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Policies

Safeguarding

Company Statement
Virtual Internship Partners Ltd (VI) makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe

VI comes into contact with children and / or vulnerable adults in the context of its programs it operates for high school / K-12 students, special educational needs and disabilities students and other similar
target audiences.
This policy seeks to ensure that VI undertakes its responsibilities with regard to protection of children and / or vulnerable adults and will respond to concerns appropriately. The policy establishes a framework to support paid and unpaid staff in their practices and clarifies VI’s expectations in this respect.

Legislation

The principal pieces of legislation governing this policy are:

  • The Care Act 2016
  • Working together to Safeguard Children 2015
  • The Protection of Freedoms Act 2012
  • Safeguarding Vulnerable Groups Act 2006
  • The Children Act 2004
  • The Adoption and Children Act 2002:
  • Care Standards Act 2000
  • Human Rights Act 1998
  • Public Interest Disclosure Act 1998
  • The Police Act – CRB 1997
  • The Children Act 1989
  • Mental Health Act 1983
  • NHS and Community Care Act 1990
  • Rehabilitation of Offenders Act 1974

Definition
Safeguarding is about embedding practices throughout our organisation to ensure the protection of children and / or vulnerable adults wherever possible. In contrast, child and adult protection is about responding to circumstances that arise. For matters related to child protection, please refer to our Child Protection Policy.

Definition of Abuse
Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

Abuse can take a number of forms, including the following:

  • Physical abuse
  • Sexual abuse
  • Psychological or Emotional abuse
  • Neglect or Omission to act
  • Financial or material abuse
  • Child Sexual Exploitation
  • Modern Slavery
  • Self Neglect
  • Domestic Abuse
  • Institutional Abuse
  • Discriminatory Abuse
  • Harassment
  • Radicalisation

 

Definition of a child
A child is under the age of 18 (as defined in the United Nations convention on the Rights of a Child). Definition of a vulnerable adult A vulnerable adult is a person aged 18 years or over who may be unable to take care of themselves or protect themselves from harm or from being exploited.
This may include a person who: is elderly and frail; has a mental illness including dementia; has a physical or sensory disability; has a learning disability; has a severe physical illness; is a substance misuser; is homeless.

Scope of Application & Responsibilities
This policy applies to all persons working for VI or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
VI expects all staff (paid or unpaid) to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The Board of Directors of VI is responsible for:

  • Ensuring that the policy is in place and appropriate; and
  • Allocating sufficient resources (time and money) to ensure that this policy can be effectively implemented.

The President of VI will be responsible for ensuring that:

  • Ensuring that the policy is accessible and implemented; and
  • Liaising with and monitoring the Designated Safeguarding Lead’s (DSL) work.

The DSL is: Mrs. Gemma Dunne. The DSL is responsible for:

  • Ensuring that the policy is monitored and reviewed;
  • Promoting the welfare of children and vulnerable adults;
  • Ensuring staff (paid and unpaid) have access to appropriate training/information;
  • Receiving staff concerns about safeguarding and respond to all seriously, swiftly and appropriately;
  • Keeping up to date with local arrangements for safeguarding and DBS;
  • Developing and maintaining effective links with relevant agencies; and
  • Taking forward concerns about responses

Implementation
The scope of this policy is broad ranging and in practice, it will be implemented via a range of policies and procedures within the organisation. These include our:

  • Whistleblowing policy;
  • Equality & Diversity policy;
  • Child Protection policy;
  • Digital Harassment policy;
  • Anti-Modern Slavery policy;
  • PSEAH policy;
  • Privacy policy;
  • Staff induction and training procedures.

Safe recruitment
VI aims to recruit and retain individuals who are committed to the safeguard of children and vulnerable adults. To ensure a safe recruitment process, VI will ensure a robust screening and interview process for any position which may involve contact or working with children and vulnerable adults. This may include the following actions:

  • Providing the following safeguarding statement in recruitment adverts or application details –‘recruitment is done in line with safe recruitment practices.’
  • Job or role descriptions for all roles involving contact with children and / or vulnerable adults will contain reference to safeguarding responsibilities.
  • There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding
  • For staff assigned to, or individuals applying for, a role involving work with children or vulnerable adults, require the provision of (i) a criminal record check from the country where they permanently reside and (ii) verbal referee checks;

Criminal Record Check (CRC) Gap Management
In order to avoid CRC gaps, the organisation will (insert methods)

  • Maintain a list of roles across its organisation which involve contact with children or vulnerable adults;
  • Commit resources to providing DBS records check on staff (paid or unpaid) whose roles involve contact with children and /or vulnerable adults.
  • Recheck the CRC records in place for holders of identified roles every 3 years.

Existing staff
In addition to checks on recruitment for roles involving contact with children or vulnerable adults, VI will require existing staff (paid or unpaid) who transfer from a role which does not require a CRC check to one which involves contact with children / vulnerable adults to be subject to a CRC.

Program contracting
For any VI program involving children or vulnerable adults:

  • There will be systematic checking of safeguarding arrangements of partner organisations
  • Safeguarding will be a fixed agenda item on any partnership reporting meetings
  • Contracts and memorandums of understanding for partnerships will include clear minimum requirements, arrangements for safeguarding and non compliance procedures.

Communications, training and support for staff & participants
VI shall commit resources for induction, training of staff (paid and unpaid), effective communications and support mechanisms in relation to Safeguarding.

Induction
Our induction for new staff will include”

  • Discussion of the Safeguarding Policy (and confirmation of understanding)
  • Discussion of other relevant policies
  • Ensure familiarity with reporting processes, the roles of line manager and Designated Safeguarding Lead (and who acts in their absence)
  • Initial training on safeguarding

Training
All staff who, through their role, are in contact with children and /or vulnerable adults will have access to safeguarding training at an appropriate level. Training will be completed annually.
This will include CPD accredited courses delivered through The Virtual College:

  • All delivery staff, administrative support and management will complete the Level 2 Safeguarding Everyone;
  • All hiring managers will also complete the Safer Recruitment course;
  • Management and DSL to complete Level 3 Safeguarding Everyone course which focuses on reporting and escalation to local authorities; and Furthermore, supplementary internal training will be provided to reinforce the implementation of this Policy, the reporting structures and to clarify learning.

Communications and discussion of safeguarding issues
Commitment to the following communication methods will ensure effective communication of safeguarding issues and practice:

  • Team meetings
  • Senior management meetings
  • Board meetings
  • One to one meetings (formal or informal).

Support
We recognise that involvement in situations where there is risk or actual harm can be stressful for staff concerned. The mechanisms in place to support VI staff include:

  • Debriefing support staff
  • Seeking further support as appropriate
  • Contacting staff who have initiated protection concerns will be contacted by their line manager within 1 week.

Participants
VI will make participants enrolled in its programs aware of this Safeguarding Policy, and other relevant VI policies, through the following means:

  • Communicating all applicable VI policies to participants who are enrolled in our programs.
  • Ensuring participants understand they may reach out to their Intern Experience Manager for all matters related to VI policies.
  • Publishing VI policies on our website.

Professional Boundaries

Professional boundaries are what define the limits of a relationship between a support worker and a client. They are a set of standards we agree to uphold that allows this necessary and often close relationship to exist while ensuring the correct detachment is kept in place.
VI expects staff to protect the professional integrity of themselves and the organisation.
The following professional boundaries must be adhered to:

  • VI staff are not allowed to give to or receive gifts from participants or business partners. However, gifts may be provided by VI in the context of planned activities;
  • VPersonal relationships between a member of staff and a participant who is a current service user is prohibited. This includes relationships through social networks such as Facebook, Instagram or Twitter.
  • It is prohibited to enter into a personal relationship with a participant who has been a service user over the past 12 months
  • VI staff shall remain polite and respectful at all times. Abusive or inappropriate language or behaviour is strictly forbidden.

The following policies also contain guidance on staff (paid or unpaid) conduct:

  • VI Anti-bribery Policy;
  • VI Equality & Diversity Policy;
  • VI Digital Harassment Policy;
  • VI Privacy Policy.

A breach of professional boundaries and/or policies by VI staff can result in disciplinary procedures.

Reporting
When alleged incidents are reported, VI will work with the individual to track incident management.
VI expects two kinds of incident reporting:

  • Mandatory and immediate (within 24 hours of becoming aware of an alleged incident) reporting by all staff and VI partners of any alleged incident of discrimination.
  • Mandatory reporting (within two working days) by all staff and VI partners of any alleged non-compliance with this Policy.

All participants, VI staff and partners must report any alleged or suspected safeguarding concerns or non compliance with this policy committed by anyone in connection with VI’s business and programs. Reporting must be made in accordance with the following procedure:
For Participants

  • VI can take corrective action only when it becomes aware of problems. Therefore, VI encourages any VI participant who has any safeguarding concern to come forward promptly with their inquiries, reports, or complaints and to seek assistance within VI. If you are a participant on one of VI’s programs and at any time during your program, you have safeguarding concerns, then you should follow the following procedure.
  • All safeguarding concerns will be dealt with seriously and promptly. Participants who have any safeguarding concern must not hesitate in using this procedure nor fear victimization.
  • VI staff will provide, in confidence, advice and assistance to participants who communicate safeguarding concerns and assist in the resolution of any problems. If you are in any doubt as to whether an incident or series of incidents which have occurred raise safeguarding concerns, then in the first instance you should approach your Intern Experience Manager on an informal confidential basis. They will be able to advise you as to whether the complaint necessitates further action, in which case the matter will be dealt with formally/informally as appropriate.
  • You should report all safeguarding concerns to your Intern Experience Manager, who will take appropriate action to resolve the issue. The means of resolving the issue will differ depending on the circumstances, but VI will consult you during each step of the process to ensure you are aware of the actions we are taking. These may include:
    • Seeking medical or psychological attention for the vulnerable person if required;
    • Discussing with the parents of the child or with the vulnerable adult;
    • Obtaining permission to referrals if safe and appropriate;
    • Contacting the help desk of local authorities and reporting the safeguarding incidents in accordance with procedures in place;
    • Ensuring that feedback from local authorities is received, recorded and implemented.
  • If your Intern Experience Manager is involved in any way with the instances or events which gave rise to the safeguarding concerns, and it would be inappropriate to report to them, you should report the issue to any other VI staff member with whom you have contact or to VI’s in-house legal counsel ([email protected]).

A breach of professional boundaries and/or policies by VI staff can result in disciplinary procedures.
For VI Staff Members

  • If you are a VI staff member and you believe you may have witnessed a safeguarding incident in the context of a VI program, or receive a report from a program participant in accordance with this Policy, you should resolve the issue appropriately, taking particular note of confidentiality concerns. You should follow internal company policies and, within 24 hours of the occurrence of any such event, inform your line superior or the company’s in-house legal counsel ([email protected])

For Third Parties

  • If you are an employee of a host company or an independent contractor, consultant, volunteer or vendor and you witness or think you may have been subject to, or witnessed, a safeguarding incident in the context of a VI program, you should report the issue to your primary point of contact at VI who will work with you to resolve the issue appropriately.

Information and Confidentiality
Information will be gathered, recorded and stored in accordance with VI’s Privacy Policy.
Instances of safeguarding raised under this Policy will be treated confidentially and in the best interest of the victim. However, when an incident is identified it may be necessary for those managing the incident to reveal its substance to people such as other personnel, partners and external persons involved in the investigation process or law enforcement agencies.
All staff must be aware that they have a professional duty to share information with other agencies in order to safeguard children and vulnerable adults. The public interest in safeguarding children and vulnerable adults may override confidentiality interests. However, information will be shared on a need to know basis only, as judged by the Designated Safeguarding Lead. All staff must be aware that they cannot promise service users or their families/ carers that they will keep secrets.
Where there is a reasonable belief that a criminal offence has occurred, the matter will be reported to the appropriate law enforcement agency while taking into account risks to those who have been affected. When a referral is made to law enforcement, any action by VI will be in consultation with its concerned partner and be guided by appropriate law enforcement agencies. Any decision not to refer to law enforcement will be documented in order to record the reasons for the decision.
VI will take all reasonable precautions to store any records or files relating to matters of safeguarding and to permit access by authorised persons only.
Unauthorised disclosure of information relating to a safeguarding incident will be taken seriously and may result in disciplinary action, which may include dismissal.

Monitoring, Compliance and Review
VI will monitor compliance with this Policy through a range of approaches including performance assessments, reviews and due diligence. VI university partners and host companies are expected to put in place appropriate risk-based measures to ensure they comply with this policy. Non-compliance with requirements may lead to VI suspending or terminating an agreement with a university partner or host company.
This policy will be reviewed once a year by VI’s DSL and President to ensure that it remains up to date and reflects VI’s needs and practices. The policy may also be reviewed if legislation changes or if monitoring information suggests that policy or practices should be altered

Supporting and Related Documentation

  • VI Anti-Digital Harassment Policy;
  • VI Policy on the Prevention of Sexual Exploitation, Abuse and Harassment;
  • VI Child Protection Policy
  • VI Risk Management Policy
  • VI Anti-Bribery Policy
  • VI Anti-Modern Slavery Policy
  • VI Equality and Diversity Policy
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