household member.
Study Links must make its own decision on whether a child’s welfare is at risk, whatever the outcome of a police or Social Services Department investigation may be. The level of evidence needed for criminal prosecution is likely to be higher than that which may trigger valid and appropriate precautionary proceedings taken by Study Links.
Appropriate precautionary proceedings and grounds for concern over its children’s welfare may therefore be based on ‘balance of probability’, rather than on evidence ‘beyond reasonable doubt’.
In any instance of an allegation of child abuse Study Links will, after reasonable investigation and if satisfied on a balance of probabilities that there is substance to the allegation, immediately terminate any contract or other arrangement with that member of the guardianship personnel or other person. Study Links has a duty to terminate any possible contact between the child and that person.
Where a Guardianship Organisation has ‘low level’ concerns that do not amount to allegations or suspicions of specific abuse, but which may indicate the possibility of abuse occurring, the Director of Study Links or designated member of staff should discuss these with the Social Services Department.
Recruitment and screening at Study Links
Study Links, ensures that when using outsourced services (e.g. taxi firms) whose employees may have contact with a child, must obtain a written assurance from the service provider that all such employees have been subjected to enhanced Disclosure and Barring Service checks (DBS checks) and other relevant checks done according to the principles and guidelines of the AEGIS Code of Practice.
Study Links makes all Study Links employees, Student Support Representatives, Academic Consultants and Homestay Hosts aware of Study Links Child Protection Policy, and are asked to sign a declaration. Study Links takes up no fewer than two references as to the character and suitability of any person under their control and their suitability to have contact with a child.
All Study Links employees and those working with Study Links must declare any history, criminal or civil, of child abuse. Enhanced Disclosure and Barring Service checks are sought to confirm this. Permission to interact with children is dependent upon a judgement of these declarations and the results of an enhanced DBS check.
If any employee of Study Links or working with Study Links is a risk to children, they will not be allowed to work with Study Links.
Complaints and abuse
Study Links ensures that key people who deal with complaints and concerns are fully aware of this policy document and that there is the possibility of certain complaints understating an allegation of abuse and therefore any such complaints should be routed via the appropriate channels.
It is important to realise that the Children Act will inevitably lead to some investigations being triggered which do not substantiate the allegations made, as well as those that do. It is a basic
assumption that it is better to accept some false alarms than to fail to initiate the specialist investigation of instances of real abuse. The Local Safeguarding Children Board will work with Study Links personnel, parents and children involved in any false alarm investigation to assist in recovery from the incident, as well as working with the Study Links to assist in ‘living through’ and recovering from a substantial investigation.
We recognise that children cannot be expected to raise concerns in an environment where adults fail to do so. All adults involved in Study Links provision of care should be aware of their duty to raise concerns, where they exist, about the management of child protection, which may include the attitude or actions of other adults. The Whistleblowing policy can be found in the handbook.
Advice on one-to-one contact with children
Study Links employees and those working with Study links should be wary of placing themselves in situations where they are open to accusations of inappropriate conduct. Essentially this involves exercising common sense.
- If in conversation with a child in a room or a car, for example, a respectful distance should be observed. Study Links employees, those working with or for including a member of their household should never be alone with the child in the bedroom with a closed door. If an adult member of their family is involved in corrective and personal guidance of a child, it is advisable to take precautions: e.g., if inside the house, by leaving the door to the room open, remaining seated at a reasonable distance from the child, ensuring there is a witness when appropriate or that there is another responsible adult in the house where possible.
- It is not wise to invite a single child into a bedroom or bathroom. On occasions it will be unavoidable that a single child will be transported in a member of the Study Links personal vehicle. It is prudent on such occasions to ensure that the child passenger sits on the rear seat to reduce the possibility of accidental contact, which might be misconstrued.
- It is good advice not to make physical contact with a child. This is most important advice in a one-to-one situation between a member of Study Links and a child. Study Links employees and those working with Study Links should note that, in one-to-one discussions, confidentiality should not be promised to the child.
- Exclusively intimate situations with a child that could either arouse undue suspicion or lead to misinterpretation and false allegations should be avoided.
Further information can be found at
This policy is reviewed annually taking into account any changes in legislation, practice or roles concerned throughout the year.