Safeguarding Policies and Procedures

Chapter Contents

• Agency Safeguarding Policy, Procedures and Training
• Young Children and Children with Disabilities
• Child Exploitation
• Female Genital Mutilation
• Forced Marriage and Honour-Based Abuse
• Trafficked Children and Young People
• Radicalisation and Extremism
• Children Missing from Care
• Online Safety
• Peer on Peer Abuse
• Bullying

Agency Safeguarding Policy, Procedures and Training

Safeguarding is everyone’s responsibility, and all staff and foster parents are provided with the agency’s safeguarding policies and procedures immediately. Those involved in the care of anyone over 18 years of age are also provided with our Safeguarding Adults procedure.

Our policies and procedures:

We require all staff and foster parents to complete mandatory safeguarding training, with an annual refresher.

Our suite of training courses:

• Safeguarding (Foundation)
• Safer Care and Managing Allegations
• Adultification
• Bullying
• Child on Child Abuse
• Child Sexual Exploitation
• Cyberbullying Awareness
• Domestic Abuse
• FGM, Forced Marriage and HBV
• Modern Slavery
• Online Safety
• Parentification
• Sexting Awareness
• Sexualised Behaviour Awareness in Children and Young People

Young Children and Children with Disabilities

Increased Vulnerability

Statistically, very young, and disabled children are more vulnerable to mistreatment and harm. Reasons include:

• Lack of support for families, leading to increased levels of parental stress.
• Having a restricted social network, meaning that there are fewer opportunities to identify neglect and abuse.
• Dependency on parents and carers for practical assistance in daily living, including intimate personal care.  There is a greater opportunity for an abusive adult to be alone with the child at a time when they are most vulnerable.
• A reduced capacity to resist or avoid abuse. 
• Speech, language, and communication needs which may make it difficult for them to tell others what is happening. 

Research has shown that professionals involved in their care may be reluctant to act on concerns for such reasons as:

• Over identifying with the child’s parents or carers and being reluctant to accept that abuse or neglect is taking place.
• A lack of knowledge about the impact of disability on the child. 
• Not knowing enough about the child e.g. not knowing their usual behaviour. 
• Being unable to understand the child’s method of communication. 
• Believing that behaviour of concern is due to the disability, rather than indicating potential abuse. For example, sexually harmful behaviour and self-harming. 

If you have any concerns that a child may have experienced abuse, you should contact your supervising social worker straight away.

Read more information about particularly vulnerable children and families at the NSPCC website.

Read the Government’s guidance on safeguarding disabled children

Accidents and Injuries

Young children are particularly at risk of accidents for several reasons:

• They are often absorbed in activity and may be unaware of what’s going on around them.
• Being less able to regulate strong emotions – they may run blindly into danger when angry or scared.
• Having a limited perception of risk because of their lack of experience or stage of development. They may also not be aware of the consequences of their actions.
• Some children enjoy physical play and this can result in pushing, shoving and wrestling with other children – which can result in accidents

Young children need a high level of supervision to help prevent accidents. Please report all accidents to ISP, and we will ask you to complete an accident form if there are any physical injuries or bruising.

Please see our Accidents and Incidents – Essential Information for Foster Parents, and our policy.

Bruising or Injury in Non-Mobile Babies

Bruising or injury in non-mobile babies is always a matter for concern, and an indicator of potential neglect or abuse. Please report any such injuries to ISP immediately. ISP is required to make a safeguarding referral to the local authority.

In the context of a parent-and-child placement, if as a foster parent you notice the bruising or injury in the presence of the parent, it may be appropriate and necessary to comment on this, e.g. ‘I notice baby has a bruise on his leg’, and remind the parent that you have a duty to report this to ISP. In order not to hinder the local authority’s safeguarding procedures, do not engage in discussion with the parent about the injuries or ask any questions, but you can report anything that the parent says in reply to your acknowledgement of the injury as part of the notification to ISP.

Read our Bruising or Injury in Non-Mobile Babies Procedure

Safe Bathing

Baths are the most common place for babies and young children to drown. Babies and children can drown in as little as 5cm (2 inches) of water. Drowning is one of the common causes of child death – it’s often silent, so you won’t necessarily hear any noise or struggle.

Important

• Children aged 5 or under should always have constant supervision while bathing.
• Children with disabilities and complex needs may need supervision until a later age than other children.
• Children up to the age of 8 should still have a level of appropriate supervision to ensure their safety.
• The child’s Safer Care Plan should include their bathtime routine, including the required level of supervision.

The NHS gives the following advice:

• Stay with the baby or toddler the whole time they’re in the bath. Never leave them for a moment.
• If you use a bath seat, remember that it’s not a safety device. You still need to stay with them all the time.
• Empty the bath as soon as you’ve taken the child out.
• Keep them within arms’ length at all times.
• Give them your full attention (leave phones outside the bathroom).
• Children must only be supervised by adults (not older siblings).
• Bathe the child in the smallest amount of water possible.
• If you need to move away from the bathroom, take the child with you.

Read further advice at the ROSPA website.

Safe Sleeping

This guidance is intended to reduce the risk of Sudden Infant Death Syndrome (SIDS) which is commonly known as cot death. It is based on advice from the NHS and The Lullaby Trust. If you are caring for a baby, follow this advice for all sleep periods, day and night.

The Child Specific Safer Care Plan for children aged 0-3 years includes a safe sleeping section and your supervising social worker will discuss expectations with you.

The following are some key pieces of guidance from our Safer Sleeping Procedure.

• Babies must sleep in the same room as their care giver for at least their first 6 months (for premature babies it is 6 months from their due date).
• The safest place for babies to sleep is in their own moses basket or cot. Never fall asleep with baby.
• Avoid using ‘next-to-me’/bedside cots.
• Lay babies on their backs to sleep, with their feet near the foot of the cot.
• Keep the baby’s environment smoke-free at all times.
• Sleeping areas must be between 16-20°C.
• Do not allow babies to get too hot whilst sleeping:
  • Use well-fitted, lightweight bedding.
  • A sheet and blanket, or a baby sleeping bag is the only bedding advised by the NHS for babies.
  • Don’t cover the baby’s head while they are sleeping
  • Do not position cots / moses baskets under a window or near a radiator
• Use a new mattress for each baby. Mattresses must be firm and waterproof.
• Keep babies’ sleep spaces flat and clear – no pillows, quilts, bumpers,
• Do not use cot mobiles for babies 4 months and over, or babies who are starting to become mobile.
• Don’t use neck cords (e.g. with dummies and biccie pegs).
• Remove bibs before sleep.
• Do not use travel cots in place of a standard cot for permanent or long-term use.
• Babies must not sleep for long periods in swings or bouncers.
• Babies must not sleep for long periods in car seats (maximum of 2 hours). For premature or low-weight babies, a maximum of 30 minutes applies.
• If using a baby carrier or sling, follow the manufacturer’s guidelines. Keep the baby in an upright position.

Please refer to our Safer Sleeping Procedure for full details.

Child Exploitation

Sexual Exploitation (CSE)

Child sexual exploitation involves a relationship with an imbalance of power, in which the abuser manipulates, coerces, intimidates or forces child victim into sexual activity. Both boys and girls can become victims of CSE and offenders often use technology (mobile phones, social media) to groom young people and establish control over them. Young people can be drawn into sexually exploitative relationships in the following ways:

• As a way of obtaining drugs, alcohol and money.
• In exchange for somewhere to live. Homeless young people are vulnerable as they depend on others for shelter.
• Through bullying, blackmail or threats of violence.

Some young people in foster care will have experienced sexual exploitation, while others will currently be vulnerable. It is important that young people in your care feel comfortable talking with you about sex and relationships and that you create an environment in which they feel safe to disclose concerns.

Signs that a young person might be experiencing CSE include (but are not limited to):

• Physical injury, e.g. unexplained bruising 
• Recurring or multiple sexually transmitted infections 
• Evidence of substance misuse 
• Frequently being missing from placement, or truanting from school 
• Involvement in ‘petty crime’ e.g. shoplifting 
• Entering or leaving vehicles driven by unknown adults 
• Mobile phones from unknown sources 
• Low self-esteem, self-harm, eating disorders 
• Hostility in relationships 
• Secrecy about friends and internet activity

Criminal Exploitation (CCE)

Criminal Exploitation involves the manipulation and coercion of children into criminal activity. It often involves gang activity, and includes the involvement of children in ‘County Lines’ drug activity. In all cases, those exploiting the child have power over them by virtue of their age, gender, intellect, physical strength, economic, or other resources. Violence, coercion and intimidation are common. A child’s poor social or economic circumstances or emotional vulnerability can result in them being more vulnerable to exploitation.

The Child Criminal Exploitation Strategy 2018 identifies criminal exploitation of young people as a combination of:

• Pull factors: children performing tasks for others resulting in them gaining accommodation, food, gifts, status or a sense of safety, money or drugs; often the hook is through the perpetrator supplying Class B drugs such as cannabis to the child.
• Push factors: children escaping from situations where there is high family conflict or the absence of a primary attachment figure.
• Control: Brain washing, violence and threats of violence by those exploiting the child, particularly when the child is identified by the police, and is expected to take full responsibility for the offences for which they are charged i.e. possession and supply of illegal substances.

Children’s vulnerability to criminal and/or sexual exploitation will be explored in their Individual Safeguarding Risk Assessment. If you are concerned that a child or young person may be subject to exploitation, report this immediately to ISP and we will ensure that an appropriate safeguarding referral is made.

If you believe the child may be at immediate risk of harm, you should contact the police on the emergency 999 number.

For more information, see our Safeguarding Children at Risk of Exploitation policy:

Female Genital Mutilation

Female genital mutilation (FGM) is a collective term for procedures which include the removal of part or all of the external female genitalia for cultural or other non-medical reasons. Communities that perform FGM can be found in parts of Africa, the Middle East and Asia. There are immediate and long-term health consequences of the practice, which is medically unnecessary and extremely painful. Children aged 4-13 years are most at risk, but there have been cases involving newborn babies or young women before marriage.

FGM is illegal in the UK. It is also an offence for a UK national or UK resident to carry out FGM abroad or to in any way enable the procedure to be carried out abroad, even in countries where the practice is legal. The United Nations and the World Health Organisation have declared FGM to be a violation of women’s human rights.

If you have concerns about the welfare and safety of a child or young person in relation to Female Genital Mutilation you should immediately inform your supervising social worker who will consult with ISP’s safeguarding lead.

For more information, see our Safeguarding Against Female Genital Mutilation Procedure.

Forced Marriage and Honour-Based Abuse

Honour-based abuse is a crime or an incident that may have been committed against somebody to defend the honour of the family or community. It is a cultural, not a religious practice.

it is often committed by family members or acquaintances who believe someone has brought shame to their family or community by doing something that is not in-keeping with the traditional beliefs of their culture. For example, it might be committed against people who:

• Become involved with a boyfriend or girlfriend from a different culture or religion.
• Want to get out of an arranged marriage or do not want to enter into an arranged marriage.
• Reject a forced marriage.
• Wear clothes or take part in activities that might not be considered appropriate within a particular culture.
• Behave in a way that is viewed to be untraditional or shameful.

A forced marriage is where one or both people do not consent to the marriage and pressure or abuse is used to make the marriage take place or to force it to continue against the wishes of one or both partners. Forced marriage is against the law and a violation of human rights.

Women and girls are the most common victims of honour based abuse. Crimes of ‘honour’ do not always include violence, which is why it is referred to as honour-based abuse. Some people consider the concept of ‘honour’ to be extremely important. To compromise a family’s ‘honour’ is to bring dishonour or shame and this can have severe consequences. The punishment for bringing dishonour can be emotional abuse, physical abuse, family disownment and in some cases even murder.

When honour-based crimes involve a child, they will also constitute child abuse.

Action

If you are concerned that a child or young person is at risk of honour based abuse or forced marriage, act immediately and inform your supervising social worker, who will initiate safeguarding procedures. It is important to maintain confidentiality about your concerns to ensure the child’s safety.

For more information, see our Safeguarding against Honour Based Abuse and Forced Marriage Procedure.

Trafficked Children and Young People

Who are trafficked children?

Trafficked children are those who have been brought into the country for the purposes of exploitation. This can include:

• sexual abuse and/or prostitution
• forced and/or cheap labour
• slavery or servitude
• financial or benefit fraud
• importation and sale of drugs

These children will often arrive in the country as unaccompanied minors or asylum seekers. They may be unaware that people have brought them into the country for these reasons. Those who are aware may be compliant or too frightened to tell.

Identifying trafficked children

The immigration authorities screen unaccompanied children arriving in the country, at the point of entry. Some children might arrive with only vague information about who is going to look after them, or the immigration authorities may have concerns about the adults who have been identified as their future carers. In these circumstances, the children will usually be placed in foster care for at least a short time, while their situation is explored. They are at particular risk of adult exploitation, but will rarely tell a foster parent about it. They might, however, show patterns of behaviour and activity that indicate possible exploitation. These include:   

• Not having money or possessions on arrival, except a mobile phone.
• Receiving unidentified/unexplained phone calls. 
• Possessing unexplained money/goods. 
• Having a prepared story – appearing to have been coached in explaining how they arrived in the country. 
• Showing signs of physical or sexual abuse or sexually transmitted disease or pregnancy. 
• Having unexplained absences from the carer’s home or going missing. 
• Unidentified adults loitering outside or near carer’s home. 
• Acquiring expensive clothes, mobile phones etc. without plausible explanation. 
• Possessing keys to unidentified premises. 
• Entering or leaving cars driven by unknown adults.
• Inappropriate use of internet and forming on line relationships with adults. 

These indicators are not a definitive list but possible signs of trafficking and/or child sexual exploitation (CSE).

Safeguarding children at risk of being trafficked

When unaccompanied children are first placed with foster parents, the local authority should undertake a risk assessment and consider the possibility that the child may have been trafficked. If you have concerns, talk to your supervising social worker who will report to the local authority social worker. The local authority will decide whether to launch formal child protection procedures.

Radicalisation and Extremism

Radicalisation is a process through which a person comes to support or be involved in extremist ideologies.  It can result in a person becoming drawn into terrorism and is in itself a form of harm.

Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.  It includes calls for the death of members of the British armed forces. (source: NSPCC) 

Young people, especially teenagers, will come into contact with new people at school or college, youth clubs, religious organisations and online. Meeting new people, and exploring new ideas could lead to them adopting views that you consider extreme, and there is the risk that they could become radicalised through these extreme views.

Some possible signs to be alert to:

• Believing that their religion, culture or beliefs are under threat or being treated unfairly
• The need for identity and belonging 
• Being secretive about their social networks, both in real life and online 
• Becoming emotionally volatile  

If you are concerned that a young person might be danger of radicalisation, speak immediately with your supervising social worker or manager who will liaise with the local authority about the appropriate course of action. 

For more information, see our Extremism & Radicalisation Practice Guidance and Procedure

Read the Government’s Prevent Strategy 

Children Missing from Care

Children at risk of going missing

Every young person in placement has a safeguarding risk assessment. This should identify any existing risks of the young person going missing and any specific factors that may increase the likelihood of the child going missing in the future.

Where there are known risks, the multi-disciplinary team will devise a plan to reduce the likelihood of the child going missing. For example, clear arrangements for contact between a fostered child and their birth family may reduce their anxiety about when they will see their family and in turn reduce their likelihood of running away.

There are many reasons why young people go missing from care placements. We sometimes refer to these reasons as “push and pull factors”. “Push factors” would be any aspects of the care placement that the young person is seeking to avoid or escape from, while “pull” factors are those which are drawing a young person away.  Over time, as your relationship develops, you will come to learn what motivates the young person to run away, be able to recognise the early warning signs, and hopefully be able to intervene to prevent them from going. 

If a young person is intent on leaving, you should try to persuade them to stay, but should not use physical restraint should solely to prevent them leaving.  Only use physical restraint when necessary to prevent injury to the child or others, or serious damage to property. No physical intervention may be excessive or unreasonable.

What to do when a child or young person is missing

If a child is missing, you need to report this to ISP.  Contact your supervising social worker or manager during normal working hours, or the out-of-hours service at evenings or weekends.

Your supervising social worker will help you to try and locate them.  If they’re not answering their phone, you might be asked to try and call their friends or family, or visit an address where they claim to be (subject to any safety issues).  This can be a powerful demonstration to the young person that you are available to them and that they belong with you and your family. 

Is this an Unauthorised Absence or Missing Child?

If the child is missing without your permission but you know where they are, we will treat this as an ‘unauthorised absence’. You should act as a responsible parent would and take all practical steps to identify their whereabouts and try to ensure that they return home straight away. If they do not return within a reasonable period of time, and we believe they are vulnerable and at risk of harm, we will report them as a missing child.

If the child is missing from placement, you do not know where they are, and cannot find them within a reasonable period of time, then we will report them as a missing child.

Reporting the child as missing

If a child is absent without permission, whether or not you know their whereabouts, you must notify ISP without delay.

We will report all ‘unauthorised absences’ to the young person’s local authority. They might ask us to report the child missing to the police.

If the child is missing, and you don’t know where they are, your supervising social worker/out-of-hours worker will ask you to call the police and report them as missing, while they let the local authority know. The child’s local authority might notify the child’s birth family.

When you report a child as missing to the police, always emphasise that they might not be safe, even if you know their whereabouts.  The police will visit you to gather information about the child and their possible location.  Have a current photo available to give to the police. Depending on the circumstances, the police might search your home and garden to ensure the child is not hiding on the premises.

Most missing children are found quickly, but some children may be missing for longer periods of time, or may go missing regularly. Systems are in place to ensure that the police, local authority and ISP remain proactive in locating the child and ensuring they return home safely. 

When a Missing Child is found

The Police are the people most likely to find a Missing Child and may return the child directly to your home or take them to a local Police Station to wait until you or a social worker can collect them.

If the police believe a child has been involved in criminal activity while missing, they may take them to a police station for questioning. The age of criminal responsibility in the UK is 10 years.

The police should inform you or the child’s social worker immediately if they detain a child for questioning. If the young person is under the age of 17, the police must follow a number of procedures defined in the Police and Criminal Evidence Act (1984). These include the child’s right to consult with a solicitor and that children should only be formally interviewed in the presence of an ‘appropriate adult’.

An ‘appropriate adult’ could be a social worker from the local authority or ISP, or a foster parent. If the police contact you and tell you that your foster child has been arrested, they will give you the reason for the arrest and the address and phone number of the police station in which the child has been detained. You should phone your local ISP centre or the out-of-hours service, to decide who should act as the ‘appropriate adult’.

For more information, see our Appropriate Adult Procedure:

Training opportunity: Criminal Justice System and the Role of Appropriate Adult – book on ‘Learnative’.

When a missing child returns

When a young person returns, the local authority will arrange a ‘return interview’ to try and find out why they went missing.  An professional who is independent of the placement should conduct this interview.  This might be the young person’s local authority social worker, an advocate or another independent adult.  The interview should take place, if possible, before the child actually returns to your home, but certainly within 72 hours of returning.

Children run away for a variety of reasons, but often because they are confused or unhappy about something. Though the reason may sometimes seem very trivial, at the time the child ran away it was the only way they felt they could deal with their confusion or unhappiness. They may not have got very far away, before they realised that there were other ways of dealing with the problem. They may feel very embarrassed and so coming home may be difficult and they will need an understanding welcome.

Whilst the child is missing, it is an emotionally challenging time for foster parents, and if the child frequently goes missing, you and your family can feel physically tired from lack of sleep and worry, dispirited and resentful at the child’s apparent disregard of your needs and feelings. When the child returns, you might experience a mixture of relief and anger. You should expect help and support from your supervising social worker with your feelings so that you will be in a position to be helpful to the child, when they return.

If a young person goes missing for a long period of time, or on a regular basis, their social worker will call a meeting with you, ISP and the young person to see what further action can we can take to help and protect them.

Payments to foster parents when a child is missing

Payments may continue while a child is missing, but this will not continue indefinitely and they are subject to monitoring and review.  The local authority might decide to terminate a placement if the child is missing for more than a few days.   

For more information, read our Children Missing From Care Policy and Procedures

Online Safety

The use of technology, and going online, have become part of everyday life for both young people and adults in the UK. Young people start using online information and services at a young age, both at home and in the school environment.  Helping keep them safe online is an essential part of caring for children and young people.

Keeping young people safe online involves two things:

1. Using parental controls to block and filter age-inappropriate content.
2. Teaching young people to recognise and avoid risks so that they learn to keep themselves safe online.

It is not important for you to understand how all the technology works, but it is important that you are able to talk about online behaviour and risks with your young people. ISP will provide training to help you with this.

There is more information in Part 6 of the Foster Parent Handbook.

Read our E-Safety Practice Guidance Procedure

Peer on Peer Abuse

The term ‘peer on peer abuse’ relates to various forms of abuse, where all parties involved are under the age of 18 years. The abuse can include:

• violence and criminal activity
• harmful sexual behaviour
• sexual exploitation
• relationship abuse and
• bullying (including cyberbullying)

This type of abuse is harmful to both the victim and the perpetrator due to their status as children.  Young people who are particularly vulnerable include those with disabilities, those who represent minority groups (based on sexuality, race or religion), and young people drawn to gangs.

Please be alert to the signs of peer on peer abuse and be familiar with our policies to ensure a swift and appropriate response. Young people’s risk assessments should identify key concerns and safeguarding measures for use within the home and community.

For more information, see our Peer on Peer Abuse policy,

Bullying

We try to ensure a culture in ISP that regards any form of bullying as totally unacceptable. We want our foster parents and staff to be able to recognise and deal with any indications or incidents of bullying. It is important that we support young people who are being bullied, while also helping and guiding those who bully to prevent them continuing to do so.

What is bullying and how to respond?

Bullying can include the following types of behaviour:

• Name calling and teasing, including taunts about sexual orientation and race. 
• Gestures, taunting and mocking. 
• Making offensive comments. 
• Malicious gossip. 
• Stealing from the victim. 
• Extortion of money, food or homework. 
• Physical violence, such as pushing, punching or pulling hair. 
• Coercion. 
• Isolation from groups. 

Bullying is deliberately hurtful and difficult for victims to defend themselves against.

Children are the most likely group in the population to experience bullying, especially in a school environment, though it can take place in any setting, including home.

Bullying at School

Every school has an anti-bullying policy, and they should share this with parents and carers. The policy will outline the school’s procedure for responding to allegations of bullying. Encourage and support your young people to report any experiences of bullying at school.

If you think your child is being bullied, you should:   

• Talk to the child about their experiences. Let them know that there are things you can do to stop it.
• Keep a record of what the child says, especially of the incidents of bullying. 
• Reassure the child that they are right to tell you about the bullying. 
• Advise the child that they should report any further incidents at school to a teacher straight away. 
• Discuss how to resolve the situation with your supervising social worker and the child’s social worker. 
• Make an appointment to meet with the child’s teacher – explain the problem and agree on what the school will do to stop any further bullying. 
• Keep a record of what has been agreed and make a time to meet the teacher again to discuss what progress has been made. 
• If little progress has been made, discuss with your supervising social worker and the child’s social worker whether to request a meeting with the head teacher or register a formal complaint. 

Bullying in the Community

If you suspect bullying in the community, formulate a plan with your supervising social worker to address the concerns.  This should include:

• Who should talk to the child or young person. 
• Who else needs to be notified (e.g. schools, birth parents). 
• Any immediate action needed to safeguard the child/young person.

The plan should involve any relevant others, including:

• The foster child or young person. 
• Other children or young people in the household. 
• The foster child’s birth parents. 
• The bully. 
• The social workers and parents of other children in the foster home. 
• Other relevant professionals such as teachers and therapists. 

After your concerns have been discussed with the child or young person, and bullying is confirmed or continues to be suspected then a protection plan should be drawn up to attempt to ensure the bullying ceases and does not re-occur.

If the bullying is being done by someone outside the foster home, then attempts should be made to engage the bully’s parents or carers in helping to put an end to the bullying. The social worker for the child or young person, rather than the foster carer, would normally undertake any contact with parents or carers in such circumstances. 

Bullying behaviours by a child

Foster parents who are concerned a foster child is bullying others should:

• Challenge the young person’s behaviour as unacceptable and explain why. 
• Ask what the young person can and will do to change such behaviour. 
• Try to find out what has led to the child’s behaviour.  
• Seek a meeting with the young person’s school to discuss how other professionals can work together to stop a young person’s bullying behaviours. 
• If the bullying behaviour doesn’t stop, talk to your supervising social worker about the use of sanctions.

Bullying against foster parents

If you believe you have been subjected to bullying by an ISP employee, you should follow our Complaints and Representations Procedure.

For more information, read our Anti-Bullying procedure.