Safeguarding and Prevent Policy

Title: Safeguarding and Prevent Policy

Reviewed by: Designated Safeguarding Lead

Sept 2025

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Approved by: Quality & Standards Committee

20 November 2025

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Date of next review: Sept 2026

Contents:

1. Purpose and aims
2. Roles and responsibilities
3. Safeguarding referrals and communication
4. Application
5. Policy Review and Compliance
6. Prevent Strategy
7. Associated information and guidance

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1. Purpose and Aims
Bath College has a statutory and moral duty to ensure it safeguards and promotes
the welfare of all college users. This includes students/apprentices who study and
work on courses away from the college premises with particular reference to
young people and vulnerable adults receiving education and training at Bath
College. This is in line with the procedures set out by Bath & North east Somerset
Community Safety and Safeguarding Partnership, Working Together to Safeguard
Children 2023 and Keeping Children Safe in Education by:

• Ensuring a safe environment where all users, particularly young people and
vulnerable adults, can learn, thrive, and progress. This commitment extends
to students and apprentices who study or work off-campus.

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• Being dedicated to identifying users, especially children, young people,
and vulnerable adults, who are at risk of harm and taking necessary actions
to ensure their safety both within the College, at home, and in work-based
settings, aiming for their best outcomes.

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• Ensuring regular contact with children and young people within the
organisation undergoes appropriate checks and training based on their
role and responsibilities.

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• Promoting a collective responsibility for safeguarding: all staff, Governors,
volunteers, students, apprentices, employers, and stakeholders must
actively contribute to the safety of children, young people, and vulnerable
adults.

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• All staff mentioned being confident in reporting any safeguarding concerns
to the Safeguarding Team, assured that these will be addressed promptly,
securely, and with the student’s or apprentice’s wellbeing as a priority. Bath
College fosters a culture where all staff have a clear understanding of
safeguarding and child protection, including identifying, responding to,
and reporting abuse and neglect in all forms, as well as managing
allegations against professionals.

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Special Educational Needs and Disabilities (SEND) & Related Safeguarding

The college follows the statutory definition of Special Educational Needs and
Disabilities (SEND) in the Children and Families Act 2014: a young person has SEND
if they have a learning difficulty or disability requiring special educational
provision.

We recognise that learners with a disability may be more vulnerable to harm,
including discriminatory abuse, harassment, ill-treatment, or denial of rights based
on disability, race, gender, religion, or other protected characteristics.

Staff must remain alert to these risks and take immediate safeguarding action if
discriminatory abuse is suspected.

Where a student is living in a private fostering arrangement (cared for by
someone who is not a parent or close relative for 28 days or more), staff must
notify the Designated Safeguarding Lead (DSL), who will inform the Local
Authority in line with statutory guidance.

Bath College recognises the fact that additional barriers can exist when
recognising abuse, neglect and exploitation in this group of children. These can
include assumptions that indicators of possible abuse such as behaviour, mood
and injury relate to the child’s condition without further exploration.

Bath college recognises the fact that additional barriers can exist when
recognising abuse, neglect and exploitation in this group of children. These can
include these children being more prone to peer group isolation or bullying
(including prejudice-based bullying) than other children

Bath College recognises the fact that additional barriers can exist when
recognising abuse, neglect and exploitation in this group of children. These can
include the potential for children with SEND or certain medical conditions being
disproportionately impacted by behaviours such as bullying, without
outwardly showing any signs

Bath College recognises the fact that additional barriers can exist when
recognising abuse, neglect and exploitation in this group of children. These can
include communication barriers and difficulties in managing or reporting these
challenges, including cognitive understanding – being unable to understand the
difference between fact and fiction in online content and then repeating the
content/behaviours in schools or colleges or the consequences of doing so.

The College is committed to ensuring the safety and wellbeing of all students, staff,
governors, parents and carers in the digital environment. Online engagement is
an essential part of education and daily life, but it brings with it a range of
safeguarding risks that must be proactively addressed.

safe@bathcollege.ac.uk

All College staff must report safeguarding concerns via the CPOMS system as
outlined in the associated safeguarding procedures. External parties can make
referrals by emailing or by calling/texting 07815491988 or
07966980534. Welfare Officers, under the direction of the Deputy DSL, promptly
address these referrals during normal College hours.

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In line with updated national guidance, the College recognises the following as
significant online safeguarding harms under the “content” risk category:

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• Misinformation – false or misleading information shared without harmful
intent.
• Disinformation – deliberately false information, including fake news, shared
with the intent to deceive.
• Conspiracy Theories – narratives that undermine trust in institutions or
promote harmful ideologies.

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These risks are addressed through a comprehensive personal development
curriculum, including digital safeguarding. This includes awareness training,
curriculum integration, and regular updates via safeguarding briefings.

The College uses Smoothwall to ensure robust filtering and monitoring of online
activity. In accordance with the Department for Education’s guidance:

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• “Generative AI: product safety expectations” – any AI tools used within the
College are assessed for safety, appropriateness, and compliance with
filtering and monitoring standards.
All staff receive safeguarding training that includes online safety risks and how to
identify and report concerns. Professional conduct online is governed by the
College’s IT Acceptable Use Policy, which outlines expectations for both personal
and organisational representation.

Online safety activities are informed by the Online Safety Act 2023 and are
detailed further in the College’s standalone Online Safety Policy.

The College provides a safe, inclusive, and respectful environment where all users
can learn and operate. This environment prioritizes their safety, respects their
wishes and feelings, and promotes positive wellbeing. Our goal is to cultivate
students, apprentices, and staff who are confident, healthy, safe, emotionally
resilient, and personally fulfilled. A significant focus is on minimising harm to young
people and vulnerable adults, including addressing child-on-child abuse with the
same seriousness as other forms of abuse or harassment. Bath college recognises
that child-on-child abuse may be happening even if there are no reported cases.
Staff are trained to act in the best interest of students and apprentices,
maintaining an attitude focused on any potential risks being assessed seriously
and immediately.

Bath College recognises that it is more likely that girls will be victims and boys
perpetrators, but that all child-on-child abuse is unacceptable and will be taken
seriously.

Bath College has a designated Link Governor with lead responsibility for
safeguarding to ensure governance guidance regarding this key function of the
college.

As an integral part of the local community, Bath College maintains strong
relationships with external agencies to manage and reduce conflict, and to foster
respect and tolerance among diverse groups. We aim to promote fundamental
British values and prepare students and apprentices for life in modern Britain,
encouraging them to interact and learn from people of different backgrounds.

Bath College also ensures that any work placement or work-based learning
environment for students and apprentices is safe, with risks minimised or
eliminated.

This policy and its associated procedures apply to all staff, students, apprentices,
and other users of Bath College, including volunteers, external contractors,
remote students, and employers involved in student/apprentice work placements.

Throughout this policy, the term 'College users' refers to all students and
apprentices, with particular emphasis on safeguarding duties for young people
under 18 years of age and vulnerable adults.

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Abuse of Trust

All staff must understand that inappropriate behavior towards children, young
people, or vulnerable adults is unacceptable. Under the Sexual Offences Act
2003, it is a criminal offense for anyone in a position of trust (e.g., teacher, youth
worker) to engage in a sexual relationship with a child or young person (under 18)
or with a vulnerable adult, even if the relationship is consensual. This applies when
the child, young person, or vulnerable adult is in full-time education, and the
individual in a position of trust works at the same establishment, regardless of
whether they directly teach or interact with the person.

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Children and young people

Bath College and the Governing Body recognises the following summary
statements as definitions of abuse in terms of Child Protection (from ‘Keeping
Children Safe in Education’):

Abuse: a form of maltreatment of a child, which can occur through inflicting harm
or failing to prevent harm. Harm includes both physical and non-physical ill-
treatment, as well as the impact of witnessing the ill-treatment of others. This is
particularly relevant in cases of domestic abuse and its effects on children. Abuse
can occur in family, institutional, or community settings, perpetrated by individuals
known to the child or, less commonly, by strangers. It can happen entirely online
or be facilitated by technology for offline abuse. Children may be abused by
adults or by other children.

Physical abuse: a form of abuse involving actions such as hitting, shaking,
throwing, poisoning, burning, scalding, drowning, suffocating, or otherwise
inflicting physical harm on a child. It can also occur when a parent or carer
fabricates or deliberately induces illness in a child.

Emotional abuse: the persistent emotional maltreatment of a child, causing
severe and adverse effects on their emotional development. It can involve
making a child feel worthless, unloved, inadequate, or valued only for meeting
someone else's needs. This abuse may include denying the child opportunities to
express their views, deliberately silencing them, or mocking what they say or how
they communicate. It can also involve imposing age or developmentally
inappropriate expectations, such as interactions beyond the child's capability,

overprotection, limiting exploration and learning, or preventing normal social
interaction. Emotional abuse may include witnessing or hearing the ill-treatment
of another person, serious bullying (including cyberbullying), causing the child to
feel frequently frightened or in danger, or exploiting or corrupting the child.
Emotional abuse is present in all forms of child maltreatment and can also occur
on its own.

Sexual abuse: involves forcing or enticing a child or young person to participate
in sexual activities, which may or may not involve violence, and the child may be
unaware of what is happening. These activities can include physical contact,
such as penetration (e.g., rape or oral sex) or non-penetrative acts like
masturbation, kissing, rubbing, and touching outside of clothing. They can also
involve non-contact actions, such as making children look at or produce sexual
images, watch sexual activities, encouraging inappropriate sexual behavior, or
grooming a child for future abuse. Sexual abuse can occur online, with
technology facilitating offline abuse as well. Perpetrators are not limited to adult
males; women and other children can also commit sexual abuse. Abuse of
children by other children is a specific safeguarding concern in education, and
all staff should be aware of their school or college’s policies and procedures for addressing it.

Neglect: the persistent failure to meet a child's basic physical and/or
psychological needs, likely resulting in serious impairment of the child's health or
development. Neglect can begin during pregnancy, such as from maternal
substance abuse. After birth, it may involve a parent's or carer's failure to provide
adequate food, clothing, and shelter (including exclusion from home or
abandonment), to protect the child from physical and emotional harm or danger,
to ensure adequate supervision (including using inappropriate caregivers), or to
provide access to appropriate medical care or treatment. Neglect can also
involve failing to respond to a child's basic emotional needs.

Specific Safeguarding Issues: There are further specific safeguarding issues that
have become critical in safeguarding in relation to children and young people,
and staff should be aware that behaviours linked to drug taking, alcohol and drug
misuse put young people in danger. Issues can also manifest themselves via child-
on-child abuse which may include bullying, cyberbullying, gender-based
violence/sexual assaults, and youth produced sexual imagery (known more
commonly amongst children and young people as nudes and semi-nudes. Listed
below are some of the issues that staff should be aware of in terms of
safeguarding risk:

• Children involved in court proceedings
• Children absent from education/absent from home or care
• Children with family members in prison
• Child Sexual Exploitation (CSE)
• Child criminal exploitation (CCE), e.g., county lines
• Domestic abuse
• Homelessness
• So called ‘honour based’ violence (HBV)
• Female Genital Mutilation (FGM)
• Forced Marriage
• Being involved in gangs
• Sexual violence and sexual harassment between children in schools and
colleges
• Child-on-child abuse
• Upskirting
• Hate crime
• Mental ill-health
• Private Fostering*
• Radicalisation
• Relationship abuse
• Sharing nudes and semi-nudes**
• Trafficking.

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Children and Young People Absent from Education
In line with Keeping Children Safe in Education (KCSIE) 2025, any learner under 18
who is absent for 10 consecutive college days or who shows a pattern of irregular
attendance (e.g., repeated unexplained absences totalling 10 days within a half-
term) must be reported immediately.
• Teaching and support staff must record all concerns on CPOMS and alert the
Designated Safeguarding Lead (DSL).
• The DSL (or deputy) will assess risk, make contact with the learner and
parent/carer where appropriate, and submit a Children Missing Education (CME)
referral to the Local Authority Welfare/Education Team without delay.

*A ‘Privately Fostered’ child is a child under the age of 16 (18 if disabled) who is
cared for and accommodated by someone other than a parent or close relative
(i.e., step-parents, grandparents, brothers/sisters, or aunts/uncles) for more than
28 days. **‘Making, possessing, and distributing any imagery of someone under
18 which is ‘indecent’ is illegal. This includes imagery of yourself if you are under
18’. (Sharing nudes and semi-nudes: advice for education settings working with
children and young people) (UK Council for Internet Safety)

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Screening and Confiscation

Staff are trained to understand their duty to report all instances of youth-
produced sexual imagery immediately as a safeguarding concern and to avoid
consciously viewing, copying, sharing, or printing the imagery. The seizing and
confiscation of devices must follow appropriate guidance regarding consent
and/or actions by authorized personnel.

In line with the DfE Searching, Screening and Confiscation Advice (2023), staff
have the right to search learners and confiscate prohibited items to maintain a
safe learning environment. Any searches must be conducted lawfully, respectfully,
and proportionately, with another member of staff present where possible.
Confiscated items must be recorded, securely stored, and returned or disposed
of according to guidance. Staff must report any safeguarding concerns identified
during screening to the Designated Safeguarding Lead (DSL) immediately.

Adults: The Department of Health Care Act Statutory Guidance states that
safeguarding duties apply to an adult who:

• has needs for care and support (whether or not the local authority is meeting
any of those needs)

• is experiencing, or at risk of, abuse or neglect

• as a result of those care and support needs is unable to protect themselves from
either the risk of, or the experience of abuse or neglect

The statutory guidance sets out 6 principles which apply to all sectors and settings,
including further education colleges, and should inform how college staff work
with adults:

1. Empowerment.

2. Prevention.

3. Proportionality.

4. Protection.

5. Partnership.

6. Accountability.

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The College and the Governing Body recognises the following summary
statements as definitions of abuse in terms of vulnerable adults:

Physical abuse including assault: hitting, slapping, pushing, misuse of medication,
restraint, or inappropriate physical sanctions.

Domestic violence: including psychological, physical, sexual, financial, emotional
abuse, and so called ‘honour’ based violence.

Sexual abuse: including rape, indecent exposure, sexual harassment,
inappropriate looking or touching, sexual teasing or innuendo, sexual
photography, subjection to pornography or witnessing sexual acts, sexual assault,
and sexual acts to which the adult has not consented or was pressured into
consenting.

Psychological abuse including: emotional abuse, threats of harm or
abandonment, deprivation of contact, humiliation, blaming, controlling,
intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation, and
unreasonable and unjustified withdrawal of services or supportive networks.

Financial or Material abuse including: theft, fraud, internet scamming, coercion
in relation to an adult’s financial affairs or arrangements including in connection
with wills, property, inheritance or financial transactions, and the misuse or
misappropriation of property, possessions, or benefits.
Modern slavery which encompasses: slavery, human trafficking, forced labour
and domestic servitude, and traffickers and slave masters using whatever means
they have at their disposal to coerce, deceive, and force individuals into a life of
abuse, servitude, and inhumane treatment.
Discriminatory abuse including: forms of harassment, slurs or similar treatment
because of race, gender and gender identity, age, disability, sexual orientation,
or religion.

Organisational abuse including: neglect and poor care practice within an
institution or specific care setting such as a hospital or care home for example, or
in relation to care provided in one’s own home. This may range from one-off
incidents to ongoing ill-treatment. It can be through neglect or poor professional
practice as a result of the structure, policies, processes and practices within an
organisation.

Neglect and Acts of Omission including: ignoring medical, emotional, or physical
care needs, failure to provide access to appropriate health, care, and support or
educational services, and the withholding of the necessities of life, such as
medication, adequate nutrition, and heating.
Self-Neglect: This covers a wide range of behaviour neglecting to care for one’s
personal hygiene, health or surroundings and includes behaviour such as
hoarding. Assessments should be made on a case-by-case basis to inform
whether a response is required under safeguarding, which will depend on the
adult’s ability to protect themselves by controlling their own behaviour, and
whether they are unable to do this without external support

The College acknowledges that the types of abuse, neglect, and specific
safeguarding issues outlined in this section reflect statutory safeguarding duties
concerning children and vulnerable adults. However, these examples may not be
comprehensive. The College is dedicated to safeguarding all students and
apprentices in any situation where their welfare and/or safety is at risk.

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2. Roles and Responsibilities

The Link Governor is responsible for liaising with the College Senior
Leadership Team to ensure that:

• The College has procedures and policies which are consistent with the
Local Safeguarding Children Board procedures.

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• The Corporation reviews and agrees the College policy on safeguarding,
including child protection, prevent and online safety each year.
• Termly updates following each Safeguarding Committee meeting
are provided to Corporation, including an overview of how staff have
complied with the policy including, but not limited to, the completion of
staff training.

• Challenging managers on issues relating to safeguarding.
• Overseeing the liaison between agencies such as the Police and Social
Care, as defined by the Local Safeguarding Children’s Partnership, in
connection with allegations against the Principal or the nominated senior
staff member. This will not involve undertaking any form of investigation but
will ensure good communication between the parties and provide
information to assist enquiries.

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Designated and Deputy Safeguarding Leads
Designated safeguarding lead

Responsibility for strategic activity supporting the Link Safeguarding Governor to
achieve the actions set out above, and for directly supporting the Deputy
Designated Safeguarding Lead to achieve the actions set out below, including
monitoring of implementation, supporting development, and implementation of
organisational safeguarding arrangements

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Deputy Designated safeguarding lead

Responsibility for first response to operational safeguarding concerns through a
dedicated team of Welfare Officers.

The Designated and Deputy Safeguarding Leads (DSL and DDSL) will carry out
their roles in accordance with Keeping Children Safe in Education

• Overseeing the referral of cases of suspected abuse or other allegations to
relevant agencies.
• Providing advice and support to other staff on issues relating to child
protection and safeguarding.
• Maintaining a formal record of any child protection referral, allegation,
disclosure, or concern (even where that concern does not lead to an
external referral), including a chronology of actions and interventions.
• Ensuring that relevant and up-to-date safeguarding information is available
for all students, apprentices, parents, carers, employers, and other
stakeholders via the College website.
• Liaising with the relevant Local Authority, Police and Prevent teams along
with other appropriate agencies and professionals.
• Liaising with secondary schools where students are making the transition
into College provision, for appropriate transition information to be shared
and any required support arrangements are established.
• Supporting colleagues to liaise with employers and training organisations
that receive young people from the College on placements, to ensure that
appropriate safeguards are put in place.
• Ongoing development and delivery of mandatory safeguarding training to
include child protection, risks associated with Radicalisation and Extremism,
along with other specific safeguarding issues. This includes guidance on
how to report concerns in line with the Bath College Safeguarding Policy
and Procedures

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Low-Level Concerns and Position of Trust

In line with Keeping Children Safe in Education (KCSIE) 2025, any behaviour by
staff, volunteers, contractors, or visitors that falls short of professional
expectations, even if it does not meet the threshold of a safeguarding
allegation, must be treated as a Low-Level Concern.
All such concerns, particularly where they relate to an individual in a Position of
Trust, must be recorded, reported to the Designated Safeguarding Lead (DSL),
and reviewed using the Low-Level Concerns Flowchart to ensure appropriate
action and oversight.

Bath College recognise the importance of sharing low-level concerns, to create
and embed a culture of openness, trust and transparency in which the college’s
values and expected behaviour set out in the staff code of conduct are lived,
monitored and reinforced constantly by all staff.

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Low-Level Concerns Flowchart

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3. Safeguarding referrals and communication
The policy and procedures are approved by the College Corporation, which has
designated a Link Safeguarding Governor. This governor represents the
Corporation on the College Safeguarding Committee, providing support and
challenge to College management, and delivering termly safeguarding updates
to the Corporation.

These policies and procedures are communicated to all staff through various
channels including staff induction, the staff intranet, safeguarding briefings,
meetings, and a variety of training sessions throughout the year.

The College has a strategic Designated Safeguarding Lead (DSL) responsible for
policy, training, and the strategic management of safeguarding arrangements,
supported by a Deputy DSL who leads a team of Welfare Officers to handle day-
to-day reporting and provide direct safeguarding interventions as needed.

The Curriculum and Quality Committee discuss and monitor safeguarding referrals,
practices, and areas for development, with Safeguarding and Prevent a standing
item on each agenda.

The DSL and Deputy DSL complete the annual Banes Council Safeguarding Audit
and the annual Prevent Duty Risk Assessment and Audit to ensure practices
remain current with legislation, guidelines, and local risk profiles. Appropriate

Identify
Any behaviour inconsistent with the staff code of conduct, even if not a safeguarding allegation, is a
Low-Level Concern.
Record
Complete the Low-Level Concern Form/Log with factual details (date, time, people involved).
Report
Send to the Designated Safeguarding Lead (DSL) or Principal if the DSL is the subject.
DSL Review
DSL assesses context and decides:
• Remains Low-Level Concern → record & monitor
• Escalates to Position of Trust issue or allegation → follow Allegations procedure & inform LADO.
Outcome & Oversight
Maintain secure record, review patterns, and inform senior leadership/governors as required.

action plans are developed, and progress is monitored by the Safeguarding
Committee.

Identification cards with lanyards are provided to staff and students/apprentices.
The mandatory wearing of lanyards is embedded within the staff and student
codes of conduct.

College prospectuses and job advertisements include a clear statement
emphasising the College's commitment to safeguarding, and Safer Recruitment
practices are overseen by the People and Culture management team, which
also delivers Safer Recruitment training to managers.

Safeguarding information, literature, and awareness resources are disseminated
to staff, students/apprentices, and other stakeholders through various means,
including the College website.

Students/apprentices receive education on safeguarding, including online safety
and child-on-child sexual abuse and harassment, through induction and tutorial
activities. They are also informed about the legal implications and risks associated
with sharing inappropriate images via social media and online.

Employers are provided with relevant safeguarding and Prevent duty information
at the point of sign-up, with regular discussions during work-based visits to help
recognise, understand, and report risks. Employers are directed to the College's
safeguarding policies and are expected to comply with these frameworks in
relation to college apprentices, and learners engaging in work based learning
opportunities.

The College Safeguarding Team maintains positive collaborative working
relationships with external organisations, ensuring effective communication and
appropriate information sharing to offer early support and minimize safeguarding
risks to students/apprentices.

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4. Application
All new employees of the College, including apprentices, will undergo an
Enhanced Disclosure via the Disclosure and Barring Service (DBS) and will
complete an annual DBS declaration thereafter. The People and Culture
department will adhere to the Disclosure Code of Practice outlined in the
Recruitment and Selection Policy and Procedures to ensure Safer Recruitment
practices are adhered to.

During the formal induction process, all new staff will complete mandatory
safeguarding and Prevent training to understand their roles and responsibilities

and become familiar with the relevant policies and procedures. This training will
cover extremism, radicalisation, and recognising concerning behaviors and
ideologies, as well as the necessary safeguarding reporting procedures.

Safeguarding will be a regular agenda item in senior and college management
and departmental team meetings to facilitate ongoing dialogue about related
procedures, policies, and practices.

The Principal, Corporation, and all staff working with or on behalf of the College,
including volunteers and external contractors in regular contact with
students/apprentices, will receive information and training appropriate to their
roles. This will help them understand safeguarding issues, outline their
responsibilities, and equip them with the knowledge to report concerns in
accordance with the College Safeguarding Policy. All staff will participate in
annual refresher training appropriate to their roles, informed by updates to the
Keeping Children Safe in Education statutory guidance, and recorded and
monitored through relevant College systems.

The College collaborates with local education providers following Local Authority
guidance on the transfer of Child Protection and Safeguarding records, ensuring
a smooth and safe transition for students/apprentices with safeguarding needs.
This is achieved by following the DfE guidance, and as detailed in the Keeping
Children Safe in Education statutory guidance to ensure the safe and timely
transfer of learner files between institutions.

The College will review and adhere to NSPCC guidelines on the retention and
storage of child protection records. Timeframes are detailed in the Retention of
Records Policy.

The Head of Governance will monitor the training of Governors and the College
Safeguarding Governor, ensuring they receive appropriate safeguarding and
child protection (including online) training. This training, updated annually at a
minimum, will equip them with the knowledge to provide strategic oversight and
assurance that the College’s safeguarding policies and procedures are effective
and support a robust whole-college approach to safeguarding.

When arranging learning in the workplace for young people, the employer is
made fully aware of their duties in terms of safeguarding, and
students/apprentices are given guidance prior to their work placement on
keeping safe and how to access College safeguarding support if required whilst
on placement.

Where school pupils are engaging in college activity, such as taster days,
agreements are in place to report any safeguarding concerns back to their
school in line with their existing safeguarding policies and procedures.

Acceptable Use Policies are in place across the organisation in relation to access
to ICT, whereby internet usage will be proactively monitored to detect any
material promoting terrorism, posing a risk of radicalisation, or posing other
safeguarding risks. Risk categories are flagged in a timely manner to the DSL &
DDSL via an automatically Smoothwall generated report, with appropriate action
taken in line with the Safeguarding Procedures and, where appropriate, the
Tackling Extremism and Radicalisation Policy and Procedures appendix

The Welfare Team will respond to any concerns related to a Support to Study
process as per the College guidance, which provides a framework to assess and
respond to any risks posed by a student or apprentice to their own or others health,
safety, or wellbeing. This includes where a student or apprentice’s health and
wellbeing appears to be deteriorating and negatively impacted by their studies,
where there is a risk of negatively affecting the teaching, learning and/or
experience of others within the College community, or the day-to-day activities
of the College, work placement or apprenticeship employer.

The DSL and DDSL are appropriately trained to respond to reported safeguarding
and Child Protection concerns, and have a working knowledge of appropriate
referral pathways including the Local Authority Social Care Teams, Early Help
Teams, Prevent Teams, and the Channel Panel.

All staff, including Corporation members and volunteers, students/apprentices,
and visitors should display their official College photo ID on the relevant colored
lanyard at all times, in order for students/apprentices and visitors to feel safe and
be able to recognise appropriate professionals that can offer support on behalf
of the College. All staff have a duty to challenge non-compliance in order that
unauthorised people on site can be identified and dealt with accordingly

All students/apprentices who self-declare a criminal conviction or have a positive
disclosure on a DBS check made in preparation for work placement will receive
a support interview to discuss the implications on their future learning. If deemed
necessary, in relation to this type of disclosure or any other type of risk posed by a
student/apprentice, a risk assessment panel is convened to make
recommendations regarding their admission to/continuation with the College in
any learning context, or suitability for work placement. Additional risk assessment
meetings are convened involving Health and Safety, Security, the DSL and deputy,
and other relevant staff as required, if a serious safeguarding issue or concern
arises.

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5. Policy Review and Compliance
This policy and its procedures are reviewed annually by the Designated
Safeguarding Lead (DSL) in accordance with the Keeping Children Safe in
Education statutory guidance. The policy is then approved by the College
Safeguarding Committee and the College Corporation.

An annual audit of safeguarding provision, including the Local Authority
Safeguarding Audit, is conducted. Additionally, the Government's Prevent Duty
self-assessment tool for further education is incorporated into practice for
strategic monitoring.

Termly reports are submitted to the Curriculum and Quality Committee, which
includes the Senior Leadership Team (SLT) and the Link Safeguarding Governor.
These reports review, analyse, and challenge safeguarding data and practices
to ensure the College maintains a commitment to safeguarding, remains current
with best practices, and complies with all requirements.

The College has an established process for auditing the Single Central Record,
ensuring all required Disclosure and Barring Service (DBS) checks are completed
and verified.

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6. Prevent Strategy
Introduction and Context
Bath College is committed to providing a safe learning and working environments
for all stakeholders. Section 26 of the Counterterrorism and Security Act 2015
places a duty on certain bodies (including educational institutions) in the exercise
of their functions to have ‘due regard to the need to prevent people from being
drawn into terrorism’. This duty is known as the Prevent duty.

The Prevent Duty Guidance, published by the Government , is part of a
government counterterrorism strategy to develop a robust counter terrorism
programme – CONTEST.

CONTEST has four elements - Pursue, Protect, Prepare and Prevent. Prevent aims
to reduce the threat to the UK from terrorists by stopping people becoming
terrorists or supporting terrorism.1

The strategy has three core strategic objectives:

• Tackle the ideological causes of terrorism
• Intervene early to support people susceptible to radicalisation.
• Enable people who have already engaged in terrorism to disengage and
rehabilitate.
The delivery model (below) sets out how we tackle the ideological causes that
lead to radicalisation, intervene early to support those who are susceptible to
radicalisation, and rehabilitate those who have already engaged with terrorism.

Terrorist groups often draw on extremist ideology, developed by extremist
organisations. Some people who join terrorist groups have previously been
members of extremist organisations and have been radicalised by them.
However, many different factors make someone vulnerable and susceptible to
radicalisation. These are not limited to but can include: identity, personal crisis,
loss/bereavement, drug/alcohol abuse, isolation, mental health, internet,
grievances, ideology, peer pressure, islamophobia, media, hate crime and a lack
of theological knowledge

A system of threat level has been created which represents the likelihood of an
attack in the near future. The five levels are:

• Critical: an attack is expected imminently.
• Severe: an attack is highly likely.
• Substantial: an attack is a strong possibility.
• Moderate: an attack is possible but not likely.
• Low: an attack is unlikely.
Further Education colleges are major education and training providers for the 16
to 25-year age group, particularly young people from ethnically diverse, and
socially and economically disadvantaged areas. Education, like other key sectors,
has a responsibility to promote values of openness, tolerance and facilitating free
debate which is central to being a British citizen. Colleges have a part to play in
fostering shared values and promoting cohesion. Colleges should focus on the
risks of non-violent ideologies which have been known to link directly to terrorism
alongside violent extremism, which represents the greatest threat at national level,
while recognising that other forms of violence and extremism can and do
manifest themselves within colleges and other training settings.

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This strategy has the following objectives:

1. To promote and reinforce shared values; to create space for free and
open debate; and to listen and support the student voice.
2. To break down segregation among different student communities
including by supporting inter-faith and inter-cultural dialogue and
understanding, and to engage all students in playing a full and active
role in wider engagement in society.
3. To ensure student safety both physically and online and that the College
is free from bullying, harassment, and discrimination.
4. To provide support for students who may be at risk or posing an active
threat and appropriate sources of advice and guidance.
5. To ensure that students and staff are aware of their roles and
responsibilities in preventing violent extremism, recognising current
practice which contributes to the Prevent agenda.
6. Identify areas for improvement through risk assessment and develop a
coordinated action plan.
To achieve these objectives, the strategy will concentrate on four areas:

Leadership and Values
To provide an ethos which upholds core values of shared responsibility and
wellbeing for all students, staff and visitors and promotes respect, equality and
diversity and understanding.

This will be achieved through:

• Promoting core values of respect, equality and diversity, democratic
society, learner voice and participation and referencing these as
Fundamental British Values.
• Building staff and student understanding of the issues and confidence
to deal with them through regular training sessions.
• Convene a ‘Prevent Board’ to oversee progress on measures to be
undertaken by college that are identified in the action plan.
• Deepening engagement with local communities to include faith-based
communities.
• Actively working with local schools, local authorities, police, and other
agencies.
Teaching and Learning
To provide a curriculum which promotes knowledge, skills and understanding to
build the resilience of students, by undermining extremist ideology and its causes
through supporting the student voice.

This will be achieved through:

• Embedding equality, diversity and inclusion, wellbeing, and community
cohesion through regular tutorials, personal development curriculum
delivery, student events and social media campaigns.
• Promoting wider skill development such as social and emotional aspects
of learning.
• A curriculum adapted to recognise local needs, challenge extremist
narratives, extremist ideologies and its causes and promote universal
rights.
• Encouraging active citizenship/participation and student voice.
• Using the external speakers risk assessment process to evaluate the
impact of any external speakers invited into college.
• Ensuring online policies are up to date with regularly reviewed filtering
software.
• Provide regular updates and training on risk assessment models.
Student Support

To ensure that staff are confident to take preventative and responsive steps
working with partner professionals, families, and communities.

This will be achieved through:

• Establishing strong and effective student support services.
• Building a culture of support and intervention within the college
community across all departments promoting Prevent as a fundamental
part of Safeguarding.
• Listening to what is happening in the College and the community.
• Implementing anti-bullying strategies and challenging discriminatory
behaviour.
• Zero-tolerance approach to bullying, and rejects excuses such as
"banter," "just having a laugh," or "boys being boys," as this can lead to
a culture of unacceptable behaviours and an unsafe environment for
children
• Promoting strategies to ensure online safety for the whole college
community utilising internet filtering software and its follow up procedure
when an alert is triggered, tracking and monitoring.
• Helping students and staff know how to access support in college and
or through community partners.
• Supporting at risk students through safeguarding and crime prevention
processes.
• Providing prayer facilities and quiet spaces.
• Focussing on narrowing the attainment gap for all students.
Managing Risks and Responding to Events
To ensure that the College monitors risks and is ready to deal appropriately with
issues which arise.

It will do this through:

• Understanding the nature of the threat from violent extremism and how
this may impact directly or indirectly on the College.
• Understanding and managing potential risks within the College and
from external influences, to include an awareness of emerging non-
violent extremist groups that have been known to be linked to terrorist
groups.
• Responding appropriately to events in local, national, or international
news that may impact on students and communities.
• Ensuring measures are in place to minimise the potential for acts of
violent extremist within the College.
• Ensuring plans are in place to respond appropriately to a threat or
incident within the College.
• Developing effective ICT security, and responsible user policies and
internet filtering software.
• Providing as secure and safe an estate as possible with effective lock
down procedures in the event of a terrorist attack.
These four areas are addressed and monitored via the ‘Prevent Duty Self -
Assessment Tool for FE Providers’ and subsequent Risk Assessment & Action Plan.
These includes judgements and actions in the following nine areas:

1. Leadership
2. Partnership
3. Training
4. Online Safety
5. Welfare and pastoral support
6. Speakers and events
7. Site security
8. Fundamental British values
9. Learner engagement
Progress on measures that are identified in the action plan to be undertaken by
the college, is overseen and scrutinised by the ‘Prevent Board’.

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7. Associated information and guidance

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