Safeguarding Policy

Safeguarding is about:

  • building and not compromising relationships of trust between under 18s and adults
  • ensuring appropriately safe systems are in place for the well-being of under 18s
  • having clear procedures in place if things do go wrong

LAL carries out activities which bring our employees and people working on behalf of our organisation into regular unsupervised contact with children. LAL acknowledges its duty of care to safeguard and promote the welfare of children and is committed to ensuring our safeguarding practices reflect statutory responsibilities, government guidance and complies with best practice.

This policy applies to all employees, other individuals associated by formal arrangement with LAL, 3rd parties, host families and volunteers whose duties bring them into contact with children for which LAL is or could be held responsible. For the purpose of this safeguarding policy the aforementioned will be referred to as LAL Representatives and a child is defined as a person who is under 18 years of age.

This policy recognises that the welfare and interests of children are paramount in all circumstances. It aims to ensure that regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation or socio-economic background, all children have a positive and enjoyable experience at LAL in a safe and child-centred environment

As part of our safeguarding policy LAL will:

  • promote and prioritise the safety and wellbeing of children and vulnerable adults
  • ensure everyone is aware of their roles and responsibilities in respect of safeguarding and is provided with the resources and appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children
  • ensure appropriate action is taken in the event of incidents/concerns of abuse and that support is provided to the individual/s who raise or disclose the concern
  • ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
  • prevent the employment/placement of unsuitable individuals
  • ensure robust safeguarding arrangements and procedures are in operation.

Please note that this Policy should be read in conjunction with the LAL Prevent Policy and Procedure.

Safer Working Practices for LAL Representatives

Physical Contact

LAL Representatives should:

  • Never physically chastise a child.
  • Never touch a child in any way that could be considered indecent.
  • Encourage children to undertake self-care tasks independently.
  • Make themselves aware of cultural or religious sensitivities about physical contact.
  • Understand that physical contact in any circumstances can be easily misinterpreted.
  • Treat children with respect.
  • Avoid all contact with intimate parts of their body.

It is understood that an LAL Representative may have physical contact with a child in order to prevent accident or injury to themselves or anyone else (e.g. to prevent a fall), or in the case of medical assistance being needed (e.g. to administer first aid). If a child is hurt or distressed, the LAL Representative will do his/her best to comfort or reassure the child without compromising his/her dignity or doing anything to discredit the person’s own behaviour.


LAL Representatives will use clear and simple lexis and always refrain from using foul, blasphemous and offensive terminology.


LAL Representatives should not behave in such a way that would leave any reasonable person to question their suitability to work with children, and will act as a role model.

LAL Representatives should be aware that behaviour in their personal lives may impact upon their work with children.

LAL Representatives should never bring to the child’s attention any material that could be construed as pornographic.

Other than for the purposes of safeguarding the child, LAL Representatives must not seek or agree to meet them anywhere outside of the normal workplace without the full prior knowledge and agreement of the parent, guardian or carer.


LAL Representatives should wear clothing that is appropriate to their role and is not likely to be viewed as offensive, revealing or sexually provocative. This clothing should not distract, cause embarrassment or give rise to misunderstanding. Clothing should be absent of any political or otherwise contentious slogans.

See our Dress Code for full details.


LAL Representatives are required not to in any way induce children for which LAL is or could be held responsible to undertake any actions against their wishes as a result of fear or favour. Gifts should only be given as part of an agreed reward system and should be of insignificant value.

Alcohol and Drugs

LAL Representatives must not distribute, purchase or sell alcohol to any children for which LAL is or could be held responsible.


The Sexual offences Act 2003 states that any person in a position of trust engaged in any form of sexual activity with students under the age of 18 is breaking the law (even though the legal age of consent is 16)

LAL strictly prohibits:

  • Even if consensual, any sexual, intimate, dating or other romantic relationship between any LAL Representative and any current or former student under the age of 18
  • Any form of communication with a child which could be interpreted as sexually suggestive or provocative i.e. verbal comments, letters, notes, electronic mail, phone calls, texts
  • Staff initiating or accepting ‘friend’ or similar social networking connection
  • requests with or from any current students or any former students under the age of 18.
  • LAL Representatives discussing their own sexual relationships with or in the presence of children.


Staff must maintain neutral and friendly relationships with all students. Staff must not initiate and must resist any attempt by any student to develop an overfamiliar or exclusive social relationship.

Staff must not engage in any social activity with students unless sanctioned by LAL.

Staff have a duty to report to their Line Manager any actual or perceived inappropriate development of the relationship between students and staff.

LAL has a duty to remove an individual from their position if there is risk of harm to students and may have a duty to report suspicion or allegations of abuse or neglect.

Safer Working Practices for LAL employees

Setting Standards

All new employees within LAL that have direct, unsupervised access to children undertake role specific training as part of the induction process which outlines the key elements of their role. This references the tasks the employee is expected to undertake, a summary of the staff dress code, safeguarding, fraternisation and social media policies as well as outlining LAL’s overall standards and expectations.

As part of the induction process all new staff are required to read and confirm in writing that they have read the Employee Handbook and associated policies.

Homestay Families are also issued with a Homestay Manual that provides rules, help and advice for hosts.

Safety and Social Media

LAL recognises that rigorous online safety policies and procedures are essential to safeguarding children and young adults online.

In order to protect children and staff from adverse effects that could result from the improper use of Social Media, staff use of Social Media must comply with LAL’s Fraternisation policy. The use of Social Media can put children young people at risk within and outside the school. Some of the potential dangers may include:

  • Access to illegal, harmful or inappropriate images or other content
  • Unauthorised access to / loss of / sharing of personal information
  • The risk of being subject to grooming by those with whom they make contact
  • on the Internet.
  • The sharing / distribution of personal images without an individual’s consent or knowledge
  • Inappropriate communication / contact with others, including strangers
  • Cyber-bullying
  • Access to unsuitable video / Internet games

Employees should not:

  • initiate or accept ‘friend’ or similar requests from any current or former LAL student under the age of 18 and for as long as they are under 18.
  • use internet or web-based communication channels to send personal message to children.
  • give their personal contact details to children including their mobile phone number.
  • Give out personal information of any kind
  • place inappropriate photographs on any social network space

The CIO along with the Designated Safeguarding Leads are responsible for e-Safety within LAL.

Other Safer Working Practices


Children who require a private fostering arrangement will be noted by the accommodation department who will initiate the required paperwork.

The local authority private fostering forms will be sent, usually via the agent, to the parents. Once this is returned to LAL we will complete the rest and make sure that the form is received by the local authority.

In communication with the local authority the school will arrange suitable time/s during the children’s stay for the local authority to visit the school and meet with the student to discuss all aspects of their stay and to ensure that all needs are being met.

General and fire safety risk assessments checks will be carried out during Host Family visits by LAL staff or contractors.

Transport and Activities from Outsourced Providers

Before LAL engages any companies to provide services for LAL students that are children, LAL will require all employees of those companies who will have unsupervised access to children for which LAL is or could be held responsible to provide LAL with full criminal records clearance details as well as evidence of adequate insurance cover.

Welfare/Implementing Safeguarding

Risk Assessments

Risk assessments will be carried out for all on site and off site activities to remove and eliminate risk where possible. This will include first aid cover and accident reporting. Staff are required to read these risk assessments and will be advised of any subsequent changes to these risk assessments.

Risk assessments and fire risk assessments for homestays will be undertaken during the initial visit and updated on all re-visits.

Behaviour and Discipline

The children will have their behaviour monitored and controlled in order to minimise any danger that they present to themselves or others. All staff are to be aware of and comply with LAL ‘s discipline policy and procedures

What If Scenarios?

All staff that answer the emergency phone outside of standard hours are fully briefed and trained to advise the caller on a wide range of ‘what if’ scenarios.


Irrespective of the type of accommodation, unless specifically by the written request of the parent/guardian of the children concerned under no circumstances will a child be placed in the same room as an adult. Children sharing a room will be of the same gender and close in age range. This applies to our Host Families and Residential Accommodation.

LAL will ensure that students under 16 lodged by them in homestay or residential accommodation will not be lodged with students of 18 years or older.

Who’s Who for Children

During first day inductions children will be introduced to all individuals whom they can contact for help and advice. This information is also provided in the LAL Young Learner Student Handbook.


Children are provided by a variety of means including verbal instruction and the student handbook easy-to-understand information regarding UK laws, personal safety, road safety, fire safety, beach and sea safety as well as being provided with instructions should they become lost.

Regular fire alarm checks and drills take place within our learning centres. As part of the student induction process, children are shown where the fire exits are located and where to meet if the fire alarm is activated.

LAL has a number of staff who are trained to provide emergency first aid.

When transporting children, the transport will be checked to ensure it is roadworthy and adequate for the purpose. Appropriate insurance will be kept up to date and adequate to cover such assignments.

Children are also issued with an LAL Student ID card on arrival which has phone numbers to call in an emergency.

Supervision Ratios

Lessons have a maximum size of fifteen students, with some courses having a lower maximum number. One responsible adult will be assigned to each class.

On activities and excursions the supervision ratio is one responsible adult to maximum of twenty students. Students under 12 years old have a supervision ratio of one responsible adult to twelve students.

In residential accommodation LAL will ensure that the ratio of residential adults to students will be at least 1:20 for students aged 12-17 and 1:15 for students under 12, to include LAL staff and accompanying Group Leaders. First aid facilities and an appropriately trained member of staff will be available at all times.

A responsible adult is required to be present overnight at host homes and will be present when children under 16 are at home.

Emergency Procedures

The Host Home manual clearly outlines to the host the procedure to be followed in the event of emergencies. Information includes office opening hours, contact numbers, out of hours contact numbers, what the family should do if a child becomes ill, requires first aid, requires a doctor or dentist appointment and is late home or missing. For children staying at our summer schools, all staff are trained to deal with emergency situations as part of their induction. This information is reiterated during host family visits and during the host family open event.

LAL provides parents and/or agents, group leaders, host families and students with 24 hour emergency contact numbers.

Children are made aware of emergency procedures in all circumstances including when in the residence, in school or on activities.

The Young Learner Student Handbook details emergency contact information and procedures.

Age Appropriate and Evening Activities

Host families are made aware via the ‘host home manual’ of the rules regarding activities children may undertake outside of scheduled activity times, the level of supervision required by the host family and what time they are expected home at a specific location including curfew times.

Students on Vacation English courses and Adult courses have different activities at different times, so students on these courses will not have activities together, unless this is arranged separately.

Where applicable host families will be required to bring the child to evening activities. A representative from the learning centre will then either accompany the child back to their host family or a private transport company will be used.

Arrival and Departure Arrangements

All under 16s are fully supervised from their point of arrival to their accommodation/learning centre and from the learning centre to the security zones and their points of departure.

At any port of arrival, under 16s will be supervised by an LAL Representative until they are handed to another LAL Representative who will escort them to their destination.

For some arrivals, the transfer will deliver under 16s directly to the host family.

On departure for all airports either the host family or an LAL Representative will take under 16s to the specified meeting point where a member of LAL Representative will be waiting for them and will escort them to the airport.

On arrival at the airport the LAL Representative will take the student to the check-in desk and assist them with checking in and dropping off bags. They will then be taken to the security point where they will be given instructions.

All children will be supplied with our pre-arrival information that contains our emergency number. They are instructed to call this number if they have any issues at the airport before they meet up with an LAL Representative for example in baggage reclaim.

Unaccompanied Minors (UM)

On arrival, airline staff will pass the UM to an LAL Representative who will accompany the UM to their destination or hand them over to another LAL Representative for transfer to their centre.

On departure, an LAL 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 LAL Representative must not leave the airport until the flight has left in case the flight is cancelled and the student is handed back to LAL for further supervision until a suitable replacement flight has been arranged.

Where students arrive and depart with an accompanying group leader from the agency, this person may take the place of the LAL Representative in the above cases.

Recognising Child Abuse

LAL Representatives are trained to monitor children for evidence of abuse as detailed by the NSPCC. Child abuse falls into one or more of four categories: physical abuse, emotional abuse, sexual abuse and neglect.

Physical Abuse

Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child.

Emotional Abuse

Emotional abuse is the persistent emotional ill treatment of a child such as to cause severe and persistent effects on the child’s emotional development, and may involve:

  • Conveying to a child that s/he is worthless, unloved, inadequate, or valued only insofar as s/he meets the needs of another person
  • Imposing developmentally inappropriate expectations e.g. interactions beyond the child’s developmental capability, overprotection, limitation of exploration and learning, preventing the child from participation in normal social interaction
  • Causing a child to feel frightened or in danger e.g. witnessing domestic violence, seeing or hearing the ill treatment of another
  • Exploitation or corruption of a child

Some level of emotional abuse is involved in most types of ill treatment of children, though emotional abuse may occur alone.

Child Sexual Exploitation and FGM

All Employees have a legal responsibility to prevent and report instances of Child Exploitation and Female Genital Mutilation as this is illegal in the UK.

Child sexual exploitation is when people use the power they have over young people to sexually abuse them. Their power may result from a difference in age, gender, intellect, strength, money or other resources. It is vitally important the employees know how to recognise and prevent this from happening. The signs of child sexual exploitation may be hard to spot, particularly if a child is being threatened. To make sure that children are protected, it’s worth being aware of the signs that might suggest a child is being sexually exploited.

Sexual abuse involves forcing or enticing a child to take part in sexual activities, including prostitution, whether or not s/he is aware of what is happening.

Activities may involve physical contact, including penetrative and non-penetrative acts.

Sexual activities may also include non-contact activities, e.g. involving a child in looking at / production of abusive images, watching sexual activities or encouraging her/him to behave in sexually inappropriate ways. It may include use of photos, pictures, cartoons, literature or sound recordings via internet, books, magazines, audio cassettes, tapes or CDs.

Signs of Grooming and Child Sexual Exploitation

Signs of child sexual exploitation include the child or young person:

  • going missing for periods of time or regularly returning late
  • skipping school or being disruptive in class
  • appearing with unexplained gifts or possessions that can’t be accounted for
  • experiencing health problems that may indicate a sexually transmitted infection
  • having mood swings and changes in temperament
  • using drugs and/or alcohol
  • displaying inappropriate sexualised behaviour, such as over-familiarity with strangers, dressing in a sexualised manner or sending sexualised images by mobile phone (“sexting”)
  • they may also show signs of unexplained physical harm, such as bruising and cigarette burns


Neglect involves 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 and development. This could involve failing to:

  • Provide adequate food, clothing or shelter (including exclusion from home or abandonment)
  • Protect from physical and emotional harm or danger
  • Meet or respond to basic emotional needs
  • Ensure adequate supervision including the use of adequate care-takers
  • Ensure access to appropriate medical care or treatment
  • Ensure that her/his educational needs are met
  • Ensure her / his opportunities for intellectual stimulation are met

Handling Allegations

What to do

If a child discloses any information to a LAL Representative suggesting that they have been abused in any way, LAL Representatives should follow the process outlined below. If this information is reported by a child to their homestay host, the host must inform LAL as soon as possible using the emergency contact numbers.

The following advice is provided by English UK:


Listen to what is being said without displaying shock or disbelief. A common reaction to news as unpleasant and shocking as child abuse is denial. However, if you display denial to a child, or show shock or disgust at what they are saying, the child may be afraid to continue and will shut down. Accept what is being said without judgement. Take it seriously.


Reassure the child, but only so far as is honest and reliable. Don’t make promises that you can’t be sure to keep, e.g. “everything will be all right now”. Reassure the child that they did nothing wrong and that you take what is said seriously.

Don’t promise confidentiality – never agree to keep secrets. You have a duty to report your concerns. Tell the child that you will need to tell some people, but only those whose job it is to protect children. Acknowledge how difficult it must have been to talk. It takes a lot for a child to come forward about abuse.


Listen quietly, carefully and patiently. Do not assume anything – don’t speculate or jump to conclusions. Do not investigate, interrogate or decide if the child is telling the truth. Remember that an allegation of child abuse may lead to a criminal investigation, so don’t do anything that may jeopardise a police investigation. Let the child explain to you in his or her own words what happened, but don’t ask leading questions. Do ask open questions like “Is there anything else that you want to tell me?” Communicate with the child in a way that is appropriate to their age, understanding and preference. This is especially important for children with disabilities and for children whose preferred language is not English. Do not ask the child to repeat what they have told you to another member of staff. Explain what you have to do next and whom you have to talk to.


Make some very brief notes at the time and write them up in detail as soon as possible. Do not destroy your original notes in case they are required by Court.

Record the date, time, place, words used by the child and how the child appeared to you – be specific. Record the actual words used; including any swear words or slang. Record statements and observable things, not your interpretations or assumptions – keep it factual.

It is not for LAL Representatives to decide if the allegations are true or not. Their role is only to listen and report as accurately as possible. Staff should inform their line manager immediately, who in turn should report to the school General Manager and LAL’s Designated Person for Safeguarding Children.

The Local Authority Designated Officer (LADO) will be informed by LAL’s Designated Person for Safeguarding Children within one working day of all allegations that come to LAL’s attention and appear to meet the criteria below:

  • behaved in a way that has harmed a child, or may have harmed a child;
  • possibly committed a criminal offence against or related to a child; or
  • behaved towards a child or children in a way that indicates they may pose a risk of harm to children.

The LADO has a responsibility to consult LAL, Police and Children’s Social Care about whether the criteria above is met and if so to determine which of the three strands listed below should be used to conduct enquiries:

  • a police investigation of a possible criminal offence
  • enquiries and assessment by children’s social care about whether a child is in need of protection or in need of services
  • consideration by LAL of disciplinary action in respect of the individual.

If there is immediate danger to the student immediate action to safeguard the child will be a taken by LAL.

LADO Contact Details

The Local Authority Designated Officer for Torbay can be contacted as follows:

Tel: 01803 208411

Email: [email protected]

The Local Authority Designated Officer for Twickenham can be contacted as follows:

Tel: 020 8891 7969

Email: [email protected]

DBS Checks

Anyone who works with or is seeking to work with children or will have unsupervised contact with children is required to have an enhanced DBS disclosure or equivalent. This includes, but is not limited to, permanent staff, seasonal staff, interns and homestay providers.

  • Full information about recruitment can be found in LAL’s Recruitment and Selection Policy
  • Full DBS information can be found in LAL’s DBS Policy Procedure


All staff to undertake training

All LAL Representatives whether paid or unpaid will be required to read LAL’s Safeguarding policy as part of their induction process. The importance of safeguarding children is also included in each role specific handbook. All staff that are recruited on a seasonal basis and permanent basis that will have unsupervised contact with children will (as part of the induction process) be tested on their safeguarding knowledge. If any areas are identified as lacking staff will receive the necessary training.

In addition to this as per our Prevent Policy and Procedure, we will ensure that all staff are fully aware of the threats, risks and vulnerabilities that are linked to radicalisation, and are aware of the process of radicalisation and how this might be identified early on.

To increase knowledge of radicalisation, awareness of the Channel process and confidence to make a referral all staff will undertake the E Learning Channel General Awareness module. This online training module introduces topics including how to identify factors that can make people vulnerable to radicalisation, and case studies illustrating the types of intervention that may be appropriate.

The E Learning Module can be found at:

It is the responsibility of the HR Manager to review this policy annually and more frequently if necessary as per government guidance, legislation change or as a result of any other significant change or event.


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