Safeguarding policy

The purpose of this policy is to ensure that the procedures in relation to the wellbeing, safety and welfare of all students are understood and always promoted throughout the University.  

The University, as a Higher Education Institution, does not typically deliver its provision to persons under the age of 18 years and cannot act in ‘loco parentis.’  Responsibility for students under the age of 18 years will continue to rest with parents or guardians.  

The circumstances in which the University interacts with under 18-year-old students will generally fall into two broad categories: 

1. Under 18 years enrolled on a programme of study at the University. 
2. Under 18 years who engage with the University in a non-teaching / academic capacity. 

This policy will clearly outline the University’s safeguarding obligations to all students and how we will work with the individuals, parents, carers, and applicable agencies to deliver its safeguarding responsibilities and to promote the welfare of all. 

Although predominately an adult environment, the University and university staff engage persons under the age of 18 years and adults at risk of harm across a range of settings. This policy applies to all members of the University community including: 

• staff employed directly by the University. 
• individuals holding honorary and / or secondment contracts. 
• individuals undertaking work experience or placements. 
• students. 
• contractors. 
• students studying an apprenticeship with Manchester Met. 
• self-employed undertaking work on behalf of the University. 
• volunteers working with or on behalf of the University. 
• those engaged on behalf of the University in widening participation activities. 

We expect that this policy takes primacy over other agency policies when work is being delivered on university premises and / or on our behalf. 

The Board of Governors has overall responsibility for ensuring that institutional safeguarding policies and procedures comply with the law and all relevant national guidance and are effective.  

The University Executive Group (UEG), through the Professional Services Leadership Team (PSLT) and the Safeguarding and Prevent Strategy Group (SPSG) oversees the implementation of safeguarding policies and procedures, and any adjustments that are required arising from changes to the law and/or national guidance. 

The Director of Student Services is the Safeguarding Lead Officer (SLO) for the University and works closely with the Academic Registrar, who is the designated PSLT safeguarding lead, UEG and the Board of Governors (where required). 

The UEG and the Board of Governors receive an annual report on Safeguarding and Prevent. In addition, members of UEG and the Board of Governors receive regular appropriate briefing and training where required. 

It is the responsibility of every member of staff and volunteer who works with children and adults at risk of harm to familiarise themselves with this policy and accompanying guidance documentation; and to work in a way that safeguards the welfare of all students, staff, and visitors. 

Safeguarding Lead Officer (SLO) 

The Director of Student Services is the SLO. The SLO is responsible for: 

• Promoting, implementing, monitoring, and reviewing this policy in accordance with legislation and guidance. 
• Presenting updates to the policy for approval to the relevant committees. 
• Contributing to the annual Safeguarding and Prevent report for UEG and the Board of Governors. 
• Chairing the University’s Safeguarding and Prevent Operations Group. 
• Acting as the main contact within the University for the safeguarding of children and vulnerable adults. 
• Overseeing a network of Local Safeguarding and Prevent Contacts who will form the University’s Safeguarding and Prevent Operations Group. 
• Overseeing the training of Local Safeguarding and Prevent Contacts. 
• Acting as a senior corporate point of contact for all staff to discuss any safeguarding concern. 
• Ensuring adequate and appropriate SLO cover arrangements in response to any closures, out of hours and holiday periods. 
• Representing the University (when needed) at multi-agency safeguarding meetings (including child protection conferences) or ensuring appropriate representation. 
• Liaising with the Academic Registrar to inform them of any safeguarding and prevent issues, especially ongoing enquiries under section 47 of the Children Act 1989 and police investigations. 
• Providing university members with information, advice, and training on the safeguarding of children and vulnerable adults. 
• Ensuring this policy is easily accessible to staff and students. 
• Keeping up to date with current policy and legislation and updating the University accordingly. 
• Establishing and maintaining contacts with internal and external key stakeholders; including the police, LADO, local authority. 

The SLO will undergo appropriate and specific training to provide them with the knowledge and skills required to carry out their role. The SLO’s training will be updated formally at least every two years, but their knowledge and skills will be updated on a regular basis, including attending networking events, engaging with the Manchester Safeguarding Partnership, and reading relevant update materials. 

Deputy Safeguarding Officers (DSO)

The following posts are Deputy Safeguarding Officers (DSO): 

• Deputy Director Student Services (Health and Wellbeing). 
• Head of Inclusion and Pastoral Support Services. 
• Head of Counselling, Mental Health, and Wellbeing Services. 
• Apprenticeship Lead (Safeguarding). 

 DSOs (Deputy Safeguarding Officers) are responsible for: 

• Acting as a point of contact for all staff to discuss any safeguarding concerns. 
• Maintaining a confidential recording system for safeguarding and child protection concerns, including the action taken.
• Coordinating safeguarding action and interventions. 
• Representing the University (when needed) at multi-agency safeguarding meetings (including child protection conferences). 
• Managing and monitoring the University’s role in any multi-agency plans. 
• Overseeing the referral of cases of suspected abuse or allegations to the appropriate agencies. 
• Reporting to the Safeguarding Lead Officer information/concerns/data relating to safeguarding referrals. 
• Providing university members with information, advice, and training on the safeguarding of children and adults at risk of harm. 
• Providing advice and support to Local Safeguarding and Prevent Contacts in relation to risk assessments that are undertaken, prior to any activity involving children. 
• Providing university members with information, advice, and training on the safeguarding of children and adults at risk of harm. 
• Liaising with the SLO to inform them of any safeguarding issues, especially ongoing enquiries under section 47 of the Children Act 1989 and police investigations.  
• Establishing and maintaining contacts with internal and external key stakeholders; including the police, LADO, local authority. 

DSOs will be trained to the same standard as the SLO.  

Local Safeguarding and Prevent Contacts (LSPCs) 

The following posts are LSPCs: 

• Head of Residential Services. 
• Head of Widening Participation. 
• Apprenticeship Lead – Safeguarding. 
• Experiential Learning Tutor (Saturday provision). 
• Senior Student Engagement Advisors.

LSPCs are responsible for: 

• Acting as a point of contact for staff / students to raise and discuss safeguarding and prevent concerns, knowing when to escalate serious concerns to the DSO or SLO. 
• Managing and escalating referrals to the DSO or SLO. 
• Maintaining a confidential recording system for safeguarding, Prevent and child protection concerns, including the action taken.[1]
• Providing advice and expertise on safeguarding issues relevant to their area of activity. 
• Inducting new members of staff who are appointed to relevant roles, which involve working directly with children and / or adults at risk of harm within their department regarding safeguarding. 
• Supporting and approving safeguarding risk assessments, relevant to their area of expertise. 
• Supporting the delivery of staff awareness training. 

All LSPCs will be trained to at least Safeguarding level 2 standard. LSPC training will be updated at least every two years, but their knowledge and skills will be updated on a regular basis through the Safeguarding and Prevent Operations Group (SPOG). 

Safeguarding Compliance Officers 

The University has various funding agreements with the Education and Skills Funding Agency (ESFA) where it receives funding from the Secretary of State for Education for specific provision e.g., Art Foundation, Degree Apprenticeships, Initial Teacher Training. There is express provision with the University’s funding agreement which requires the University to comply with Keeping Children Safe in Education Guidance, specifically parts 2 (the Management of Safeguarding) and 3 (Safer Recruitment) in the context of funded provision. This means that if the University has under 18 years enrolled on ESFA funded provision, the University must ensure that it can meet the requirements of the Guidance. Safeguarding also forms part of an Ofsted inspection, where the University must be able to demonstrate a readiness and due regard to the Keeping Children Safe in Education Guidance to evidence and demonstrate that effective safeguarding measures are in place, should any under 18 years enrol upon the relevant provision. 

The University Safeguarding Compliance Officers are: 

• Compliance Delivery Senior Manager (Art Foundation). 
• Director of Ofsted Compliance and Quality (Initial Teacher Training). 
• Apprenticeship Lead – Safeguarding. 

The University Safeguarding Compliance Officers are responsible for: 

• Safeguarding compliance on ESFA funded and Ofsted provision, relevant to their position of responsibility. 
• Maintaining a single central record for FE (Further Education) and Skills Ofsted inspected provision. 
• Liaising with relevant academic Heads of Department and the Head of Inclusion and Pastoral Support Services to co-ordinate and record attendance of staff safeguarding training. 

All SCOs will be trained to at least Safeguarding level 2 standard. SCOs training will be updated at least every two years, but their knowledge and skills will be updated on a regular basis through the Safeguarding and Prevent Operations Group (SPOG). 

[1]  The University has a duty of care and legal obligation, to safeguard our students under the Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012 and the Counter Terrorism and Security Act 2015. Art 6(1)c - the processing is necessary for compliance with a legal obligation. Art 6(1)e of the GDPR - the processing is necessary for the performance of a task carried out in the public interest. Substantial public interests include fulfilment of an enactment or rule of law, and the safeguarding of children and of individuals at risk. 

Safeguarding and promoting the welfare of all students is of paramount importance. Safeguarding and promoting the welfare of children under the age of 18 years for the purpose of this guidance is: 

Protecting children from maltreatment; preventing impairment of  children’s health or development; ensuring that children grown up in  circumstances consistent with the provision of safe and effective care;  and taking action to enable all children to have the best outcomes.

(Working Together to Safeguard Children’ 2018). 

Child Protection is part of the safeguarding agenda. It refers to action that is required to be undertaken to protect children who are suffering, or likely to suffer, significant harm. This policy encompasses child protection. 

Safeguarding incidents can be associated with factors outside the University. All staff, especially the SLO, DSO and LSPCs should consider the context within such incidents and / or behaviours occur. This is known as contextual safeguarding, which means assessments of children under the age of 18 years, should consider whether wider environmental factors are present in a child’s life that are a threat to their safety and / or welfare. 

Safeguarding concerns should be raised with Local Safeguarding and Prevent Contacts (LSPCs) or Deputy Safeguarding Officer (DSO) at the earliest opportunity, who will make a judgement as to whether the matter is serious enough to escalate to the University’s SLO. 

If a child or adult at risk of harm makes a disclosure to you, or if a third party discloses their concerns for a child or adult at risk of harm, it is important that you: 

DO: 

• Take everything that is said seriously. 
• Remain calm and listen carefully. 
• Reassure the person that they have done the right thing by disclosing. 
• Make a detailed, contemporaneous written record of the conversation, including   details of the date, time, place of the incident and what the child or adult at risk of harm said and did, and the questions asked of them. 
• Explain to the person what you will need to do next, including who you will need to tell. 
• Allow time and a quiet space for support. 
• If you have an immediate concern for a person’s welfare and it is not possible to contact the University SLO or DSO or, if you are working within an external organisation, you should:  
  • If on campus, contact campus security on telephone number 0161 247 2222. 
  • If in an environment with security provision (e.g., a hospital) contact the respective security.  
  • Dial 999 and contact the police.
  • Act in accordance with this procedure, complete the Incident Report Form (staff access only).  

DO NOT:  

• Ever ignore a disclosure. 
• At any time promise confidentiality. Instead, you should explain that you are worried about a risk of harm/abuse and would like the person’s consent to talk to the SLO or DSO.  If this consent is not given, you should inform the person that you have a duty to protect their wellbeing and safety and that of others and that you will have to talk with the SLO or DSO for advice. 
• Seek to investigate the report or make any judgements. 
• Ever ask the child or adult at risk of harm if they are being abused. 
• Ever take photographs of any injury. 
• Ever record a child or vulnerable adult. 
• Ever physically undress a child or adult at risk of harm to physically examine them.  
• Ever make any assumptions about what may have happened or elaborate beyond what was said in your notes.  

An overview of the process for reporting a safeguarding concern is provided in the appendix.

If you have any concerns about a student, please contact: 

• Assistant Academic Registrar; or 
• Director of Student Services/ Lead Safeguarding Officer; or 
• Assistant Director Security and Compliance.  

If you have any concerns about a member of staff, please contact: 

• Director of Health and Safety; or 
• [email protected] 

Students are expected to abide by the Student Regulations for the use of University Computing Resources. Failure to do so will be regarded as a breach of conduct under the Student Code of Conduct.  

This control procedure defines the University’s approach to acceptable use of its IT systems, and directly supports the following policy statements from the Information Security Policy: 

• The University’s security policies and expectations for acceptable use will be communicated to all users to ensure that they understand their responsibilities. Information security education and training will be made available to all staff and poor and inappropriate behaviour will be addressed. 
• Students must not use computing facilities to access, create, store, or transmit offensive, indecent, obscene, discriminatory, or extremist material. They must not use the computing facilities in a way that has the potential to create an environment that is offensive or threatening, or that may constitute harassment. Threatening, abusive, obscene, or otherwise offensive communications must not be sent; this includes the sharing of nude or semi-nude images, videos, or live streams online by children underthe age of 18 years and / or vulnerable adults. Students must not undertake any online activity that could be harmful sexual behaviour towards or between children or vulnerable adults. Harmful sexual behaviour towards or amongst children or vulnerable adults will be investigated under the Student Code of Conduct. Students will be supported as per the safeguarding policy. 

If a member of staff or others become aware of the sharing of such materials this should be reported to the SLO immediately.

• Never view, copy, print, share, store or save the imagery yourself, or ask a child or adult at risk of harm to share or download – this is illegal. If you have already viewed the imagery by accident (e.g. if a child has showed it to you before you could ask them not to), report this to the SLO or DSO and seek support. 
• Do not delete the imagery or ask the child or adult at risk of harm to delete it. 
• Do not ask the child/children or adult at risk of harm who are involved in the incident to disclose information regarding the imagery. This is the responsibility of the SLO or DSO. 
• Do not share information about the incident with other members of staff, the child or adult at risk of harm if it involves their, or others, parents, and/or carers. 
• Do not say or do anything to blame or shame any child or adult at risk of harm involved. 
• Do explain to them that you need to report it and reassure them that they will receive support and help from the DSL (or equivalent). 

Please note that where the person reporting feels that the LSPC, DSO or SLO has not addressed their concerns, or the person reporting the safeguarding concern prefers not to raise it with the LSPC, DSO or SLO for any reason, the disclosure can be made, in writing, via the University’s Whistleblowing Policy.  

All recorded information relating to safeguarding concerns and disclosures are kept in secure files separate from all other student files. Responsibility for maintaining these files lies with the DSO - Head of Inclusion and Pastoral Support Services. Access to these files is restricted to the: 

• Academic Registrar. 

• Director of Student Services. 

• Deputy Director Student Services (Health and Wellbeing). 

• Head of Inclusion and Pastoral Support Services. 

• Head of Counselling, Mental Health, and Wellbeing Service. 

• Student Welfare Managers. 

Safeguarding files will be reviewed and deleted after seven years after the most recent safeguarding file for the student has been closed. 

If a safeguarding concern arises out of normal working hours that cannot wait until the resumption of normal working hours, then the safety of the student must be prioritised. Please contact Security on telephone number 0161 247 2222. If Security is not available, please call the local police force on 999. The police will be able to provide you with the number for out of hours support.  

Any case dealt with in this manner should also be reported to the SLO via e mail at  [email protected] with the information about who was informed, crime reference number and action that was taken by the police or local authority. The SLO will then set up a case management meeting when normal hours have resumed. 

Staff DBS checks and student chaperones

The University accepts students onto study programmes where they are under the age of 18 years when they start their course (rising 18-year-olds). Where the University has students under 18 years of age, the University will be a Regulated Activity Provider and it must comply with the necessary DBS checks. 

In relation to ESFA funded and Ofsted regulated provision, the University must be able to demonstrate ‘effective’ Safeguarding and compliance with Part 2 and 3 of Keeping Children Safe in Education, in the event any under 18 years enrol on to this provision. 

The University will DBS check any relevant staff (those engaged in teaching, training, instructing, caring for or supervising under 18 years).   The Head of Admissions will regularly provide the Inclusion and Disability Service with a list of under 18 years students that have accepted an unconditional or conditional offer of a place to study at the University.  The Inclusion and Disability Services will contact the relevant Head of Department who will work with the Immigration and Right to Work department within People and OD4 to arrange for relevant staff engaged in regulated activity to complete the necessary DBS checks. 

Where it is not possible for the relevant DBS check to be completed, before the student commences their programme of study, Heads of Department will use departmental resources to employ Enhanced (Children’s barred) DBS chaperones for under 18 years students until they reach the age of 18 years, or until all relevant staff have the requisite Enhanced (Children’s barred) DBS check via J4S. 

This group typically consists of children who attend events either organised or hosted by the University e.g., Saturday groups with local children, widening participation activity, summer schools run by external organisations. It also includes the children of staff or students who accompany their parent / carer on campus. It does not include children who are on site as members of the public e.g., when visiting a university facility open to the public. 

Where the University organises events for children under 18 years of age, the University will be a Regulated Activity Provider of activity if the frequency criteria are met (three or more times in a thirty-day period), and where this threshold is met, must comply with the necessary DBS checks. 

The organiser of such activity must liaise with their LSPC or in the absence of a LSPC the DSO to: 

• Review the activities to determine whether any provision would be regarded as regulated provision. 
• Check whether the provision is subject to funding conditions. 
• Risk assesses activities, using KCSIE as a guide, to ensure mitigations are put in place for any specific risks e.g., supervision of children entering communal spaces.
• If the University is providing accommodation as part of this activity, carry out a specific risk assessment of accommodation arrangements using Accommodation NMS as a best practice guide. 
• Where the activity is regarded as regulated activity, ensure relevant DBS checks are in place for staff and student volunteers (where required). NB regulated activity must not go ahead without the necessary DBS checks being in place. 

Where the University wishes to hire its premises for use by an external provider, the legal department at the University must check the legal terms and conditions of the contract before the contract is entered into. The University legal department will ensure that the terms and conditions of the contract explicitly confirm that the hirer is responsible for the safeguarding of children whilst using the University premises.  The contract will also outline expectations regarding staff to student ratios as well as the actions the University will take where there is a potential breach in relation to safeguarding terms and conditions. (NB the University’s standard terms of hire include these provisions). 

In most cases, students will be aged 18 years or over when they attend their first placement (e.g., Nursing, Initial Teacher Training etc); or study abroad exchange. Where a student who is under 18 wishes to attend a work placement or study abroad exchange; a thorough risk assessment must be completed and approved either by the LSC or DSO. 

Where a university department is approached to offer work experience to children under the age of 16 years, the person who is supervising the child must be DBS checked and a thorough risk assessment should be in place before the placement takes place.  

Where a university department is approached to offer work experience to children aged 16-17 years, the person who is supervising the child does not have to be DBS checked, although it is good practice. However, a thorough risk assessment should be put in place before the placement takes place.

The Health and Safety at Work Act 1974 places a duty upon Manchester Metropolitan University to identify hazards, evaluate and manage risks associated with having children under the age of 16 years on campus. 

A greater duty of care is owed to children than adults and our buildings have been designed with an adult population in mind. As a result, children are  generally prohibited from our university campus; although exceptions are made, where the university is hosting events open to the public, e.g., open days, or during organised educational visits. Under no circumstances should any child or children be left unsupervised.  

The University offers accommodation to children under the age of 18; as well as students over the age of 18. Where a child is living in university accommodation with a student aged 18 years and over the Residential Services team will conduct a risk assessment to identify any necessary safeguarding requirements to mitigate against any risk before the under 18 takes up residence. 

The University must adhere to the Counterterrorism and Security Act 2015, which requires all universities to ‘have due regard to the need to prevent people from being drawn into terrorism’. This is known as the Prevent Duty. The Prevent Duty seeks to protect and support those vulnerable to radicalisation. Radicalisation is the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. The Prevent Duty covers a broad spectrum of beliefs and ideologies which includes Extreme Right-Wing (ERW), Islamist, and Left Wing, Anarchist and Single-Issue (LASIT) radicalisation.

Members of staff may have concerns about students or other members of staff in relation to the Prevent Duty. These concerns may arise from things students or staff say, write or share on social media, as well as their behaviours and appearance. Act Early provides useful information about Prevent, as well as guidance on identifying signs that someone may be vulnerable to radicalisation. 

The Student Referral Guide (staff only) contains information relating to some of the key signs, cues, and behaviours to look out for to help you spot a student who may need additional support, including signs of radicalisation. It provides practical guidance on action you need to take, as well as outlining what is likely to happen after you have made a referral.  

If you have any concerns about a student, please contact:  

• Assistant Academic Registrar; or 

• Director of Student Services / Lead Safeguarding Officer; or 

• Assistant Director Security and Compliance. 

From time to time the University will engage in research with children or adults at risk of harm. The nature of this research will vary. The University’s ETHoS Committee will ensure that all research of this nature will be conducted in a safe manner and that all safeguarding arrangements are risk assessed for each proposal as part of the ETHoS approval process. The approval process will determine the level of checks, parental/carer consent, supervision, participation requirements for the research and will consult with relevant stakeholders, including the LSO and where appropriate the Immigration and Right to Work department within People and OD to arrange for relevant staff engaged in regulated activity to complete the necessary DBS checks. 

Where the University uses contractors to provide services, it will set out the relevant safeguarding requirements in the contract between the University and the provider. 

Navitas is responsible for safeguarding all children and adults at risk of harm attending the International College at Manchester Metropolitan University. 

All members of the University community who are representing the University on non-university premises and who expect to be engaging with children, vulnerable adults, and young people as part of their university activity must familiarise themselves with, and abide by, the host organisation’s safeguarding procedures. 

In relation to ESFA funded and Ofsted regulated provision, the University must be able to demonstrate ‘effective’ Safeguarding and compliance relating to section 3 (Safer Recruitment) of KCSIE. Compliance with Safer Recruitment is the responsibility of Deputy Chief People Officer within the Directorate of People and OD. Responsibility for the collation of the single central record in the first instance is the responsibility of the Assistant Director of HR Operations. Responsibility for the maintenance and update of the single central record, once the single central record is first established, is the University Safeguarding Compliance Officers. 

It is a criminal offence under the Sexual Offences Act 2003 for an adult in a position of trust to engage in sexual activity with a child under the age of 18 years. All staff should take steps to ensure that they do not put themselves in a position where an allegation of abuse can be made against them. Such steps include, but are not limited to: 

• always working in an open environment with children. 
• avoiding unnecessary physical contact with children. 
• avoiding inappropriate familiarity with children. 
• not inviting or allowing children to socialise with them and/or to visit them at home. 
• never engaging with a child via social media and online platforms other than those formally authorised within the context of the project/activity. 
• always acting upon and recording allegations/reports of abuse made by children. 
• always reporting potential concerns/allegations/reports of abuse made by children to the Safeguarding Lead Officer, or in their absence the Deputy Safeguarding Officer. 
• reporting any potential concerns to their Head of Department. 

Failure to adhere to the University’s Safeguarding policy and relevant statutory requirements, could jeopardise the University’s ESFA funding stream and ultimately lead to a withdrawal of such provision.   

The University Executive Group (UEG), through the Professional Services Leadership Team (PSLT) and the Safeguarding and Prevent Strategy Group (SPSG) oversees the implementation of safeguarding policies and procedures, and any adjustments that are required arising from changes to the law and/or national guidance. This policy will be reviewed every three years or earlier if any legislative changes occur.

• The Children Act 1989 (as amended).
• Education Act 2002.
• Safeguarding vulnerable groups 2006.
• The Equality Act 2010.
• Care Act 2014.
• Counter Terrorism and Security Act 2015.
• Guidance for safer working practice for staff working in education settings. October 2015.
• The Children and Social Work Act 2017.
• Working Together to Safeguard Children 2018.
• Data Protection Act 2018.
• Keeping Children Safe in Education 2022.
• Greater Manchester Safeguarding Policies and Procedures.
• Preventing and tackling bullying advice.
• Sexual-violence-and-sexual-harassment-between-children-in-schools-and colleges.
• Mental Health and behaviour in schools November 2018.
• Designated Teacher for Looked After and Previously Looked After Children. February 2018.
• The University’s Statement on compliance with the Prevent duty.
• Student Code of Conduct.
• Staff Disciplinary Procedure.
• Staff Guidance on Responding to Inappropriate Social Media Posts and Other Inappropriate Behaviour.
• The University’s Acceptable Use Policy.
• The University’s Whistleblowing Policy.
• What to do if you are Worried a Child is Being Abused – Advice for Practitioners.