Team Domenica Safeguarding Policy
Author: Sara Fletcher (Education and Quality Lead)
Consulted: Lisa Campbell-Squires (Co CEO)
Date last reviewed: August 2025
Renewal due: August 2026
Associated Documents
Admissions, Attendance and End of Placements Policy
Charity Ethos Statement
Compliments and Complaints Policy
Curriculum Policy (Including RSHE)
Emergency Evacuation Policy (available on request)
Security Policy
First Aid Policy (available on request)
Health and Safety & Fire Safety Policy (available on request)
Mental Capacity Policy
Online Safety Policy
Promotion of Positive Behaviour and Relationships
Prevention of Radicalisation & Extremism Policy
Safer Recruitment Policy
Staff Code of Conduct
Whistleblowing Policy
Team Domenica Easy Read Safeguarding Policy
Legislation and Guidance
Please note that this is intended to provide useful links to relevant guidance and legislation. It is not an exhaustive list:
The Care Act 2014
Care Standards Act 2000
The Children Act 1989 & 2004
Education Act 2011
The Equality Act 2010
Guidance Issued Under Section 175/157 of the Education Act 2002
The Human Rights Act 1998
Keeping children safe in education – GOV.UK
Mental Capacity Act 2005
Prevent Duty
Protection of Freedoms Act 2012
Safeguarding Vulnerable Groups Act 2006
The Sexual Offences Act 2003
Working together to safeguard children – GOV.UK
United Nations Convention on the Rights of the Child 1989
Contents
Introduction
The Aims, Purpose and Scope of This Policy
The Team Domenica Safeguarding Team
Reporting and Recording a Safeguarding Concern including Whistleblowing
Safeguarding Contexts
Mental Capacity, Consent and Best Interests
Training for Safeguarding
Appendices
Procedure for Visitor, Speakers and Partners
Procedure for responding to a Safeguarding Concern
Key Contacts
Support and specialist organisations
Introduction
All those working at Team Domenica, including trustees, senior managers, teachers, mentors and café staff, are committed to a robust culture of safeguarding that moves our candidates to greater autonomy, independence and participation in work and community and upholds the rights of all adults to live a life free from harm, abuse, exploitation and neglect, through a detailed understanding of managed risk, personal capacity, and a thoroughly embedded awareness of how to respond to any situation that may cause harm to any adult in our care.
The following policy has been developed by the Senior Leadership Team (SLT) and has been adopted by the Board of Trustees.
Employees and volunteers should be aware that a failure to comply with the following Safeguarding Policy could result in disciplinary action including dismissal. People who abuse vulnerable adults may also face criminal proceedings.
The Aims, Purpose and Scope of This Policy
Team Domenica believes everyone has the right to live free from abuse, neglect and exploitation regardless of age, ability or disability, sex, race, religion, ethnic origin, sexual orientation, marital or gender status.
Team Domenica is committed to creating and maintaining a safe and positive environment and an open, listening culture where people feel able to share concerns without fear of retribution.
Team Domenica acknowledges that safeguarding is everybody’s responsibility and is committed to prevent abuse and neglect through safeguarding the welfare of all adults involved.
Team Domenica recognises that health, well-being, ability, disability and need for care and support can affect a person’s resilience. We recognise that some people experience barriers, for example, to communication in raising concerns or seeking help. We recognise that these factors can vary at different points in people’s lives.
Team Domenica recognises that there is a legal framework to safeguard adults who have needs for care and support and for protecting those who are unable to take action to protect themselves and will act in accordance with the relevant safeguarding adult legislation and with local statutory safeguarding procedures.
This policy applies to anyone representing Team Domenica, including senior managers and the board of trustees, paid staff, volunteers, sessional workers, contractors, agency staff, work placement providers and candidates themselves. Visitors, Speakers and Partners also have a duty to follow our policies and the procedures for this are detailed below in Appendix
The purpose of this policy is to protect from harm the adults who may be at risk (referred to throughout this policy as ‘Candidates’) who receive Team Domenica’s services.
This policy sets out to provide candidates, staff, parents/carers, volunteers, contractors and work placement providers with both the overarching principles that guide our approach to safeguarding candidates and to promote their physical and emotional wellbeing, and specific procedures that will be followed in response to concerns. It is to be used alongside our wider suite of specific policies as necessary.
The policy is based on the following principles:
Team Domenica is committed to creating a culture of zero-tolerance of harm to adults which necessitates: the recognition of adults who may be at risk and the circumstances which may increase risk; knowing how adult abuse, exploitation or neglect manifests itself; and being willing to report and respond to safeguarding concerns in a sensitive but confident manner.
That while our candidates are young adults, they are likely to have additional risk factors when compared to other adults because of the impact of previous experiences, their level of dependency, their learning disabilities and/or communication needs and/or other issues.
That our candidates have an equal right to protection from all types of harm and abuse, regardless of age, disability, race, religion or belief, sex, or sexual orientation.
That no candidate should come to harm while working with Team Domenica and that everyone at Team Domenica can play a part in reducing the risk of harm across the wider lives of candidates.
That the provision at Team Domenica can provide a significant opportunity to teach the essential skills and knowledge necessary for candidates to make safe choices for themselves and feel empowered to do so. Our intention is that through experience and direct teaching, our candidates become full participants in our safeguarding culture.
That an open and secure approach to information sharing and partnership work, with candidates, their parents, carers, colleagues and other professionals is central to the prevention of harm.
The Team Domenica Safeguarding Team
All adults and professionals and volunteers working for or on behalf of Team Domenica, including candidates themselves, have a responsibility to safeguard Team Domenica candidates and promote their welfare.
Those with overarching responsibility for safeguarding are:
DSL (Designated Safeguarding Lead)
Deborah Rayner- Gray | deborah@teamdomenica.com | (01273) 681111
Deputy Designated Safeguarding Leads (Alerting Managers)
Sara Fletcher | sara@teamdomenica.com | (01273) 68111
Kate Payne kate@teamdomenica.com
Allie Sutton allie@teamdomenica.com
Becky Chan becky@teamdomenica.com
Amanda Thomson AmandaT@teamdomenica.com
Ruth Thomas Ruth@teamdomenica.com
Beverly Rosling Beverly@teamdomenica.com (For safer recruitment and HR related Concerns)
CO-CEO and Principal
Lisa Campbell-Squires | lisa@teamdomenica.com | (01273) 681111
Safeguarding Trustee
Lalli Howell | lalli@teamdomenica.com
Chair of Trustees
Rosa Monckton | Responsible for notifications of serious incidents to the charity commission | rosa@teamdomenica.com
The Safeguarding Team meet monthly to look at safeguarding provision across the whole organisation, identify patterns and trends of concern, respond to arising issues and consider more complex incidents.
Information about who can be contacted about safeguarding concerns can be found around the Team Domenica sites and is described in the appendix ‘Procedure for responding to a Safeguarding Concern’ on page 18 of this policy.
The role of the Safeguarding Team as a whole is to:
- Discuss referrals made to the Safeguarding Team at Safeguarding Team meetings held in term time.
- Ensure safeguarding procedures are in place and updated as needed.
- Ensure all staff remain aware of the safeguarding policy & procedures.
- Be available to provide advice/support to staff and for staff to discuss concerns with.
- Be available to provide support to candidates as needed.
- Liaise with Social Care Services in accordance with Pan-Sussex procedures concerning vulnerable candidates.
- Attend and/or contribute to Strategy Meetings/Case Conferences.
- Keep records of any concerns/suspected cases of abuse/referrals on My Concern.
- Co-ordinate arrangements for monitoring of specific candidates on roll who have been identified as needing protection.
- Deliver Induction and refresher training for all staff to ensure that the staff who work with candidates undertake appropriate training to equip them to carry out their Safeguarding responsibilities.
- Help prepare trustee reports reviewing arrangements for safeguarding and promoting the welfare of candidates and support the implementation of any action plan from this review.
- Review relevant policies when required to do so.
Responding to, Reporting and Recording a Safeguarding Concern (including Whistleblowing)
The mechanism for reporting and recording all safeguarding concerns, other than the exceptions listed below, is via MyConcern – an online portal for the secure sharing of information that alerts the Safeguarding Team of reports and updates and allows them to note actions and responses made.
A comprehensive record on MyConcern ensures that not only are individual incidents and concerns noted but that patterns of behaviour, incidents or concerns can be noted, analysed and responded to appropriately. It is the current approach of Team Domenica that all staff have access to MyConcern throughout their working time, and this may include using password protected personal devices.
Team Domenica has a dedicated phone line, monitored during office hours, providing an alternative route to sharing concerns.
In this policy the term “concern” is used to mean any incident, allegation, observation disclosure or report that a candidate is, or maybe at risk of harm through any of the types of behaviours or contexts listed in the subsequent sections, or by other means not listed but which cause a reasonable adult to be worried about the welfare of the individual.
Responding to a concern that a candidate might have been harmed or is at risk of harm:
As per part one of Keeping Children Safe in Education, all staff at Team Domenica are trained in how to receive, manage and report. However, this policy acts as a reminder of effective safeguarding practice
Unfortunately, on a national level, it can take many disclosures or incidents of concern before an effective response is made. It is the intention of this policy that such barriers are reduced. When a member of staff observes or is informed of a concern that is not an immediate risk and does not involve a criminal act then a report is made via MyConcern, and if necessary, a phone call made to the Safeguarding Team. A number of considerations must be made by the staff member in this moment:
- Involvement, agreement and consent of the candidate – It is best practice that candidates are always informed of reports written about them and their agreement sought. If this can be discussed in the moment in a safe, contained manner it should be done, however, if this is not possible it should be noted on the report so the Safeguarding Team can ensure an appropriate response is planned. Many learners will have specific communication needs which are described in full in their Education, Health and Care Plan (EHCP) and summarised on individual Progress Monitoring Forms which are available in all settings. If a candidate’s communication needs are likely to impair their capacity to raise concerns this must be considered on their risk assessment.
- Confidentiality – Concerns must not be discussed with other candidates, staff members or other people until the Safeguarding Team have determined a response. Conversations with the candidate should be done as discreetly as possible. Candidates should never be promised confidentiality or the holding of “secrets” and must be assured that information sharing will be in their interests and only with key people. Staff should only share the report with people who are necessary in order to progress it. It is important that the victim understands what the next steps will be and who the report will be passed to. Consideration must be given to what information is communicated to families and carers. While family and/or carers can be essential partners in safeguarding they should not be contacted until agreement has been sought from the candidate, and this recorded on MyConcern. However, if the risk of harm may be raised by not communicating the concern the decision to contact the family of carer may be made by a member of the Safeguarding Team, and their rationale for this noted on MyConcern.
- The preservation of information and evidence – If handwritten notes are taken at any point they must be signed and dated and given to the Safeguarding Team for safe storage. Individual adults should not take photographs of any injuries on personal devices but, if it is safe and appropriate for them to view these should include a description in their report.
- The content and tone of the discussion –
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- Recognising that a young person is likely to disclose information to someone they trust: this could be anyone on the Team Domenica staff. It is important that the person to whom the young person discloses recognises that the young person has placed them in a position of trust. They should be supportive and respectful of the young person.
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- Listening carefully to the young person, being non-judgmental, being clear about boundaries and how the report will be progressed, not asking leading questions and only prompting the young person where necessary with open questions – where, when, what, etc.
All staff are asked to be aware of the advice given by the NSPCC on content and tone of the discussion:
- Show you care, create an open forum and let them know what is being said is important: Give your full attention to the young person and keep your body language open and encouraging. Be compassionate, be understanding and reassure them their feelings are important.
- Take your time, slow down: Respect pauses and doesn’t interrupt– let them go at their own pace. Recognise and respond to their body language. And remember that it may take several conversations for them to share fully what’s happened to them.
- Show you understand, reflect back: Make it clear you’re interested in what you are being told. Reflect back what they’ve said to check your understanding – and use their language to show it’s their experience. Do not make value judgements about the situation or the people involved.
The Safeguarding Team are also able to support any adult who feels upset or worried about what they have heard or witnessed, and good self-care is essential for all involved in a safeguarding situation. All staff should be ready to seek this support if necessary.
- Considering the best way to make a record of the report. Best practice is to wait until the end of the conversation and immediately write up a thorough summary. This allows the staff member to devote their full attention to the young person and to listen to what they are saying. It may be appropriate to make notes, especially if a second member of staff is present. However, if making notes, staff should be conscious of the need to remain engaged with the young person and not appear distracted by the note taking. Either way, it is essential a written record is made.
- Only recording the facts as the young person presents them. The notes should not reflect the personal opinion of the note taker. Everyone should be aware that notes of such reports could become part of a statutory assessment by adult social care and/or part of a criminal investigation.
- Where the report includes an online element, being aware of Searching Screening and Confiscation advice for working with children and young people: Sharing nudes and semi-nudes: advice for education settings. The key consideration is for staff not to view or forward illegal or sexual images of a young person.
- Managing reports with two members of staff present, (preferably one of them being the designated safeguarding lead (DSL) or a deputy). However, this might not always be possible.
At Team Domenica this means an incident or disclosure could happen in the classroom, in a work placement or in the public space of our training cafes. Staff must use their professional judgement to balance taking the disclosure, managing any arising risks and the need to safeguard a group of candidates. In such cases staff must phone the office and request additional support to maintain both safety and the integrity of reporting.
If there is a clear threat of harm, including criminal behaviour, then the police must be called by the staff in situ. In other circumstances the safeguarding team will decide how to manage the police report. They will need to consider supporting and updating the victim and family, what communications are necessary with any alleged perpetrator and their family or support network and the potential need for communication and action beyond normal working hours. There may also be a need to contact adult social care.
It is essential that all victims are reassured that they are being taken seriously and that they will be supported and kept safe. Candidates should never be given the impression that they are creating a problem by reporting harm or feeling unsafe.
Recording Concerns
All safeguarding reports must be made on the day of the incident or concern and before 4.30pm. Staff members must complete their duty to report before leaving any Team Domenica site or work placement for the day.
The reports on MyConcern and other records taken could be shared with other agencies, with candidates and/or their families or carers and could be used in legal or formal proceedings now or in the future.
Reports must be respectful, factual, clear and concise with no subjective content, value judgement or interpretations. The language used by the candidate should be reported directly and noted as so. Important information such as times, dates, the names and roles of those involved and locations of incidents must be included.
The unavailability of MyConcern at any time must not be a barrier to high quality report writing and, if necessary, handwritten or emailed accounts must also follow these principles.
The Safeguarding Telephone Line can be used to make immediate alerts, discuss more complex issues and to access support and guidance. This line is available during the Team Domenica working day on 01273 056807.
Exceptional Circumstances
Immediate Harm – If a member of staff believes a candidate is at risk of immediate harm from another, from their own behaviour or from environmental factors then this must be resolved before further reporting is undertaken. This may be removing the candidate from a situation, calling emergency services or asking colleagues for support or advice.
Criminal Activity – If criminal activity is suspected the police must be informed. This may need to be by the adult dealing with the safeguarding concern or it may necessitate the support of others if withdrawing direct supervision of candidates creates a higher risk.
Concerns around a colleague -If the safeguarding concerns involve a member of staff who works for Team Domenica in any capacity, then there may need to be variations to the above. If an allegation of harm is made against a member of staff the following applies:
- In most cases adults should not record an allegation made against them, where possible a colleague should record the concern.
- If the adult is lone working or working off site with a candidate in the workplace, they should take initial notes and contact a member of the Safeguarding Team immediately it is safe to do so.
- Adults may have low level concerns about the practice of colleges-these will be situations where no harm is evident but conduct and behaviour falls below the expected standard. All staff must feel able to discuss this with their line manager and line managers will refer incidents or patterns of incidents to the Safeguarding Team.
- If an allegation is made against one of the Safeguarding Leads or HR managers, these must be reported to the Co-CEOs
- If the allegation or concern is about the Co-CEOS then the procedure is to alert the Founder and Chair of Trustees, Rosa Monkton, who is available at rosa@teamdomenica.com. She will take advice from relevant parties and, if necessary, allocate the management of the situation to a suitably trained member of the Senior Leadership Team.
A one-page summary sheet of reporting procedures is available on page 18 in the appendix of this policy, and all staff should familiarise themselves with it and take responsibility for it being visible and accessible in their workplace.
Types of Abuse
Physical
Being pushed, shaken, pinched, hit, held down, locked in a room, restrained inappropriately, or knowingly giving an adult too much or not enough medication.
Sexual
An adult being made to take part in sexual activity when they do not, or cannot, consent to this. It includes rape, indecent exposure, inappropriate looking or touching, or sexual activity where the other person is in a position of power or authority.
Financial
Misusing or stealing an adult’s money or belongings, fraud, postal or internet scams tricking adults out of money, or pressuring an adult into making decisions about their financial affairs, including decisions involving wills and property.
Neglect
Not meeting an adult’s physical, medical or emotional needs, either deliberately, or by failing to understand these. It includes ignoring an adult’s needs, or not providing them with essential things to meet their needs, such as medication, food, water, shelter and warmth.
Self-neglect
Being unable, or unwilling, to care for their own essential needs, including their health or surroundings (for example, their home may be infested by rats or very unclean, or there may be a fire risk due to their obsessive hoarding).
Psychological or emotional
Being shouted at, ridiculed or bullied, threatened, humiliated, blamed for something they haven’t done, or controlled by intimidation or fear. It includes harassment, verbal abuse, cyber-bullying (bullying which takes place online or through a mobile phone) and isolation.
Discriminatory
Forms of harassment, ill-treatment, threats or insults because of an adult’s race, age, culture, gender, gender identity, religion, sexuality, physical or learning disability, or mental-health needs. Discriminatory abuse can also be called ‘hate crime’.
Modern slavery
An adult being forced to work for little or no pay (including in the sex trade), being held against their will, tortured, abused or treated badly by others.
Domestic violence
Psychological, physical, sexual, financial or emotional abuse by someone who is a family member or is, or has been, in a close relationship with the adult being abused. This may be a one-off incident or a pattern of incidents or threats, violence, controlling or coercive behaviour. It also includes so called ‘honour’ based Safeguarding Policy & Procedure Page 26 of 62 violence, being forced to marry or undergo genital mutilation.
Organisational
Neglect and providing poor care in a care setting such as a hospital or care home, or in an adult’s own home. This may be a one-off incident, repeated incidents or on-going ill-treatment. It could be due to neglect or poor care because of the arrangements, processes and practices in an organisation.
Safeguarding Contexts
The Pan-Sussex Safeguarding Adults guidance lists the following specific contextual safeguarding risks for vulnerable adults, which have specific legislation, guidance and/or reporting procedures outlined in guidance. It is essential that all staff are aware of these, where to seek further advice and information, how to educate and empower candidates to safeguarding themselves, and the controls in place to protect candidates against them. All staff and volunteers at Team Domenica need to be aware that while some of these contexts are highly specific, many can arise in any of the four following situations.
Learning and working within Team Domenica
Robust safer recruitment processes and an open, vigilant culture of monitoring and oversight should combine to deter anyone who deliberately wishes to harm candidates. However, there must never be complacency about the potential for this to happen. In addition, there are contexts when practice can, without supervision, support and challenge can become coercive, exploitative or abusive. This policy outlines the specific procedures for the reporting of concerns arising from the actions of staff and the relationships between staff and candidates.
Individual behaviour and peer relationships
Candidates at Team Domenica are likely to have diagnosis of cognitive or neuro-diverse conditions that may inhibit some or all the skills that they need to keep themselves safe, including the capacity to learn from experience. In addition, such conditions or the related social and emotional environments in which they have lived (i.e., less independence or community interaction, interrupted educational opportunities) may mean that their personal risk management skills are lower than that of many people of the same age. This means that if relationships between peers become unsafe, and harm is likely to one or more people candidates need effective support to stop this in such a way that does cause further or related harm. A deep understanding of the needs of learners, well organised and accessible personal and social education and effective, empowering risk assessments are in place to mitigate against risk as is a commitment to restorative practice. However, if serious harm is threatened, occurs, or is persistent, or crimes against individuals suspected additional measures, up to and including the end of placement, may be considered.
Team Domenica takes as is a commitment to restorative practice.
Supported Internships, work experience, job placements and/or visitors to Team Domenica
Candidates at Team Domenica interact with a large number of people-from the general public in the café settings to co-workers in job settings. This is absolutely necessary if the core aims of Team Domenica are to be met and candidates take up meaningful, fulfilling and independent places in our community. To reduce the risk of exploitation and abuse where possible Team Domenica informs partner organisations of their responsibilities, thoroughly risk-assesses the capacity of each individual to manage such risks and teaches specific strategies for safer choices. Overarching this is an expectation of vigilance and information sharing by all employees as set out in this policy.
Concerns arising from outside Team Domenica
A number of the contextual risks listed below such as hate crimes, sexual exploitation and/or harassment are potential risks in all of the above situations, however others are much more likely to occur within the home or social lives that candidates experience outside of Team Domenica. It is essential that all staff are alert to signs that these maybe occurring or that the candidate is at risk of this and report accordingly so that the Safeguarding Team can carry out the necessary checks, including contacting other agencies as appropriate.
Specific Contextual Safeguarding Risks
Controlling or coercive behaviour is a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour. Section 76 of the Serious Crime Act 2015 has created an offence in relation to coercive control within domestic abuse and sets out the importance of recognising the harm and cumulative impact on the victim caused by these patterns of behaviour.
Stalking and Harassment: Stalking refers to unwanted, persistent or obsessive attention by an individual or group towards another person causing fear, anxiety, emotional or psychological distress to the victim. Harassment can include repeated attempts to impose unwanted communications and contact upon a victim in a manner which causes fear or distress to the victim. Stalking and harassment behaviours may include nuisance telephone calls, sending excessive emails, regularly sending gifts, following the person or spying on them and making death threats. The Protection from Harassment Act 1997 makes stalking a specific offence.
Hate Crime is defined as any crime that is perceived by the victim, or any other person, to be racist, homophobic, transphobic or due to a person’s religion, belief, gender identity or disability. It should be noted that this definition is based on the perception of the victim or anyone else and is not reliant on evidence. Such incidents may constitute a criminal offence.
Cuckooing is a form of crime in which drug dealers take over the home of a vulnerable person in order to use it as a base for criminal activity. Organised criminal groups are increasingly targeting adults with care and support needs in this way, and the level of coercion and control involved with cuckooing often leaves the victims with little choice but to cooperate with the perpetrators.
County Lines is the police term for groups who are supplying drugs to suburban areas and market and coastal towns using dedicated mobile phonelines or “deal lines”. It can involve child criminal exploitation and using adults who are vulnerable to move drugs and money. Groups establish a base in the market location, typically by taking over the homes of local adults by force or coercion in a practice referred to as ‘cuckooing’. The Home Office County Lines guidance describes County Lines as a major, cross-cutting issue involving drugs, violence, safeguarding, criminal and sexual exploitation, modern slavery, and missing persons. The response to tackle this activity involves the police, the National Crime Agency, a wide range of government departments, local government agencies, voluntary and community organisations and groups. County Lines activity and the associated violence, drug dealing, and exploitation have a devastating impact on young people, adults at risk of exploitation and local communities.
Extremism and Radicalisation -Young people with additional needs, especially young men with an autistic spectrum condition are at particular risk of being radicalised into extremist ideology and action. This can put themselves and others at risk of harm. A fuller statement is included as an appendix to this policy.
‘Honour’-based violence is a crime or incident which may have been committed to protect or defend the perceived ‘honour’ of the family and/or community. Women are predominantly (but not exclusively) the victims, and the violence is often committed with a degree of collusion from family members and/or the community. Many victims are so isolated and controlled that they are unable to contact the police or other organisations.
Forced marriage is a term used to describe a marriage in which one or both of the parties are married without their consent or against their will. A forced marriage differs from an arranged marriage, in which both parties’ consent to the assistance of their parents or a third party in identifying a spouse. Forced marriage can be a particular risk for people with learning disabilities and people lacking capacity.
Female genital mutilation (FGM) involves procedures that include the partial or total removal of the external female genital organs for cultural or other non-therapeutic reasons. The practice is medically unnecessary, extremely painful and has serious health consequences, both at the time when the mutilation is carried out and in later life. The age at which girls undergo FGM varies enormously according to the community. The procedure may be carried out when the girl is first born, during childhood or adolescence, just before marriage or during the first pregnancy. FGM constitutes a form of abuse and violence against women and girls. In England and Wales, the practice is illegal under the Female Genital Mutilation Act 2003.
Sexual Exploitation involves exploitative situations, contexts, and relationships where adults at risk (or a third person or persons) receive ‘something’ (e.g. food, accommodation, drugs, alcohol, cigarettes, affection, gifts, money) as a result of them performing, and/or another or others performing on them, sexual activities. It affects everyone. People who are sexually exploited do not always perceive that they are being exploited. Those exploiting the adult have power over them such as by virtue of their age, gender, physical strength, and economic or other resources. There is a distinct inequality in the relationship.
Extremism by Radicalisation: Prevent is a key part of the government’s counterterrorism strategy. Its aim is to stop people becoming terrorists, or supporting terrorism, including preventing the exploitation of susceptible people who are at risk of being drawn into violent extremism by radicalisation. As of November 2022, Team Domenica is reviewing its risk assessment, policies and procedure in this area. A statement summarising our duties is an appendix to this policy.
Sexual violence and sexual harassment
That Team Domenica has a zero-tolerance approach to any form of sexual violence and sexual harassment, including online. All staff should proactively reinforce a culture of respect, tolerance and safety. Inappropriate verbal abuse should never be passed off as “banter”, “just having a laugh”, “a part of growing up” or “boys being boys”. Omission of this responsibility normalises abuse and creates an environment in which people feel unable to report their concerns.
That Team Domenica has a responsibility to teach and model appropriate relationships, shared social norms and the law as it relates to abuse, harassment and sexual violence. Many candidates at Team Domenica would not have fully accessed the full statutory Relationship, Sex and Health Education curriculum prior to admissions. Accommodation of an individual’s learning needs is, however, never a reason for others to permit or tolerate sexual harassment or violence.
That all incidents need a rapid response, following the steps outlined below. This response needs to include rapid dynamic risk management, the involvement of external agencies including the police when relevant, support and care for the well-being of all involved, and accurate and effective reporting and recording.
Our Curriculum Policy and our Policy for Promoting Positive Relationships and Behaviour further outline the steps we take to maintain a safe and positive culture.
Sexual violence and sexual harassment can occur between two or more people of any age and sex. It can occur also through a group of people sexually or sexually harassing a single person or group of people. Sexual violence and sexual harassment exist on a continuum and may overlap; they can occur online and face-to-face (both physically and verbally) and are never acceptable.
What actions constitute sexual violence and harassment?
Sexual violence
It is important that schools and colleges are aware of sexual violence, and the fact young people can, and sometimes do, abuse others in this way and that it can happen both inside and outside of college. When referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003.
Rape: A person (A) commits an offence of rape if: they intentionally penetrate the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents.
Assault by penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents.
Sexual assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents. (NOTE – colleges should be aware that sexual assault covers a very wide range of behaviour so a single act of kissing someone without consent or touching someone’s bottom/breasts/genitalia without consent, can still constitute sexual assault).
Causing someone to engage in sexual activity without consent: A person (A) commits an offence if: s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not consent to engaging in the activity, and A does not reasonably believe that B consents. NOTE – this could include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.
What is consent?: Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g.to vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity, and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.
Sexual intercourse without consent is rape.
Some candidates at Team Domenica may not have the capacity to consent and this will need to be considered in risk assessments and reporting.
Sexual Harassment
‘Unwanted conduct of a sexual nature’ that can occur online and offline. Sexual harassment is likely to: violate an individual’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment.
Whilst not intending to be an exhaustive list, sexual harassment can include:
- Sexual comments, such as telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance, and calling someone sexualised names
- Sexual jokes or taunting
- Physical behaviour, such as deliberately brushing against someone, interfering with someone’s clothes. Schools and colleges should be considering when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim
- Displaying pictures, photos or drawings of a sexual nature
- Upskirting (this is a criminal offence)
- Online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include consensual and non-consensual sharing of nude and semi-nude images and/or videos. Taking and sharing nude photographs of U18s is a criminal offence
- Sharing of unwanted explicit content
- Sexualised online bullying
- Unwanted sexual comments and messages, including on social media, or sexual exploitation; coercion and threats, and coercing others into sharing images of themselves or performing acts they’re not comfortable with online
Peer on Peer Abuse or Abuse by children: If a young person, child or children is/are causing harm to a peer or an adult, this should be dealt with under the Safeguarding Adults’ Policy and Procedures. If children are involved, whether as the perpetrator or the victim, this will also need to involve the local authority Children’s Services.
Mental Capacity, Consent and Best Interests
A key issue in the protection of adults at risk is one of consent. Adults at risk have a fundamental right to decide how they live their life and with whom they live. A person who is able to make decisions for their self is entitled to refuse protection. However, if the person lacks mental capacity to make this decision or there is an overriding public interest, (e.g. other adults at risk are at risk) the need for referral should be considered. Wherever possible, the adult at risk should be informed that a referral will be made and the reason for this. Where there is an issue of whether the candidate is able to give consent, a Best Interest Meeting needs to be arranged as soon as possible so that all decisions are made in the best interest of the candidate.
Members of the Best Interest group may include:
- Designated (or Deputy) Safeguarding Lead
- Candidate
- Candidate’s Social Worker
- Parents/Carers
- Relevant medical professional
The Mental Capacity Act 2005 is underpinned by a set of five key principles:
- A presumption of capacity – every adult has the right to make his or her own decisions and must be assumed to have capacity to do so unless it is proved otherwise.
- The right for individuals to be supported to make their own decisions – people must be given all appropriate help before anyone concludes that they cannot make their own decisions.
- That individuals must retain the right to make what might be seen as eccentric or unwise decisions.
- Best interests – anything done for or on behalf of people without capacity must be in their best interests.
- Least restrictive intervention – anything done for, or on behalf of people without capacity, should be the least restrictive of their basic rights and freedoms
Team Domenica will act as if all candidates have capacity until such a time as relevant professionals assess otherwise. On occasion, candidates are admitted to Team Domenica with a partial or specific restriction on their capacity and this will be reflected in the individual risk assessment written by the Pastoral Lead.
Find the Team Domenica Mental Health Capacity form here.
Post Internship Support
A unique feature of Team Domenica’s support for young people in, or seeking work, is that it doesn’t end once paid work is offered. Our Post Internship Manager provides bespoke opportunities for working candidates to meet with her on whatever basis works best for them. For some this is regular scheduled meet ups, some may use a less formal drop-in type session while others may need a targeted piece of work for a fixed time. There will be learners who do not access this support at all.
Although it may look very different to what happens on the main programme our safeguarding work here is based on the same core principals of empowerment, prevention, protection, proportionality and accountability and partnership as in all adult safeguarding. The Post Internship Manager, on hearing of anything that concerns her from someone accessing her service will dynamically risk assess the level of risk and use her knowledge of a young person’s circumstances, support network and capabilities to formulate a response. Where there is a risk of crime or serious harm, immediate action will be taken in the form of a referral to the police or to Adult Social Care, as described in the main body of our policy. In other cases, where such a threshold is not met, then the work may involve supporting the young person to develop the skills necessary to keep themselves safe. A crucial part of the Post Internship Support Manager’s relationship with this cohort is to build a good knowledge of the network around each young person, including family, employer and any agency, so action can be taken by the right person. In all cases, the Post Internship Support Manager will record concerns and actions onto MyConcern.
The Post Internship Support Manager is a member of our monthly safeguarding meetings and from May 2024 there is a standing item for them to discuss the concerns and issues raised in their work and the responses they have given so that they are not working is isolation.
Training for Safeguarding
Team Domenica provides a comprehensive suite of training opportunities for all staff; made specific for the role they undertake.
Each employee is required to undertake a two-stage safeguarding training plan before commencing work in the organisation. This is made up of the Safeguarding Adults online course and is underpinned by a face-to-face session delivered by the Safeguarding Leads. This session includes instruction in the use of MyConcern. Specific team meetings are used to discuss arising practice issues and at least annually there will be a face-to-face refresher of policy and procedure made available to the whole team.
Online training and in-house face to face training is also used for further contextual safeguarding training, such as regular updating of Prevent awareness, risk management and local risks courses and needs that may arise from practice, and specific risks.
The annual whole organisation safeguarding update happens in early September each year and includes:
- Updates made to KCSiE and other relevant guidance
- Learning related to all staff duties related to Part One of KCSIE including individualised action planning related to roles, responsibilities and training needs
- Updates to the policies
- Priorities for the coming year, and input into areas of focus
- In February There is a comprehensive annual survey mandatory for all staff. This focuses on awareness of policy and of KCSiE part one
- Training for the designated leads is sourced from an independent consultant who works with the Safeguarding Team annually.
Appendix 1 - PROCEDURE FOR VISITORS, SPEAKERS AND PARTNERS
Team Domenica believes that learning is best consolidated by a rich variety of activities both on site and in the community and to support this our RSHE and Enrichment Curriculum access a number of visitors, speakers a well as coaches and trainers for off-site activities. Visitors, and those we visit contribute to the life and learning of the college and the experience and opportunities they bring are encouraged and appreciated.
It is the college’s responsibility to ensure that security and welfare of the whole college community is not compromised at any time. It is our aim to make sure that our college is protecting students and staff during college time and in extracurricular activities and to ensure that visitors and those we visit comply with the Visitors & Partners Agreement (See Appendix 3).
“External Speaker”/ “Visitor”/ “Partner” are used to describe any individual who is not a student or staff member of our college who leads or co-leads all or part of a learning activity or who interacts with candidates for a substantial part of a learning activity by invitation of Team Domenica. All such activities organised with “External Speaker”/ “Visitor”/ “Partner” in and outside of our college building are still within the responsibility (and liability) of our college.
Our college will assess the suitability and effectiveness of input from external agencies, individuals or speakers or individuals to ensure that:
- Any messages communicated to students support British Values and Team Domenica’s values
- Any messages communicated to students are consistent with the ethos of the college and do not marginalise any communities, groups or individuals
- Any messages communicated to students do not seek to glorify criminal activity or violent extremism or seek to radicalise students through extreme or narrow views of faith, religion or culture or other beliefs and ideologies (must not incite hatred, violence or call for the breaking of the law)
- Activities are matched to the needs of students
We recognise, however, that the ethos of our college is to encourage students to understand opposing views and ideologies, appropriate to their understanding and abilities, and to be able to actively engage with them in informed debate, and we may use external agencies, individuals or speakers to facilitate and support this. It is essential that this policy is not used to impair discussion or freedom of speech.
Organising the event
When organising an event covered by this policy agreement from the Head of College and/or the Head of Admissions, Safeguarding and Pastoral Care must be sought in advance.
They should be given a clear explanation as to the relevance and purpose of the visit and intended date and time for the visit. Our college reserves the right to cancel, prohibit or delay any event with an external speaker. If this Policy is not followed or if health, safety and security criteria cannot be met.
The member of staff (organiser) who has invited the visitor to college is responsible for the activities that take place within their lessons/events. The organiser must ensure that all speakers/visitors are made aware of their responsibility in-line with the college’s Safeguarding Policy and have read and signed the Visitors and Partner’s Agreement (Appendix 3)
The organiser will conduct a short check into all potential speakers using an open-source check: searching the speaker and any organisation the speaker are affiliated with, on a suitable search engine and look at the first three pages of results. They will then repeat the search with ‘controversy’ added to the search terms. If the speaker has a history of or has in the past been accused of any of the following, the details for the booking will to be sent to the Designated Safeguarding Lead.
The organiser will also not arrange any candidate focused activity without speaking personally to the visitor/partner to ensure they will carry out the activity in such a way that is aligned with our values.
The event will not go ahead as planned if there is any perceived risk that it may involve:
- Inciting hatred, violence or calling for the breaking of the law
- Insulting or making derogatory remarks to other faiths or groups
- Using threatening, abusive or insulting words or behaviour
If no issues are identified, then the event/speaker will proceed with event confirmation.
In particular Team Domenica will not permit any activity that includes:
- Any person or group on/or linked to the UK Government list of proscribed terrorist organisations
- Talks by organisations generally considered to be extremist by Home Office and related organisations
- A speaker who is known to have spoken previously at another institution on a topic that has caused fear or intimidation of students or staff
- A speaker accepted in mainstream as being highly controversial
- A speaker known to/or likely to cause harm to a specific group of staff or students
- A link or links, to any person or group that has, in those search engine listings, been connected with any controversy of a negative or positive nature
- A speaker who has significant profile and attracts a following that could create crowd control and health and safety issues
The safeguarding leads will also consider what external referrals and support may be needed in any such circumstance.
Procedure for speakers on site
- All visitors must meet the organiser or a named colleague before entering any classroom or learning space.
- At reception, all visitors must state the purpose of their visit and who has invited them. They should be ready to produce formal identification where appropriate.
- All visitors will be asked to sign in.
- All visitors will be required to wear a lanyard.
- At no point should a visitor be left on their own with candidates (if the visitor is meeting a member of staff).
- Visitors will be notified that photographs are not permitted without the prior agreement
- Visitors will be informed of the safeguarding details on their lanyard and make themselves aware of procedures, including the named DSL (Designated Safeguarding Lead)
Visitors should be reminded that their internet use at Team Domenica should always only be professional and appropriate and is covered by the online safety policy
- In the event of a fire alarm/drill, the visitor should be accompanied to the assembly point
- The organiser should ensure that at the end of the visit the lanyard is handing in and the visitor has left the learning area
More details for offsite visits are included in our Candidate Risk Assessment Policy.
Confidentiality
Information about candidates and staff is confidential. Volunteers are not permitted to discuss issues related to candidates or staff with those outsides of the organisation.
If visitors have concerns, they should raise these with the appropriate member of staff.
If concerns relate to safeguarding, visitors must follow the guidance in safeguarding policy and inform the designated safeguarding lead. Details on how to do this are on the back of visitor lanyards.
Click here to view the Team Domenica-Visitors, Speakers and Partners Agreement.
Appendix 2 - Procedure for responding to a Safeguarding Concern
Step 1: Appropriately reassure the person about whom the concern has been raised or noted, inform them of steps being taken and what could happen next. If this is not possible, move to Step 2 without delay.
Step 2: Write a clear factual account of what has happened on MyConcern.
This will automatically alert the Safeguarding Team:
DSL Deborah Rayner-Grey deborah@teamdomenica.com
CO-CEO and Principal Lisa Campbell Squires lisa@teamdomenica.com
Alerting Managers
Kate Payne kate@teamdomenica.com
Becky Chan becky@teamdomenica.com
Bekki Lindores bekki@teamdomenica.com
Amanda Thomson AmandaT@teamdomenica.com
Ruth Thomas Ruth@teamdomenica.com
Sara Fletcher sara@teamdomenica.com
Beverley Rosling beverley@teamdomenica.com for safer recruitment and HR related issues
Step 3: If MyConcern is not available, any of the exceptional circumstances above apply or you have any further concerns about safeguarding the candidate(s), call the Safeguarding Telephone Line on 01273 056807.
Step 4: The Safeguarding Team will investigate the report and decide on appropriate actions.
Step 5: The Safeguarding Team may need to contact you for further information. If you receive further information after your initial report, then this must be recorded and shared.
Step 6: If you have been personally affected by a safeguarding situation, seek support from your manager.
Appendix 3 - Key Contacts
Emergency 999
NHS Non-Emergency (24hr) 111
Sussex Police Non-Emergency 101
Brighton & Hove SAB (Safeguarding Adults Board): hascsafeguardinghub@brighton-hove.gov.uk
BHCC Adult Social Care Access Point Team: 01273 295 555 or email accesspoint@brighton-hove.gov.uk
East Sussex SPoA (Single Point of Access): 01323 464222 or 0-18.spo@eastsussex.gov.uk
East Sussex Adult Social Care:0345 60 80 191 (for out of hours 0345 60 80 191 select menu option 2)
West Sussex Adult Social Care: 01403 229900
West Sussex Adult Social Care urgent referrals: 0330 222 7007 or 0330 222 28400 (professionals only)
St John’s Senior Safeguarding Lead: Ellie Crosthwaite: elliecrosthwaite@st-johns.co.uk
BHCC Children’s Services: 01273 290400
Front Door for Families (for concerns around under 18s): 01273 335059 (out of hours)
Healthwatch Brighton & Hove Helpline: 01273 234040
National Domestic Violence Helpline (24h) Freephone: 0808 2000 247
Public Concern at Work (to report suspected workplace malpractice): 020 3117 2520
or Contact Protect Advice Line
Carers Direct National Helpline Freephone: 0300 123 1053
Brighton & Hove Speak Out: 01273 421921
NSPCC: 020 7825 2505
Worried about a child? Call 080 880 5000 help@nspcc.org.uk
Childline: 0800 1111
Mind in Brighton & Hove: 01273 666950
Samaritans: 116 123
You have a professional responsibility to stay updated with the safeguarding policy, relevant training and on how to use MyConcern. Log into MyConcern.
Appendix 4 - Support and specialist organisations
Read the rest of our organisational policies