Safeguarding Policy

MEDWAY HOMESTAY SAFEGUARDING STATEMENT

A. Policy Statement

Medway Homestay (MHS) provide host family accommodation for a variety of Agents in the UK and abroad including some who are British Council Accredited providers and members of English UK. We maintain that it is unacceptable for a child or young person to experience abuse of any kind and recognise the paramount importance of safeguarding all children and young people (U18’s) in our care. We aim to create a safe environment in which children and young people can thrive and adults can work with the security of clear guidance.

We undertake:

To safeguard the welfare of all children and young people (U18s) who are staying with any of MHS hosts, whatever their race, gender or sexual orientation.
To provide staff, group leaders, hosts and any adults from other organisations with clear guidance on procedures, and appropriate support and training, on how to deal with an allegation of, or concern about, any actual or suspected abuse.
To encourage active responsibility amongst U18s to respect each other, look out for each other and raise concerns with adults if necessary.
To avoid making ourselves vulnerable to suspicion of any form of abuse.

We will seek to safeguard children and young people by:

Ensuring that MHS practises safer recruitment
Ensuring that all adults agree to and adopt a code of conduct which includes having read the Safeguarding Policy.
Ensuring that all U18s agree to and adopt a student code of conduct.
Sharing information and acting promptly and professionally over any concerns.

When will the policy be reviewed?

We are committed to reviewing our policy and good practice annually or whenever an issue arises, to keep it as up to date as possible.

This policy applies to the relationship between students and staff before, during or after a stay.

Terminology

Safeguarding: umbrella term meaning “looking after”
Child Protection: protecting children from direct harmful behaviour
DBS: Data Barring Service (previously CRB)
Child – person under 18
Student – any person under 18 who a member of staff or host family may come into contact with as a result of their work in an educational establishment or while hosting.
Social contact - the exchange of personal information between two or more people.
Electronic contact – the communication or publication of information (including images) between two or more people using an electronic device. This may occur using (but is not limited to) landline and mobile phones, other handheld electronic devices, gaming equipment and computers. Electronic contact may include but is not limited to voice communication, text communication, instant messaging, email, social networking sites, blogs, photos and videos.

Safer recruitment: recruitment procedures and practices which aim to prevent the appointment of people who may pose a risk to children.

Prevent: A government strategy to stop people becoming involved in violent extremism and/or supporting terrorism. MHS has a duty to have due regard to the need to prevent people from being drawn into terrorism.

Key Individual Roles and Levels of Responsibility

All staff and hosts have responsibility for safeguarding U18s. The lead all staff and the lead family member has undertaken an on-line Basic Awareness Training Safeguarding course.

B) Code of Conduct

All adults and U18s are requested to follow an MHS Code of Conduct. This is to ensure that everyone has a positive experience within a safe environment based on mutual trust and respect. It is to protect students and adults alike, from any behaviours/actions which might be misconstrued.

Safe Working Practices for Staff and Home Stay Providers

All members of staff and homestay providers should ensure that they avoid making themselves vulnerable to suspicion of any form of abuses.

Electronic Contact with Children

Students may contact you prior to their arrival, while they are in the UK or once they have arrived home. Please ensure you follow the advice below:

In any electronic contact with students, staff/hosts must pay particular attention to use neutral, un- emotive language that will not be misconstrued.
Staff /hosts must not exchange any information with a student that they would not be happy to share with the child’s parent or carer.
Staff/hosts should be aware that personal information about them may be available in various forms online. Staff/hosts should be particularly cautious about their public web profiles and privacy settings.

Appropriate social contact (electronic or otherwise)

Staff/hosts must maintain neutral, friendly relationships with students while avoiding exclusivity or overfamiliarity.
Staff/hosts must resist any attempt by a student to develop an overfamiliar or exclusive social relationship.
If a student confides sensitive personal information staff/hosts have a duty to listen and respond in a professional manner in accordance with organisation guidelines.

Social Networking Sites

If schools or classes set up social networking forums like Facebook for students, they should be closed groups.
Staff who monitor or administer social networking sites for students should use professional accounts that are as far as possible devoid of personal information.

C) Child Protection

If you are concerned that a student might be at risk or is suffering abuse, you should tell the Co- ordinator of your group who will inform the Group Leader and MHS Safeguarding Officer: Mrs Sam Presneill.

Child Abuse is described by the World Health Organisation as: “all forms of physical and/or emotional ill- treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship or responsibility, trust or power”.

There are four main categories of abuse as follows:

Physical: through hitting, shaking, squeezing, kicking, punching etc.
Sexual: though inappropriate physical contact, the taking of indecent images of children, or the encouragement of sexual activity by children for the purpose of adult gratification.
Emotional: through persistent lack of affection, unrealistic adult demands, verbal bullying including cyber bullying.
Neglect: persistent lack of appropriate care of children, including safety, nourishment, warmth, education and medical attention.

Recognising the symptoms of abuse

It can be difficult to identify child abuse as it has various forms. The signs listed in this document are only indicators and many can have reasonable explanations.
Below are some typical indicators to look for:

Unexplained injuries
A child describing an abusive act that has happened to them
Another child telling you of their concern about a friend/ fellow student
Sexually explicit behaviour in games/ activities
Serious distrust of adults
Difficulty in making friends/ socialising with other children.
Eating disorders; obsessive behaviours
Self-harming; suicide attempts

How to respond to concerns

If you notice any physical or behavioural signs, tell the Coordinator / Designated Safeguarding Officer.
If you suspect an adult is a threat to a child in some way tell the Coordinator / Designated Safeguarding Officer and continue to monitor the situation (see whistle blowing section).
If a child/young person makes any comment that gives cause for concern react calmly and act accordingly as outlined below.
Make a note of what was said and who was present and inform the Designated Safeguarding Officer. He/she will take appropriate action which may involve external agencies and contacting parents/guardians.
Make sure that the student in question is safe and away from the alleged abuser.

How to react if a child chooses to talk to you

A child may choose any adult to talk to, therefore, all adults need to know the right way to respond:

Stay calm, accessible and receptive.
Listen, hear and believe.
Communicate with the child in a way that is appropriate to their age, understanding and preference – this is very important for children whose first language is not English.
Be aware of the non-verbal messages you are giving.
Acknowledge their courage and reassure them that they are right to tell.
Don’t probe for more information. Questioning the participant may affect how the participant’s disclosure is received at a later date.
Don’t promise confidentiality to keep the information a secret.
Don’t deal with this yourself, act in accordance with the procedure in this policy.
Keep a written record of the incident, if possible, on the “Safeguarding/Welfare incident referral form” (attached in appendix).

Allegations made against staff

Allegations can be made by U18s or other members of staff/hosts. Allegations can be made for a number of reasons. Some of the most common are:

a) Abuse has actually taken place.
b) Something happens to a student that reminds them of an event that happened in the past – the student is unable to recognize that the situation and the people are different.
c) Some students know how powerful an allegation can be; if they are angry with you about something, they can make an allegation as a way of hitting out.
d) An allegation can be a way of seeking attention.

An allegation should be reported to the Safeguarding Officer, who will decide whether outside agencies, e.g. the police, the LCSB (Local Child Safeguarding Board) might be involved.

Irrespective of any investigation by social workers or the police, we will follow the appropriate disciplinary procedure: common practice is for the alleged abuser to be suspended from work until the outcome of any investigation is clear.
All incidents should be investigated internally after any external investigation has finished, reviewing organisational practice and putting in place any additional measures to prevent a similar thing happening again.

Keeping Records

An accurate record should be kept and should be signed by the person or people making the statement. The following details should be included:

Date and time of incident/disclosure.
Parties involved, including any witnesses to an event.
What was said or done and by whom.
Any further action taken by Medway Homestay LTD to look into the matter.
Any further action taken.
Where relevant, the reasons why a decision was taken not to refer those concerns to a statutory agency.
Any interpretation/inference drawn from what was observed, said or alleged should be clearly recorded as such.
Name of person reporting on the concern, name and designation of the person to whom the concern was reported, date and time and their contact details.

All this information should be recorded on the Incident/Safeguarding Form held in the Welfare Folder.

All documentation is to be kept secure in the relevant centre within the lockable A4 cabinet, and then forwarded to the Head Office to be kept securely for up to 6 years depending on the severity of the allegation.

D) TRAINING

A senior designated person (currently Sam Presneill) has undertaken appropriate training.
All staff undertake online child protection training (Basic Safeguarding) to ensure that they recognise the symptoms of possible abuse and how they should respond to suspicions of abuse.

E) SAFER RECRUITMENT

All Coordinators and Administrators are recruited from long standing experienced host families and are all DBS checked and have completed the basic safeguarding course.

Relevant staff will have an Enhanced Disclosure and Barring Service (DBS) Disclosure before they start employment with us. If not, until such time as the DBS is received, they will be closely monitored and not left on their own with U18s.

If an applicant’s DBS has a criminal record, their suitability will be judged on a case by case basis by at least two people, (based on the criteria provided in “Guidance for ELT providers – FAQ section C5) and the decision recorded.

All original relevant documentation (proof of identity, qualifications) will be seen by the centre manager prior to the member of staff commencing employment.

Staff are asked to sign a self-declaration statement confirming that they have no convictions for any offence involving any type of harm to a child or children and should declare anything that may affect their suitability to work with children.

Safer recruitment of Hosts

The lead host will require an enhanced Disclosure and Barring Service (DBS) disclosure or to complete Child act 1989 Declaration.

Household must have working smoke and carbon monoxide detectors.

House Rules will be discussed with students and or rules will be displayed in the guest bedrooms. All hosts are visited initially to ensure they are suitable and are revisited periodically. Hosts sign an agreement that they are suitable to host, together with members of the household over the age of 16.

Hosts are required to agree to our T&C and safe-guarding policy which are available on their portal. They can also request a paper copy if required.

F) WELFARE/IMPLEMENTING SAFEGUARDING

Duty to report

All members of staff/homestay providers are required to report to the Safeguarding Officer any concern or allegations about MHS practices or the behaviour of colleagues which are likely to put children/young people at risk of abuse or other serious harm.

Staff have a duty to report to the employer any actual or perceived inappropriate development of the relationship between student and staff, electronic or otherwise.
Any sensitive information communicated by a student to a member of staff, electronic or otherwise, must be reported to the employer.

Failure to comply:

Non-compliance with the above policy will result in disciplinary procedures.
Employers have a duty to remove an individual from regulated activity where there is risk of harm to children.
Employers have a ‘duty to refer’ to external authorities* any suspicion or allegation of inappropriate contact by an individual engaged in regulated activity where there is risk of harm to children. (*ISA, police, local child protection authorities).

Abusive Behaviour

MHS will not accept any form of abusive behaviour towards our students from other students or adults during the stay. This kind of behaviour may involve (not a comprehensive list):

Verbal abuse: name-calling, racist or sexist comments, threatening language • Physical/sexual abuse: touching, striking, spitting
Emotional abuse: ostracising, neglecting, humiliating, intimidating

The Group Leader & Coordinator will decide what sanctions may be used against the offender e.g. apologies, being moved to another homestay provider, being moved to the adult homestay provider.

All staff have a collective responsibility for ensuring:

that abusive behaviour does not go unnoticed.
that abusive behaviour is reported promptly.

If you are not sure whether something you’ve seen should be dealt with under this heading, please speak to the Coordinator / Safeguarding Officer.

Procedure in the case of a Student abusing another student

In the event of an incident being reported to the Coordinator / Safeguarding Officer, the Coordinator will inform the Group Leader who will take appropriate action to gather any additional information.

The student(s) will then be spoken to by the Group Leader, together with (as necessary) the Coordinator/ Safeguarding Officer. They will be told that they can bring a friend/supporter with them to the meeting.

If the staff involved are content that the incident is not of the most serious sort, and that the student(s) concerned is unlikely to repeat the action, then the student will be given a warning as to his conduct and an appropriate sanction. The student may also be obliged to meet with any other affected student(s) to offer an apology.

Depending on the seriousness of the incident, a letter may be sent both to the agent with whom the student travelled, and to his/her parents/guardians.

In more serious cases of abuse, the student would be returned home at their own expense. In the most serious cases, relevant outside agencies may be involved.

Procedure in the case of an adult abusing a student

The Co-ordinator will immediately notify the Safeguarding Officer – Mark Simpson and direct Lisa Sullivan. All instances of reported abuse between an adult and a student must be treated as serious and need to be investigated without delay.
Depending on the exact circumstances of the incident, and the role of the staff member/host, he or she may be temporarily removed from their position or hosting.

The Managing Director in consultation with the Safeguarding Officer will decide whether an outside agency needs to be involved at this stage.

If the incident is of a serious nature, the staff member/host may face dismissal. If the incident is of a less serious nature it will be dealt with accordingly.

Managing Behaviour and Acceptable Restraint

(This has been formulated in accordance with Department for Education – Use of Reasonable Force 2011).

Physical contact with students must be appropriate for the age, understanding and sex of the child and must never threaten or be sexually inappropriate. In some cases, physical contact may be appropriate:

To remove disruptive students from the classroom where they have refused to follow an instruction to do so;
Prevent a student behaving in a way that disrupts a school event or a school trip;
Prevent a student leaving the classroom/home where allowing the students to leave would risk their safety or lead to behaviour that disrupts the behaviour of others;
Prevent a student from attacking a member of staff or another person, or to stop a fight;
Restrain a student at risk of harming themselves through physical outburst.

You cannot:

Use force as a punishment – it is unlawful to use force as a punishment.

What happens if a student complains if force is used on them?

All complaints should be thoroughly investigated.
Where a member of staff/host has acted within the law – that is, they have used reasonable force in order to prevent injury, damage to property or disorder – this will provide a defence to any criminal prosecution or other civil or public law action.
MHS must consider carefully whether the circumstances of the case warrant a person being suspended/no longer host until the allegation is resolved or whether alternative arrangements are more appropriate.

Prevent Duty

MHS is committed to the government strategy to stop people becoming involved in violent extremism and/or in supporting terrorism. Anyone may be vulnerable to extremist exploitation. Our aim is to provide an environment on our courses/homestay where everyone feels safe and supported, and where there is a clear process of referral of concerns for staff, students and homestay providers. We will promote core British values where possible. These are: democracy, the rule of law, individual liberty, and respectful tolerance of different faiths or beliefs.

Signs that May Cause Concern

Students talking about exposure to extremist materials or views outside school.
Changes in behaviour, e.g. becoming isolated.
Intolerant of differences.
Attempts to impose own beliefs.
Use of extremist vocabulary to exclude others or incite violence.
Accessing extremist material online or via social network sites Over new religious practices.
Drawing or posters showing extremist ideology/views/symbols.
Students voicing concerns about anyone

How and When to React to Concerns

If you are concerned, contact the Co-ordinator at your centre, or the Safeguarding Officer. We will discuss the issue, take advice if necessary, and then make a referral to the relevant authorities if necessary. Please report any concern or incident, however small.
All will be dealt with sensitively and carefully.

MEDWAY HOMESTAY (MHS)

Here, at MHS, we are like a big family, with one goal in mind - to ensure that the students and teachers that visit us go back with fantastic memories of their "English Experience" in England.

To ensure this happens we have well trained and experienced Administrators and Coordinators.

It is our aim to give the families and leaders all the support they need, with a minimum of fuss, so that everyone has a good time.

If you have any concerns about students, Coordinators or other hosts please get in touch with

Designated Welfare and Prevent Lead: Mrs Sam Presneill.

STUDENT CODE OF CONDUCT

We want your students to enjoy their time with us in the UK. We will do everything we can to make the stay a big success for everyone, and we want your students to help us to do this too.
Please ensure you discuss or display the House Rules with your student. You can also talk through the examples below with your students. The rules tell the student about examples of behaviour which we will not accept, and also examples of behaviour we want to encourage.

These rules apply to all students
Including those who are 18 years old or over before or during the stay.

Examples of GOOD student behaviour

We want you to respect the hosts and the home where you are studying.
We want you to listen to your teachers, the MHS Coordinator and the other students.
We want you to listen to your teachers and to follow their instructions on the excursions
We want you to listen to the Co-ordinator and to follow their instructions.
We want you to let us know if you or your friends are unhappy.
We want you to be punctual for meals and for departure to the meeting point.
We want you to be friendly, polite and respectful and to accept other students’ faith and beliefs.
We want you to participate in the activities and to include everyone.
We want you to try and speak English all the time.
We want you to try different foods.
We want you to work hard and participate in your English classes (if applicable).
We want you to stay safe on-line and be careful with whom you share information.

Examples of UNACCEPTABLE student behaviour

You must not buy or drink alcohol.
You must not smoke cigarettes or e-vapour cigarettes in the host’s home.
You must not buy or take any illegal drugs (including legal highs).
You must not steal from other students, shops or the families.
You must not carry any weapons, for example a knife or imitation gun.
You must not threaten or be violent towards other people.
You must not make too much noise at your host’s house, especially late at night.
You must not drop rubbish in the streets or at school or write graffiti anywhere.
You must not enter other people’s bedrooms without permission.
You must not leave your host’s house in the evening.
You must not bully other people, (this includes things you say and do as well as physical bullying).
You must not create, transmit, display or publish any inappropriate or extremist material online, or share inappropriate photos or information without permission.

What happens if a student breaks the rules?

We take student behaviour very seriously and there will be consequences.

Hosts should talk to your Coordinator.
The Co-ordinator will then decide whether to inform the Group Leader or not.
If necessary, the Group Leader and Co-ordinator will talk to anyone else involved.
The Co-ordinator will make a record of the incident and inform the Administrator if necessary.
The Co-ordinator and the Group Leader will then make a decision about the consequences.
Students will usually have an opportunity to improve their behaviour, however if it is a serious situation (for example: drinking alcohol, taking drugs, bullying another student, stealing) they may be removed from their accommodation and sent home.
If serious the Safeguarding Officer will be informed and act according to the MHS Safeguarding Policy.
If a student is sent home, then their parents will have to pay the cost.

Some consequences for less serious situations could be:

Cleaning up the bedroom if you have been making a mess.
Apologising to a host for being noisy or unfriendly.

For the most serious bad behaviour which involves breaking the laws in the UK the police may be called. The police have the power to arrest you if they suspect you have committed an offence.

What do I do if a student has a problem or wants to make a complaint?

If your student has any problem, it is really important that they tell somebody about it so we can deal with it. The person who will help you with the problem is the Co-ordinator, however, in the first instance, they may prefer to tell a friend, a teacher or your Group Leader. They can then help the student to bring the problem to us.

If your student has a complaint about any member of staff, another student, or their Homestay placement, please advise them to tell the Group Leader and Coordinator as soon as possible. We will take their complaint seriously; we will investigate and then we will tell the student whether we agree with them and what we can do.

Who should they speak to?

In the first place speak with the person who can easily solve the problem: if it is about the homestay, talk to the host or co-ordinator; if it is about another student or staff member talk to the Group Leader. If talking to that person doesn’t solve the problem, they may want to make a complaint to our management. There is a way for them to do this and it will involve having a meeting with the Safeguarding Officer, Sam Presneill. They can take a friend or the group leader to that meeting you help you.

Personal Safety and Care of Valuables

Students must always be aware of their surroundings and use common sense. Cross roads safely, remember that vehicles drive on the left in the UK, so traffic will be coming towards them from the right. Avoid walking alone and keep to well-lit, busy streets. Keep their wallet, phone, keys and other valuables with them at all times, and out of sight in busy, public places.

Important note to hosts:

If you have any concerns regarding your student’s behaviour, please contact your co-oordinator in the first instance.

STAFF CODE OF CONDUCT

We expect all MHS staff to conduct themselves in a way that will reflect well on our organisation and ensure the safety of our students.
Invariably, this is the case, and we recognise that our staff are a great advertisement for our organisation as well as a role model to our students. Nonetheless, it is important that we are absolutely clear about what is expected from staff.

Drugs, Alcohol, Smoking, Weapons

Our staff will not possess, use or be under the influence of drugs (including legal highs) while in our employment.
Staff will not consume alcohol while on duty, nor will they be under the influence of alcohol while on duty. It is also unacceptable to come to work suffering from the effects of alcohol – the students deserve better. Staff will observe the laws regarding smoking on site (including e-cigarettes). Staff will not smoke while engaged in activities with the students. The breaking of these rules will lead to disciplinary procedures. Please do not carry any weapons, e.g. knives.

Relationships

A staff/staff relationship is your own affair, except where it has a negative impact on your performance of your job, or where it reflects badly on our organisation. Discretion is required.

Adult – U18 Interaction

A relationship between staff/student is unacceptable, even where it is not illegal. Generally, in relating to students, staff have to exercise caution, without distancing themselves entirely. As a general principle:

Avoid situations where you are alone with a student. If the situation is unavoidable try to ensure that the door is not closed and that you don’t position yourself between the student and a door.
Respect the privacy of students regarding bedrooms, bathrooms, etc. in residential accommodation.
Physical contact is not acceptable.
If you are concerned in anyway about the nature of a relationship with a student talk about it with the Safeguarding officer.

HOWEVER

Do take an interest in the students; using praise and being positive.
Do speak with them as often as possible.

Prevent Duty

Prevent is a government strategy to stop people becoming involved in violent extremism and/or in supporting terrorism. We have a legal duty to identify and safeguard children who may be vulnerable to radicalisation, and to challenge extreme views, whilst promoting the core British values of democracy, the rule of law, individual liberty, and respectful tolerance of different faiths and beliefs. We expect you to be observant and vigilant in noticing any signs of radical or extremist behaviour, and to report any concerns to the Centre Welfare Office.

Professional Duties

We expect you to fulfil your duties to the best of your ability and to be professional in all you do. This includes the details: being on time, learning the leaders’ names, dressing appropriately. It also includes being polite and respectful towards your colleagues and the group leaders accompanying the students.

All staff should be familiar with and follow MHS’ policies, particularly the Safeguarding Policy and Health & Safety Policy.