Safeguarding Policy

At SSS Learning Ltd we are committed to taking all appropriate measures to safeguard all employees and any personnel of external agencies / organisations contracted to provide our services. This includes safeguarding students on work experience whilst on placement with the company.

The term 'safeguarding' applies to a wide remit of protective measures. For the purposes of this policy this includes:

• Our company ethos, including zero tolerance standards;
• Reporting arrangements;
• Safer recruitment & Induction;
• Training;
• Health & Safety;
• ICT Acceptable Use & Online safety.

Our ethos

As a company our overall aim is to provide a safe, inclusive environment where all can work safely. This includes those working at our headquarters and those working remotely in premises offsite. We are committed to ensuring the personal safety of all employees whilst carrying out their duties. This requires all staff to strictly adhere to and work within the working conditions specified in their contract of employment, our code of conduct and also applies to the measures set out in our ICT Acceptable Use Agreement (see Appendix 1).

Zero tolerance

We have a zero tolerance for abusive behaviours such as:

• Bullying- including cyberbullying;
• Harassment and discrimination which includes abuse related to protected characteristics e.g. race, gender, age, disability, sexual orientation or religion;
• Physical / verbal abuse;
• Psychological or emotional abuse – such as threats of harm, humiliation or intimidation;
• Coercion;
• Theft;
• Fraud;
• Internet scamming.

All allegations of such behaviour will be taken seriously and staff disciplinary procedures will be taken where deemed necessary, directed by a senior leadership panel. As such we expect all staff to respect their colleagues and conduct themselves in a caring and professional manner at all times.

Reporting arrangements

Our Designated Safeguarding Lead is Sam Preston, our Safeguarding Director, and Deputy Named Person is Jonathan Case. They will ensure active compliance with this policy by all staff. To accommodate both centrally based staff and those who work remotely, safeguarding concerns may be reported to any company Director. All reported concerns will be then discussed with our DSL and / or her deputy. Our DSL, or deputy in her absence, is responsible for providing the Directors with information pertaining to safeguarding. Such notifications will be addressed as an agenda item at Board meetings.

All safeguarding concerns will be taken seriously and acted upon appropriately in a timely manner. Where deemed necessary, the company will seek the assistance of external support agencies and, where the seriousness of an incident warrants, reports will be made to external services e.g. the police.

Prevent Duty

Under the Counter-terrorism and Security Act 2015, we have a corporate responsibility to have 'due regard to the need to prevent people from being drawn into terrorism'. Any concerns within this remit will be followed up in line with locality safeguarding procedures set out by our area safeguarding tri-partnership. Should any critical incident affect headquarters, e.g. where a suspected / actual threat may place those on site in danger, the company will reserve the right to employ lockdown or evacuation procedures as appropriate. In line with the National Terrorism Strategy, we expect staff to be vigilant and follow the Run, Hide Tell direction outlined in the guidance.

Recruitment & Induction

We will ensure highest standards of safe recruitment, supervision and management of staff particularly, but not exclusively, those who have access to our Meta system, CRM Tools, our cloud based server, personal data records, financial and confidential information.

To meet safer recruitment standards we will always:

• Check the applicant is who they claim to be - e.g. having sight documentation such as a birth certificate, passport and/or driving licence;
• Check the applicant has the right to work in the UK;
• Check the applicant's academic qualifications are genuine;
• Check the applicant's previous employment history has been examined and any gaps satisfactorily accounted for;
• Check the applicant is registered with the relevant professional body and there are no active restrictions against them (where applicable).
• Check that satisfactory professional and character references have been received and verified for the applicant. Verification of references will always be conducted prior to commencement in post.

Should a post require the submission of a check to the Disclosure and Barring Service (DBS), the prospective employee will not take up post until the disclosed information is received by the company. In such cases, all offers of employment will be made subject to a satisfactory DBS check.

In line with our Equality, Diversity and Inclusion policy, our procedures will safeguard recruitment methods which enable prospective applicants to include those with protected characteristics.

Training

We will support all new and existing staff to understand their roles and responsibilities for safeguarding, through appropriate induction, training, information sharing and guidance on what to do if there are concerns.

This also applies to any agency workers working on our behalf.

Health & Safety

The Directors of SSS Learning Ltd recognise the company has a corporate responsibility and overall accountability for the health and safety of staff. Health and Safety is a key element of our safeguarding remit to ensure the protection of staff, agency staff, students on work placement and visitors to our corporate headquarters.

We recognise that developing and creating a positive health and safety culture will ensure our legal duties are met and enable staff to know how to work safely without risk to their or others health. This means ensuring risks are managed effectively on site and that risk is managed responsibly and proportionately.

Under the Health and Safety at Work Act (1974), the company is required to provide information, instruction, training and supervision to ensure, so far as is reasonably practicable, the health and safety at work of our employees. This is further expanded by the Management of Health and Safety at Work Regulations 1999, which identifies situations where health and safety training is particularly important, e.g. when people start work, are exposed to new or increased risks or where existing skills may need updating.

To meet these duties the Directors will be responsible for:

• Ensuring effective measures are in place at our site premises at all times. This will be carried out in association with the landlord;
• Ensuring effective measures are in place where employees work offsite e.g. discussion and assessment of home working environments;
• Ensuring staff receive health & safety training relevant to their role;
• Communicate health & safety matters effectively with staff;
• Monitoring arrangements for managing health & safety risks to ensure they are effective, including those put in place by the landlord;
• Ensuring any control measures deemed necessary have been implemented and that they remain appropriate and effective;
• Ensuring staff, agency staff and students on placement adhere to health & safety requirements on-site at headquarters;
• Monitoring accident and incident reporting;
• Ensuring that all offsite working has been risk assessed and any appropriate health & safety measures identified are complied with;
• Providing clear information to visitors and contractors;
• Ensuring staff have the appropriate training and competencies to deal with risks in their areas of responsibility, including where to access support and advice;
• Consulting and working with recognised Trade Union safety representatives / employee representatives and safety committees where appropriate.

All staff are required to ensure they are familiar with and adhere to all specified health & safety requirements. They are expected to:

• Take reasonable care for their own health & safety;
• Consider the care of others who may be affected by what they do or fail to do;
• Ensure health & safety information is shared when arranging visitors to headquarters;
• Raise health & safety concerns to a Director / Manager in a timely way, undertaking any immediate action to temporarily minimise risks.

The company will meet the statutory requirements for accident reporting, detailed in the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). This includes reporting and keeping records of:

• Work-related accidents which cause deaths;
• Work-related accidents which cause certain serious injuries, known as reportable injuries;
• Certain 'dangerous occurrences', that is incidents with the potential to cause harm.

ICT Acceptable Use & Online Safety

Given that the mainstay of our business and communication systems involve the use of technology, the company undertakes a range of safeguarding measures to protect staff, the company and our customer base. Whilst we actively encourage staff to take full advantage of the benefits our ICT equipment and communications systems offer, we also expect staff to do this responsibly within the terms and conditions specified in our ICT Acceptable Use Agreement. All staff are required to sign and comply with this agreement as a mandatory condition of employment. This will also be a requirement for agency staff and or students on work placement where deemed appropriate.

This policy should be read in conjunction with our Equality, Diversity & Inclusion policy.

Appendix 1 – SSS Learning ICT Acceptable Use Agreement

Policy and Guidance on Staff use of ICT and Communications Systems

Policy Statement

The Directors of SSS Learning Ltd recognise the use of its ICT and communications facilities as an important resource for business use, professional development and as an essential aid to business efficiency. The term 'communication facilities' includes access to our Meta system, CRM Tools and our cloud based server. The company actively encourages staff to take full advantage of the potential for ICT and communications systems to enhance development in all areas of core business, professional development and administration. It is also recognised that along with these benefits there are also responsibilities, especially for ensuring that staff are protected from contact with inappropriate material.

In addition to their normal access to ICT and communications systems for work-related purposes, SSS Learning Ltd permits staff limited reasonable personal use of ICT equipment and e-mail and internet facilities during their own time subject to such use:

1. not depriving other colleagues of the use of the equipment and / or
2. not interfering with the proper performance of the staff member's duties

Whilst our ICT systems may be used for both work-related and for sole personal use, we expect use of this equipment for any purpose to be appropriate, courteous and consistent with the expectations of the Directors at all times.

This document is issued to all staff before they are provided with laptops, tablets, cameras, USB / portable hard drive devices, mobile phones and passwords giving access to the ICT network.

Policy coverage

This agreement covers the use by staff of any issued ICT and communications equipment, examples of which include:

• Laptops, tablets and personal computers;
• ICT network facilities;
• Personal digital organisers and handheld devices;
• Mobile phones and phone / computing hybrid devices;
• USB keys and other physical and on-line storage devices;
• Image data capture and storage devices including cameras, camera phones and video equipment.

This list is not exhaustive.

The policy covers the use of all ICT and communications equipment provided for work purposes and equipment which is on loan to staff for their sole personal use.

The use of SSS Learning Ltd ICT and Communications Facilities

Use of ICT Equipment

Staff who use our ICT and communications systems:

• Must use it responsibly;
• Must keep it safe;
• Must not share and treat as confidential any passwords provided to allow access to ICT equipment and / or beyond firewall protection boundaries;
• Must report any known breach of password confidentiality to a Director or Manager as soon as possible;
• Must report known breaches of this policy, including any inappropriate images or other material which may be discovered on our ICT systems;
• Must report any vulnerabilities affecting safeguarding in our ICT and communications systems;
• Should understand and recognise the risk posed by the use of technology, including the internet, in radicalisation and extremism. Staff should understand such risks and know how to keep themselves safe;
• Must not install software on equipment issued, including freeware and shareware, unless authorised to do so by a Director or manager;
• Must adhere to network monitoring and not attempt to bypass our restrictions on internet access;
• Must comply with any ICT security procedures governing the use of systems, including anti-virus measures;
• Must ensure that it is used in compliance with this agreement.

Any equipment provided to a member of staff is provided for their sole personal use. Use of the equipment by family or friends is not permitted and any misuse of the equipment by unauthorised users will be the responsibility of the staff member.

Whilst it is not possible to cover all eventualities, the following information is published to guide staff on the expectations of the company Directors. Any breaches of this policy or operation of issued equipment outside statutory legal compliance may be grounds for disciplinary action being taken.

E-mail and Internet and Communications systems usage

The following use of our ICT system is strictly prohibited and may amount to gross misconduct. (This could result in dismissal):

1. To make, to gain access to, or for the publication and distribution of inappropriate sexual material, including text and / or images, or other material that would tend to deprave or corrupt those likely to read or see it;
2. To make, to gain access to, and / or for the publication and distribution of material promoting homophobia or racial or religious hatred;
3. For the purpose of bullying or harassment, or in connection with discrimination or denigration on the grounds of gender, race, religious, disability, age or sexual orientation;
4. For the publication and / or distribution of libellous statements or material which defames or degrades others;
5. For the publication of material that defames, denigrates or brings disrepute to the organisation;
6. For the publication and distribution of personal data without authorisation, consent or justification;
7. Where the content of the e-mail correspondence is unlawful or in pursuance of an unlawful activity, including unlawful discrimination;
8. To participate in on-line gambling;
9. Where the use infringes copyright law;
10. To gain unauthorised access to internal or external computer systems (commonly known as hacking);
11. To create or deliberately distribute ICT or communications systems 'malware', including viruses, worms, etc;
12. To record or monitor telephone or e-mail communications without the express approval of management / governance. In no case will such recording or monitoring be permitted unless it has been established for that such action is in full compliance with all relevant legislation and regulations. (Regulation of Investigatory Powers Act 2000 – 'Ancillary to their provision of ICT facilities the management / governance asserts the employer's right to monitor and inspect the use by staff of any computer (including e-mails) or telephonic communications systems and will do so where there are grounds for suspecting that such facilities are being, or may have been, misused.')
13. To enable or assist others to breach governance expectations as set out in this policy.
14. Additionally, the following uses of our ICT facilities are not permitted and could lead to disciplinary action being taken:
    • For participation in 'chain' e-mail correspondence (including forwarding hoax virus warnings);
    • In pursuance of personal business or financial interests, or political activities (excluding the legitimate activities of recognised trade unions);
    • To access ICT facilities by using another person's password, or to post anonymous messages or forge e-mail messages using another person's identity.

Note: The above restrictions apply to the use of phones, e-mails, text messaging, internet chat rooms, blogs, and personal websites (including personal entries on social networks e.g. MySpace, Facebook, Twitter, Instagram, tiktok etc).