Policies 2025

Berkeley Guardians is unequivocally committed to safeguarding and promoting the welfare and wellbeing of every young person and member of staff in our care. We believe that everyone – without exception – has the right to:

• live free from harm, abuse, exploitation and discrimination
• be treated with dignity, fairness and respect
• have their voice heard and their views considered in all matters affecting them

We recognise that children learn and thrive when they are healthy, safe, secure and feel confident to share worries or concerns. Safeguarding and promoting welfare means:

• protecting children from maltreatment
• preventing impairment of their mental and physical health or development
• ensuring they grow up in circumstances that provide safe, effective care
• taking timely action to enable all children to achieve the best possible outcomes

This policy applies to all Berkeley Guardians staff, directors, volunteers, contractors and host families, and underpins our close-working partnerships with schools, local authorities and other safeguarding agencies. It covers any setting or activity in which staff or host families are working with pupils.

A copy of this policy is published on our website and is available in large-print or alternative formats on request.

Statutory Framework and Guidance

• Keeping Children Safe in Education (DfE September 2025)
• Working Together to Safeguard Children (HM Government July 2023)
• Prevent Duty Guidance for England and Wales (Home Office July 2023)
• Education (Independent School Standards) Regulations (April 2019)
• National Minimum Standards for Boarding (DfE September 2022)
• What to Do If You’re Worried a Child Is Being Abused (DfE March 2015)
• Safeguarding Children and Young People (Independent Schools Inspectorate July 2022)
• Children Missing Education (DfE September 2016)
• Charity Commission: Safeguarding and Protecting People (2019)
• Equality Act (2010) and Human Rights Act (1998)

Our Commitment to Continuous Improvement

We maintain active membership of SACPA, BSA and AEGIS, and draw on NSPCC training and sector-wide briefings to ensure our staff, host families and governors remain abreast of emerging risks, legislation and best practice—preparing us for forthcoming duties such as mandatory reporting under the Crime and Policing Act.

Safeguarding and promoting the welfare of children is defined as protecting children from maltreatment; preventing impairment of children’s mental and physical health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes. (Keeping Children Safe in Education, September 2023)
This policy applies to all pupils cared for by the Guardianship and to acknowledge the close-working partnership with which we work alongside our partner schools.
The purpose of this policy is to inform all staff (including host families), parents about the Guardianship’s responsibilities for safeguarding children and to enable all parties to have a clear understanding of how these responsibilities should be carried out. It applies wherever staff/host families etc. are working with pupils.
This policy is published on the Guardianship website and is available to parents, schools and host families from the Designated Safeguarding Lead on request. Large print or other accessible formats can also be made available.
This policy is also in accordance with current legislation and the following statutory guidance:
• Keeping Children Safe in Education September 2023 (KCSIE)
• Working Together to Safeguard Children July 2018 (updated 2023) (WTSC)
• Prevent Duty Guidance for England and Wales July 2023
• Education (Independent School Standards) Regulations April 2019
• Boarding Schools: National Minimum Standards (September 2022)
• What to do if you are worried a child is being abused – advice for practitioners March 2015
• Safeguarding children and young people July 2022
• Children Missing Education September 2016
• Charity Commission guidance: safeguarding and protecting people for charities and trustees 2019
• The Equality Act (2010)
• The Human Rights Act (1998)

Every complaint or suspicion of abuse from within or outside the Guardianship will be taken seriously and action will be taken in accordance with this policy.

Berkeley Guardians is a member of SACPA and uses this membership to update safeguarding training, read and update through regular newsletters and in its membership of BSA and AEGIS keep up to date in all areas of safeguarding whether in training or awareness and practical support. NSPCC training is also used to ensure that the breadth of understanding is in place across all areas of child protection and safeguarding.

Berkeley Guardians requires all staff and host families to share our commitment to safeguarding and promoting the welfare of every pupil. We aim to create a secure environment with strong pastoral support so that any child who has experienced abuse can report it confidently, without shame, and receive full support.

• Maintain clear, confidential reporting routes and take every concern seriously.
• Ensure DSL and DDSL are trained to listen, identify risks early, follow agreed procedures and liaise with the pupil’s school.
• Apply rigorous safer-recruitment checks to all staff and host families to confirm suitability.
• Work alongside multi-agency partners, schools and local authorities to provide early intervention and coordinated support.
• Stay vigilant for signs of abuse—whether in homestays, schools or external settings—and protect pupils from adults or peers.
• Manage allegations sensitively to support victims, follow child-protection plans and safeguard innocent staff from false claims.
• Accommodate pupils’ physical and mental health needs through tailored care and clear health-and-safety protocols.
• Enforce homestay policies on drugs, alcohol and substance misuse.
• Assess and mitigate risks of radicalisation, identify pupils vulnerable to extremist ideas and act in line with the Prevent Duty.
• Secure host-family premises to the greatest extent practicable.
• Provide incoming pupils with up-to-date safeguarding guidance before they arrive in the UK.
• Routinely review safeguarding procedures and promptly address any deficiencies.

Safeguarding and child protection are everyone’s responsibility. All staff, host families and volunteers must:

• Provide a safe environment where pupils can live, study and relax.
• Prioritise the best interests of each pupil and support them to achieve positive outcomes.
• Attend annual safeguarding and child-protection training (and additional sessions if directed by the DSL).
• Recognise indicators of abuse, neglect, mental-health needs, radicalisation and extremism.
• Follow our safeguarding procedures independently when required.
• Record all significant concerns, conversations or events accurately and promptly.
• Report any safeguarding concerns to the DSL (or DDSL) without delay and cooperate with social care or other agencies after referral.

The Designated Safeguarding Lead (DSL)

The DSL is a senior member of the leadership team with ultimate responsibility for safeguarding, child protection and online safety. Berkeley Guardians ensures the DSL has the time, funding and resources to fulfil their duties.

Key Responsibilities

• Managing Referrals
  • Refer concerns of abuse, neglect, radicalisation or other harms to Local Authority Children’s Services, the Channel programme, DBS and/or police.
  • Track progress and follow up on multi-agency actions.
• Multi-Agency Liaison
  • Act as the principal contact for staff, host families, parents and schools on safeguarding matters.
  • Foster supportive partnerships with local safeguarding partners, social care and law enforcement.
• Record-Keeping & Information Sharing
  • Maintain an up-to-date, confidential child-protection file with clear records of decisions and actions.
  • Securely transfer records to a pupil’s new school or relevant agency without delay.
• Policy Review & Awareness
  • Review and update the Safeguarding Policy at least annually (or sooner to reflect legislative changes such as KCSIE 2025).
  • Ensure all staff and host families understand the policy, know how to access it, and are aware that referrals may be made.
• Training, Knowledge & Online Safety
  • Complete advanced DSL training and regular updates on child-protection, online risks and the Prevent Duty.
  • Advise on safe use of technology and filtering/monitoring systems.
• Supporting Staff & Host Families
  • Provide ongoing guidance, mentoring and supervision on welfare and safeguarding concerns.
  • Build staff confidence in identifying risks and making referrals.
• Listening to Children
  • Promote a culture of listening, respect and pupil voice in all safeguarding matters.
  • Help staff and host families form trusted relationships that encourage children to share concerns.

Induction

All new staff, volunteers and host families (over 16) receive formal child-protection training before working with pupils. This covers:

• Our Safeguarding Policy and related policies (Preventing Bullying & Cyber-bullying, E-Safety, Mental Health, Prevent)
• Part 1, Part 4 and Annex B of KCSIE
• DSL and DDSL roles, contacts and Referral Procedures
• Acceptable Use of IT, Online Safety guidelines and Staff Code of Conduct (including low-level concerns)
• Whistleblowing Policy and LSCP procedures overview

Key documents are issued in paper or electronically, accessible via our shared drive, and staff must confirm they have read and understood them.

Mandatory Updates

• All staff (including Directors) complete whole-staff child-protection and safeguarding training every two years (per LSCP guidance).
• Annual refresher sessions, e-bulletins and policy re-issues ensure everyone remains up to date.
• Safer Recruitment training is provided to all involved in hiring panels.
• Training partners include NSPCC, Three Rivers, AEGIS, BSA/SACPA, covering Online Safety and the Prevent Duty.

Targeted Training

The DSL team regularly reviews and tailors training to address emerging risks and local needs, for example:

• Mental health first aid
• Peer-on-peer abuse, sexual violence and harassment
• Online safeguarding and cyber-exploitation
• Radicalisation and the Prevent Duty
• Child sexual and criminal exploitation
• Female Genital Mutilation (FGM) awareness

Host families complete the AEGIS online safeguarding modules, updated regularly.

DSL & DDSL Professional Development

DSL

• Advanced Level 3 DSL qualification, refreshed every two years
• Prevent awareness, Online Safety, Safer Recruitment, First Aid and Mental Health training (annual updates as required)
• Ongoing professional development in:
  • Promoting a culture of listening to children
  • Early help assessment and multi-agency intervention
  • Local child-protection conference processes
  • Supporting pupils with SEND or other vulnerabilities

DDSL

• Level 3 DSL training, Online Safety, Safer Recruitment, First Aid and Mental Health Awareness
• Provides cover for the DSL and supports staff with welfare and safeguarding queries

Berkeley Guardians believes that timely, “early help” prevents problems from escalating. We recognise that pupils may face stress, peer pressure, body-image worries, mental-health or relationship challenges and ensure staff understand these risks.

Pupils are encouraged to speak up at the first sign of difficulty—either to their host family or directly to the DSL—so we can provide targeted support without delay.

When a member of staff identifies a pupil who may benefit from early help, they must consult the DSL. The DSL will apply the Bristol Safeguarding Children Partnership’s threshold criteria, agree next steps and work closely with the pupil’s school.

Certain pupils are particularly vulnerable and may need proactive support:

• Disabled pupils or those with SEN/EHC plans
• Learners for whom English is an additional language
• Young people in private foster care
• First-time boarders living away from home
• Pupils facing challenging family circumstances
• Those showing early signs of anti-social or criminal behaviour
• Young people misusing alcohol or drugs
• Pupils at risk of radicalisation or exploitation
• Those exhibiting early indicators of abuse, neglect or mental-health issues
• Young people subject to discrimination based on race, faith, sexuality, gender identity or other protected traits

Abuse or neglect can be harder to spot in these groups because:

• Behaviour changes may be attributed solely to a disability
• SEND/EAL pupils are more prone to isolation or prejudice-based bullying
• Hidden impact of peer-on-peer abuse without obvious signs
• Communication or cognitive barriers hinder disclosure
• Difficulty distinguishing online content from reality, leading to repeated harmful behaviour

Early identification and tailored support ensure every pupil in our care can thrive safely.

All staff and host families must stay alert to indicators that a pupil may need help or protection. Children may not recognise or know how to disclose abuse, neglect or exploitation. Building trusting relationships, exercising professional curiosity and speaking to the DSL/DDSL at the first sign of concern reduce barriers to disclosure.

Understanding Abuse and Harm

Abuse or neglect can be an act or omission that causes—or fails to prevent—harm. It can occur:

• Within families, institutions or the community
• Face-to-face or wholly online (using technology to facilitate abuse)
• By adults or other children (child-on-child abuse)
• As serious bullying, which becomes a child-protection issue when significant harm is suspected

Four Main Categories of Abuse

1. Physical Abuse
   • Hitting, shaking, burning, drowning, suffocation or other physical harm
   • Fabricating or inducing illness
2. Emotional Abuse
   • Persistent maltreatment causing adverse emotional development
   • Conveying worthlessness, silencing or excessive expectations
   • Includes serious bullying, witnessing domestic abuse, exploitation
3. Sexual Abuse
   • Forcing or enticing a child into sexual activities, with or without violence
   • Contact acts (penetrative or non-penetrative) and non-contact acts (grooming, sharing sexual images)
   • Can be perpetrated by adults or other children
4. Neglect
   • Persistent failure to meet basic physical or psychological needs
   • Failing to provide food, shelter, supervision or medical care
   • Neglect of a child’s emotional needs

Other Forms of Harmful Exploitation

Staff should also be aware of:

• Child Criminal Exploitation (CCE) and County Lines
• Child Sexual Exploitation (CSE)
• Children Missing from Education
• Child-on-Child Abuse, including Sexual Violence & Harassment
• Domestic Abuse
• Honour-Based Abuse (HBA) and Female Genital Mutilation (FGM)
• Forced Marriage
• Radicalisation & Extremism

All staff and host families must recognise that pupils’ safety and wellbeing are influenced by environments beyond home and school. Contextual safeguarding (Keeping Children Safe in Education, Part 1; Working Together 2023) requires us to assess risks arising in the community, online and peer groups, and to respond accordingly.

• Awareness of Extra-Familial Harms • Sexual exploitation and grooming (CSE) • Criminal exploitation and county-lines (CCE) • Serious youth violence, gangs and knife crime • Hate-motivated abuse (race, religion, sexuality, gender identity) • Modern slavery, trafficking and radicalisation • Online harms and image-based sexual abuse
• Listening and Logging Concerns • Use CPOMS (or our secure incident log) to record contextual concerns—what happened, where and who was involved. • Note patterns of behaviour or hotspots (e.g., unsupervised gathering places, routes to school). • Exercise professional curiosity: ask open questions about a pupil’s friendships, community activities and online contacts.
• Reporting and Referral • Escalate contextual risks immediately to the DSL/DDSL for a multi-agency risk assessment under the Bristol Safeguarding Children Partnership thresholds. • Work with schools, police, youth offending teams and community organisations to share intelligence and coordinate interventions. • Develop a contextual risk-management plan with clear actions, timescales and review dates.
• Prevention and Partnership • Include contextual risks in homestay risk assessments and health-and-safety reviews. • Educate pupils on how to identify and avoid dangerous situations outside school and home. • Engage local stakeholders—transport providers, sports clubs, faith groups—to build safer community networks. • Ensure that contextual safeguarding features in annual policy reviews, staff training and homestay inductions.

By embedding contextual safeguarding in our daily practice, we ensure that pupils are protected from harm wherever it occurs and can access support as soon as they need it.

Berkeley Guardians ensures pupils can raise concerns safely—through their host family, Guardian Angel, or directly to the DSL/DDSL. “Help and Advice” posters (Childline, Children’s Commissioner) are displayed in homestays, and our safeguarding leaflet is issued before arrival in the UK.

Responding to a Disclosure

• Immediately stop other activities; give the pupil your full attention.
• Listen carefully, allow silences, keep an open mind.
• Ask only brief, open questions for clarification (what, when, where), avoiding leading or multiple-choice prompts.
• Do not investigate, judge or promise absolute confidentiality. Explain that you must share with the DSL to ensure proper action (KCSIE 2025, Part One; Working Together 2023).
• Report verbally to the DSL/DDSL without delay. Share further only on a strictly need-to-know basis.

Recording the Disclosure

Record the disclosure as soon as possible using CPOMS or our secure incident log. Entries must be:

• Factual and precise, using the pupil’s own words in quotation marks.
• Date-, time- and place-stamped.
• Inclusive of non-verbal behaviours (e.g. facial expressions, body language).
• Documenting who was present or informed.

Any physical evidence (notes, devices, clothing) must be kept intact and handed to the DSL immediately for secure scanning and filing. Do not create or retain personal copies.

Online Material

Under no circumstances should staff or host families view or forward suspected illegal images of a child. If an incident involves indecent images or digital content:

• Secure the device without examining the content.
• Seek DSL guidance and follow the DfE “Searching, Screening and Confiscation” (2025) and UKCIS “Sharing Nudes and Semi-Nudes” (2020) protocols.

By listening attentively and keeping accurate, confidential records, we ensure every pupil’s voice is heard and acted upon in line with statutory guidance.

When any member of staff or a host family becomes worried that a pupil’s welfare may be at risk—even if you are unsure—act without delay.

Immediate Actions

• Report verbally to the DSL (or DDSL) as soon as possible.
• If the concern is an allegation against a staff member or host family, follow the “Allegations Against Staff”procedure (Section 12).
• Do not assume someone else will share the information.
• Record all details in writing immediately (CPOMS or secure incident log):
• Date, time, location and people involved
• Exact words spoken by the pupil (in quotation marks)
• Your observations, actions taken and who you notified
• Follow any instructions given by the DSL. Take no further action unless directed.

Female Genital Mutilation (FGM)

• If you discover that FGM appears to have been carried out on a girl under 18, you must report it to the police immediately (Children Act 2004; Serious Crime Act 2015).
• Notify the DSL as soon as you are able, unless you have a compelling reason not to do so.

Preventing Radicalisation

• Concerns that a pupil is at risk of radicalisation or extremist ideologies must be reported to the DSL under the Prevent Duty (Counter-Terrorism and Security Act 2015).
• The DSL will consider a Channel referral in line with local multi-agency procedures.

Mental Health and Early Help

• If the concern relates to a pupil’s mental health or wellbeing, discuss it with the DSL promptly.
• The DSL may initiate an Early Help assessment (Working Together to Safeguard Children 2023) and liaise with the school and external agencies.

Direct Referral to Children’s Social Care

In exceptional circumstances—such as imminent risk or lack of appropriate response—you or the host family may refer directly to children’s social services. If you do so:

• Inform the DSL as soon as possible.
• Keep a written record of your referral and any feedback received.

Escalation and Review

• If you believe the pupil remains at risk after reporting, escalate to the local authority’s Designated Officer or the NSPCC helpline.
• The DSL will review all welfare concerns at least termly, monitor patterns and update risk assessments in line with KCSIE 2025.

When notified of any welfare or safeguarding concern, the DSL will:

• Consider whether the matter meets the threshold for a statutory referral to children’s social care or the pupil’s school.
• Decide if an immediate referral to the police or the Channel programme (Counter-Terrorism and Security Act 2015) is required.
• If the concern does not meet statutory thresholds, determine whether early help is appropriate (Working Together 2023).
• Keep the pupil’s wishes and feelings at the centre of all decisions.
• Record the rationale for every decision and action taken.

Decision-Making Factors

When deciding next steps, the DSL will weigh:

• The pupil’s best interests and safety
• Nature, seriousness and context of the concern
• Local Authority safeguarding thresholds (Bristol SCP criteria)
• Pupil’s age, understanding and views
• Multi-agency safeguarding procedures and information-sharing protocols
• Any known patterns or contextual risks affecting the pupil

Early Help and Review

If early help is chosen:

• Work jointly with the pupil’s school and other agencies to agree a support plan.
• Monitor progress and review within agreed timescales.
• Refer to children’s social care without delay if the pupil’s situation does not improve.

Record-Keeping

The DSL team will maintain confidential records for every concern, including:

• A clear summary of the issue and pupil’s views
• Details of actions taken, decisions made and referrals initiated
• Outcomes and any further plans

Access to these records is restricted to the DSL and authorised deputies only.

Statutory Referrals

Child in Need

• When a pupil has unmet needs falling below the threshold of significant harm, the DSL will refer to children’s social care under the Children Act 1989.
• Parental consent is not required, but where possible parents should be involved in the process.

Child at Risk of Harm

• If a pupil is in immediate danger or at risk of significant harm, the DSL will make an urgent referral to children’s social care and/or the police.
• Notify the school’s DSL if the pupil attends another setting.

Referral Confirmation and Escalation

• Confirm any telephone referral in writing within 24 hours.
• Expect written feedback from children’s social care within one working day.
• If no response is received, the DSL will re-contact children’s social care to escalate.
• Anyone can make a direct referral in exceptional circumstances; the DSL must be informed as soon as possible.

Multi-Agency Cooperation

• Collaborate fully with children’s social care, police and the Channel panel.
• Provide information promptly—within five to ten working days—for Prevent or police enquiries.
• Contribute to strategy meetings, child-protection conferences and planning.

Unsubstantiated or Malicious Reports

• If a referral is deemed unsubstantiated, the DSL will consider whether the pupil or reporter needs support or further assessment.
• In cases of deliberately false or malicious allegations, the Guardianship will consider disciplinary action in line with staff or host-family conduct procedures.

Parents or carers will normally be told if we take any safeguarding action concerning their child. However, the DSL may delay or withhold information if:

• Consulting the LADO, children’s social care or the police indicates that parental notification could compromise an investigation or place the child at further risk (KCSIE 2025, Part Four).
• In cases of suspected honour-based abuse or forced marriage where informing parents may increase risk.

Key points:

• For Channel referrals, the DSL will consider whether to seek the pupil’s or parent’s consent before sharing information, balancing confidentiality, public protection and the individual’s welfare (Prevent Duty Guidance 2023).
• When we refer a concern to social services, the police or a school’s DSL, we will inform parents/carers and the pupil in writing of their right to make their own referral, with clear contact details for local children’s services and the police.
• Parental consent is not required for any statutory safeguarding referral. Staff must always act in the best interests of the child, even if this conflicts with parental wishes.

Allegations that a member of staff or host family may have:

• Harmed or placed a child at risk of harm.
• Committed a criminal offence against or related to a child.
• Behaved in a way suggesting unsuitability to work with children (including domestic violence or other concerning behaviour in personal life).

These fall under the “Harms Threshold” (KCSIE 2025, Part Four).

Safer Working Practices

All adults must follow our Staff Code of Conduct, avoid one-to-one unsupervised situations with pupils and recognise situations that could lead to misunderstandings or allegations.

Reporting an Allegation

• Immediate reporting: Allegations about staff or host families must go straight to the DSL. If the allegation concerns the DSL, report to the DDSL or the Chair of Trustees.
• No informal investigation: Until the LADO is consulted, do not interview the child, staff member or gather evidence that could jeopardise a police inquiry.

Liaison with the LADO

Within one working day the DSL (or case manager) will:

• Conduct basic fact-finding enquiries (dates, times, witnesses) without interviewing the accused.
• Consult the Local Authority Designated Officer to decide whether the allegation meets the harms threshold and agree next steps.
• Record all discussions, rationale and actions agreed with the LADO.

Investigation and Outcomes

• If the LADO and DSL decide no further action is needed, record the decision, inform the individual and agree what feedback is appropriate.
• If there is an immediate risk to children or evidence of a crime, involve police from the outset in consultation with the LADO.
• Non-recent allegations: Historic abuse disclosed by an adult or pupil must be reported to the police and LADO under local multi-agency procedures.

Malicious or False Allegations

• If an allegation is proven malicious or unfounded, consider whether the reporter needs support or if disciplinary action is warranted under our Staff or Host-Family Conduct Policy.

All steps will be handled in line with

• Keeping Children Safe in Education (DfE September 2025)
• Working Together to Safeguard Children (HM Government July 2023)
• Local Safeguarding Children Partnership procedures regarding allegations management.

When an allegation meets the harms threshold and the LADO has been consulted:

• The case manager will inform the accused adult in writing as soon as possible, sharing only the allegation’s nature and process.
• Parents or carers of the pupil will be notified promptly—unless doing so would impede a police or children’s services investigation.
• Any decision on what, when and how to share information will comply with data-protection law (UK GDPR, Data Protection Act 2018) and the advice of external agencies.
• Parents will receive updates only on matters affecting their own child; no personal data about the accused adult will be disclosed.

1. Lead Investigator

• A senior staff member (case manager), under LADO direction, usually conducts the inquiry.
• External agencies (police, children’s social care) may lead where criminal or statutory safeguarding investigations are required.

1. Cooperation and Timing

• The Guardianship will fully support any external inquiry and defer internal disciplinary action until those investigations conclude.
• The case manager will review progress at four weeks, then at least every two weeks, to ensure a fair and timely process.

1. Continuity of Investigation

• Investigations proceed even if the accused resigns or withdraws from duties.
• All records—nature of the allegation, evidence, decisions—are retained securely.

1. Outcome Definitions

• Substantiated: sufficient evidence to prove the allegation.
• Malicious: evidence disproves the allegation and shows intent to deceive or harm.
• False: evidence disproves the allegation.
• Unsubstantiated: insufficient evidence to confirm or refute the allegation.
• Unfounded: no evidence or proper basis for the allegation.

1. Notification of Outcome

• The accused is informed in writing of the investigation’s result and any next steps.

• Duty of Care to Staff/Host Families
  • A named representative will keep the accused adult informed of the process.
  • Access to counselling, occupational health or medical advice is provided as needed.
  • Unless prohibited by investigative agencies, social contact with colleagues and friends is permitted.
• Support for the Pupil and Their Family
  • Pupil welfare is reviewed continuously; pastoral support or external referrals are arranged.
  • Parents receive guidance on accessing specialist support (counselling, advocacy).
  • The DSL liaises with social services or police to agree the most appropriate way to help the child recover.

By ensuring clear information-sharing, a robust investigation framework and tailored support, we protect both children’s welfare and the rights of those subject to allegations.

Maintaining confidentiality safeguards the integrity of investigations and protects all parties’ privacy. Berkeley Guardians complies with UK GDPR, the Data Protection Act 2018 and the Contempt of Court Act 1981, ensuring information is only shared on a strict need-to-know basis.

Informing Key Individuals

• Case manager consults the LADO, children’s social care and/or police before notifying the accused adult or the pupil’s parents.
• The accused is informed in writing of the allegation and process as soon as permitted.
• Parents/carers receive timely updates about their own child’s welfare, but no personal data about the accused is disclosed.
• Decisions on wider disclosure (e.g. to host families, partner schools or the media) are made in consultation with external agencies and our Directors.

Managing Speculation and Press Interest

• All staff and host families are reminded not to comment publicly or on social media.
• Leaked or unauthorised disclosures may prompt a separate investigation or disciplinary action.
• Media enquiries are referred to the DSL and Directors, who coordinate any approved statements.

Police-Led Investigations

• Where the police lead, we seek their agreement to share statements and evidence for any subsequent internal disciplinary processes.
• Internal disciplinary proceedings are paused until criminal or statutory safeguarding inquiries conclude.

Handling Allegation Outcomes

Unsubstantiated, Unfounded or Malicious Allegations

• If a pupil’s claim is deemed unsubstantiated or malicious, the DSL will consider whether the pupil or reporter requires support or further safeguarding assessment.
• Allegations found to be deliberately false may result in disciplinary action or referral to the police.

Substantiated Allegations

• When an adult is dismissed or removed for posing a risk to children, a referral to the Disclosure and Barring Service is made within one month (Safeguarding Vulnerable Groups Act 2006).
• Settlement agreements that conceal the risk of harm are prohibited; resignation does not override our duty to refer.

Post-Investigation Review

• The DSL and case manager conduct a lessons-learned review with the LADO to assess: • adherence to statutory guidance (KCSIE 2025; Working Together 2023) • the effectiveness of information-sharing protocols • whether additional training or procedural changes are needed
• A written report of findings and recommendations is submitted to the Directors promptly.

By rigorously controlling information flow and reviewing each case, we uphold both child protection and data-protection standards.

Berkeley Guardians promotes a culture of openness, trust and transparency, where any concern about an adult’s behaviour—no matter how small—is reported and addressed promptly.

Definition

A low-level concern is any behaviour by an adult that:

• Falls short of our Code of Conduct, inside or outside work
• Causes unease or a “nagging doubt”
• Does not meet the harms threshold for a LADO referral (KCSIE 2025, Part Four)

Behaviour can range from inadvertent thoughtlessness to actions that—if unchecked—might enable abuse. Examples include:

• Excessive familiarity with pupils
• Showing unexplained favouritism
• Taking pupil photographs on personal devices
• Humiliating or singling out a pupil

Reporting

• All staff and host families must report low-level concerns without delay to the DSL or, if the concern involves the DSL, to the DDSL.
• You do not need to decide whether it crosses the allegation threshold; the DSL/DDSL will determine this, consulting the LADO if uncertain.
• Adults who believe they have behaved in a way that may cause misunderstanding should self-refer to the DSL immediately.

Recording and Storage

• The DSL logs every low-level concern—substantiated or not—in a secure, confidential register.
• Entries include: date, context, details of the concern, actions taken, decisions made and outcome.
• Reporters’ names are recorded; anonymity is respected wherever reasonably possible.
• Records are held in accordance with the Data Protection Act 2018 and UK GDPR and retained until the individual’s engagement with Berkeley Guardians ends.

Escalation

• If a pattern of low-level concerns emerges, the DSL will review whether the accumulated evidence meets the harms threshold and should be referred to the LADO.
• The DSL, DDSL and Directors review low-level concerns termly to identify trends, policy gaps or training needs.

References and Employment

• Low-level concerns that remain below the harms threshold and are safeguarding-only will not be disclosed in employment references.
• If a concern (or group of concerns) meets the threshold and is substantiated, a LADO referral is made and may be included in references in line with statutory guidance.

By capturing and acting on low-level concerns, we reinforce behavioural standards and protect children, staff and host families alike.

Most peer-on-peer incidents are managed under our Behaviour and Anti-Bullying Policies. However, any behaviour by one pupil towards another that raises safeguarding concerns must be handled under this policy (KCSIE 2025, Part Five).

Examples of Child-on-Child Abuse

• Bullying (including cyberbullying, prejudice-based or discriminatory)
• Abuse in intimate peer relationships
• Physical violence or threats (hitting, kicking, shaking, biting, hair-pulling)
• Sexual violence (rape, assault by penetration, sexual assault)
• Sexual harassment (comments, jokes, online harassment)
• Coerced sexual activity (forcing stripping or sexual acts)
• Upskirting (taking non-consensual images for sexual gratification)
• Sharing nude/semi-nude images (“sexting”)
• Hazing or initiation rituals involving abuse or humiliation

Pupils with SEND, girls (particularly for sexual abuse) and LGBT+ children are at increased risk and require heightened vigilance.

Reporting and Initial Response

• Any disclosure or concern must be reported immediately to the DSL/DDSL.
• Staff follow “Listening and Record-Keeping” procedures (Section 8), noting exact words, context and witnesses.
• Less serious incidents may be managed with restorative approaches, but every allegation is logged.

Assessment and Thresholds

On notification, the DSL will:

• Check if the Local Authority Children’s Services threshold for significant harm is met (Working Together 2023).
• Refer promptly to children’s social care and/or police when required.
• Manage lower-level cases with an internal safeguarding plan and behaviour sanctions, liaising with the school’s DSL.

Risk Assessment and Safeguarding Plans

For all child-on-child incidents, a written welfare risk assessment is completed with input from the school (if relevant). It considers:

• The victim’s wishes and feelings
• Ages, developmental stages and any power imbalances
• Whether the incident is isolated or part of a pattern
• Contextual factors (location, peer group dynamics, online elements)
• Ongoing risks to all involved

Actions may include temporary host-family re-placement, supervised contact, counselling, peer mentoring or external referrals.

Police Interviews and Appropriate Adults

• If police interviews are necessary, parents are informed and an appropriate adult (guardian or school staff) attends.
• If parents are overseas, the pupil’s education guardian or designated member of staff acts as appropriate adult.

Ongoing Support

Both the alleged victim and alleged perpetrator are viewed as “children in need” and receive tailored support. The DSL monitors progress, reviews risk assessments regularly and updates safeguarding measures until the case is closed.

Sexual violence and sexual harassment between pupils is never acceptable. All staff and host families must respond in line with KCSIE 2025 Part 5, Working Together 2023 and DfE guidance on Sexual Violence and Harassment (2021).

Definitions

• Sexual Harassment (“unwanted conduct of a sexual nature”):
  • Comments or jokes about appearance, sexualised name-calling, taunting.
  • Physical acts (brushing against someone, clothing interference, upskirting).
  • Online harassment (non-consensual image sharing, explicit messages, grooming).
• Sexual Violence (criminal offences):
  • Rape, assault by penetration, sexual assault.
  • Coercing someone into sexual activity without consent.

Consent requires freedom and capacity to choose and may be withdrawn at any time.

Vulnerable Groups

Girls, pupils with SEND and LGBTQ+ young people face higher risks. Staff must ensure those groups have trusted adults and clear reporting routes.

Initial Response

• Two-Adult Rule: If possible, have two trained staff present (one DSL/DDSL).
• Safe Space: Reassure the pupil, explain next steps, avoid blaming or shaming.
• Record-Keeping: Use CPOMS—note exact words, context, witnesses, date/time.
• No Viewing of Images: Do not view or forward illegal images; secure devices and consult the DSL on confiscation and police handover (DfE Searching, Screening and Confiscation 2025; UKCIS Sharing Nudes 2020).

Risk and Needs Assessment

The DSL conducts an immediate Risk and Needs Assessment, considering:

• Victim’s wishes and feelings.
• Ages, developmental stages, power imbalances.
• Pattern versus one-off incident.
• Online or offline context.
• Disability or learning needs.
• Sibling or household risks.

Review and update the plan regularly, in liaison with the school’s DSL, children’s social care or police.

Management Pathways

1. Internal Management
   • Restorative approaches, behaviour sanctions, internal safeguarding plan.
2. Early Help
   • Multi-agency support for pupils below statutory thresholds.
3. Children’s Social Care
   • Referral where significant harm or risk is identified.
4. Police
   • Report crimes (rape, assault by penetration) to police; consent for referral not required when risk is high.

Decisions (except purely internal cases) are taken with local MASH and police input.

Ongoing Support

• Victim Support: Access to counselling, specialist services and regular welfare check-ins.
• Perpetrator Support: Behaviour interventions, risk reduction work and counselling as needed.
• Whole-Group Wellbeing: Debrief peers, reinforce respectful relationships and consent education.
• Documentation & Review: DSL maintains detailed records, reviews outcomes and lessons learned to strengthen prevention.

By embedding clear definitions, prompt risk assessments and multi-agency cooperation, Berkeley Guardians ensures every pupil is protected and supported.

Mental Health

All staff and host families should recognise that mental health problems can sometimes signal that a pupil has experienced, or is at risk of, abuse, neglect or exploitation.

Where young people have suffered trauma—abuse, neglect or other adverse childhood experiences—these can have lasting effects on their mental health, behaviour and educational progress.

• Staff and host families are well placed to notice changes in mood, sleep, appetite, attendance or social engagement.
• Only appropriately trained professionals should diagnose mental health conditions.
• If a mental health concern also raises safeguarding issues, staff or host families must report it immediately to the DSL or a deputy.
• The DSL may consult external agencies or the child’s school DSL to coordinate assessment and support.

Teaching Pupils to Keep Themselves Safe

Preventative education underpins a culture of zero tolerance towards sexism, misogyny, homophobia, biphobia and sexual violence or harassment.

• Promote personal safety in homestays and the wider world, including safe online practices during remote learning.
• Cover safeguarding topics: radicalisation, grooming, child sexual and criminal exploitation, healthy relationships, mental health, substance misuse, bullying and sexting.
• Reinforce PSHE/RSE lessons from school through daily conversations and examples in the home.
• Guardian Angels maintain regular contact via WhatsApp and phone calls to check pupils are safe, happy and settled.
• Pupils are encouraged to speak freely with their Guardian Angel—who has visited them at school and is known to their parents—as a trusted bridge between host family and school.

This combined approach ensures Berkeley Guardians offers both proactive education and responsive care, safeguarding pupils’ wellbeing in every environment.

Maintaining Strong School Partnerships

Regular, two-way communication with schools ensures a joined-up approach to each pupil’s welfare and progress.

• Schools are encouraged to complete homestay checks and feed back via the National Minimum Standards (NMS) channels.
• Berkeley Guardians shares relevant safeguarding information, attendance data and wellbeing updates with the school’s DSL.
• Scheduled termly reviews and ad-hoc meetings enable prompt responses to emerging concerns.

Collaborative Support

Building trust between school staff, host families and Guardian Angels strengthens the support network around each pupil.

• Joint case conferences, where appropriate, include the school DSL, Berkeley Guardians’ DSL and host family.
• Agreed action plans—covering behaviour, academic support and pastoral care—are monitored by all parties.
• Feedback loops ensure that any positive progress or new issues are shared and addressed without delay.

Four Categories of Online Risk

Host-Family E-Safety Strategies

Host families play a vital role in helping pupils navigate online risks:

• Implement clear e-safety and acceptable-use policies for all devices in the home.
• Where feasible, switch off or restrict internet access at an agreed curfew to deter misuse.
• Remind pupils that they are guests in a family home and should respect household Wi-Fi terms.
• Encourage open dialogue about online friendships, apps and suspicious messages.

Appropriate Use

To protect pupils’ privacy and dignity, homestay members must not take photographs or videos without explicit permission.

• Seek consent from the pupil; if they are under 13, obtain written permission from Berkeley Guardians’ DSL.
• Avoid one-to-one images—always include context or additional occupants to reduce risk of misuse.
• Do not capture or display images that could embarrass, distress or exploit a pupil.

Permissions and Safeguards

Strict rules govern how images and contact information are managed:

• No social-media posting of pupil images under any circumstances.
• Images of vulnerable pupils require prior written approval from parents or legal guardians.
• Host families may store a pupil’s mobile number solely for the duration of the stay; remove all contact details immediately upon departure.

All staff and host family members aged 16 and over must undergo safer-recruitment checks in line with the Education (Independent School Standards) Regulations 2014 and KCSIE 2025.

• Enhanced DBS check before appointment
• Two satisfactory references, verified directly
• Collection of personal identity and right-to-work documentation
• At least one panel member trained in safer-recruitment techniques
• Ongoing monitoring, including annual review of suitability

Unexplained absences may indicate abuse, exploitation or other serious risks. Staff and host families must follow these steps immediately:

1. Record the time and circumstances of the absence.
2. Contact the Guardian Angel and DSL without delay.
3. Follow homestay’s emergency contact cascade to locate the pupil.
4. Log all actions taken and any explanations provided by the pupil.
5. If the pupil is no longer under Berkeley Guardians’ care but remains in the UK, inform the school of change in guardian status.

Note: Maintain at least two up-to-date emergency contact numbers for every pupil.

Under section 26 of the Counter-Terrorism and Security Act 2015 (as updated September 2023), Berkeley Guardians must have due regard to preventing radicalisation.

• Partnership working with schools to support vulnerable pupils
• Mandatory training for staff and host families to recognise radicalisation indicators
• Clear referral routes to the DSL and local Prevent coordinator
• Ongoing review of local threat assessments and policy alignment

Safeguarding records are confidential and shared strictly on a need-to-know basis to protect and promote pupils’ welfare.

• Store child-protection files securely, separate from academic records
• Disclose information only to individuals directly involved in safeguarding action
• Cooperate fully with police, children’s social care and MASH when required
• Follow Data Protection Act 2018 and GDPR: sharing for safeguarding is lawful and essential
• Use secure channels for special-category personal data; adhere to “Information Sharing” July 2018 guidance

All staff are required to report to the DSL, DDSL or Directors any concerns about:

• poor or unsafe safeguarding practices in a homestay or in the offices of Berkeley Guardians
• potential failures by the Guardianship or its staff to properly safeguard the welfare of pupils
• other wrongdoing in the workplace that does not involve the safeguarding and welfare of pupils

The NSPCC whistleblowing advice line is available for staff who do not feel able to raise safeguarding concerns internally.

Staff may raise a whistleblowing concern without fear of detrimental treatment or disciplinary action, provided the report is made in good faith. Malicious allegations may be treated as a disciplinary matter.

Any child protection incident within the Guardianship will trigger a review of the relevant safeguarding procedures, either within the Guardianship or the appropriate homestay.

Where an incident involves a member of staff or homestay member, the Local Authority Designated Officer (LADO) will be invited to assist in that review and recommend any procedural improvements.

The DSL will monitor the content and operation of this policy on a day-to-day basis and ensure that any deficiencies or weaknesses in child protection and safeguarding arrangements are remedied without delay.

This policy should be read in conjunction with the following:

• Prevention of Bullying Policy
• Emergency Procedures Policy
• Health and Safety Policy
• Recruitment, Selection and Disclosure Policy
• Code of Conduct for Staff
• E-Safety Policy
• IT Acceptable Use Policy
• Whistleblowing Policy
• Missing Pupil Policy
• Mental Health and Wellbeing Policy
• Prevent Duty Policy
• Mobile Phone Use Policy for Host Families

Appendix 1: Other types of abuse

Appendix 2: Further information on signs of abuse

Appendix 3: Flowchart of when and how to share information

Appendix 4: DSL Job Description

Appendix 5 – Safeguarding The Homestay

APPENDIX 6 – Reporting a disclosure form

APPENDIX 7 – Referring a Concern

APPENDIX 8 – Reporting an alleged incident