A report on the School Safeguarding Audit and Self-Evaluation for 2013-14 1
1 Purpose and rationale 1.1 The DFE Guidance Safeguarding Children and Safer Recruitment in Schools requires every school to review its child protection policies and procedures annually, and to report this information to the Local Authority. In the light of this requirement, the Local Authority conducts an annual audit of schools in Croydon to ensure they are meeting their statutory requirements in relation to safeguarding. This also helps schools to benchmark their own performance in safeguarding, to build up an evidence base for this, and to identify areas for further development or support. 2 Process 2.1 A letter is circulated to head teachers explaining the purpose of the audit with two forms attached. The first is the School Safeguarding Audit itself which captures essential information about who has responsibility for safeguarding, and provides a checklist of requirements. The second is a self-evaluation tool focusing on key aspects of safeguarding practice in key areas such as policy, training, and the curriculum, with a 1-4 rating that corresponds broadly with Ofsted judgements. With Ofsted in mind, schools are also encouraged to use this as an opportunity to build up the evidence base to validate their own assessments. 2.2 As a quality assurance measure, the paper-based audit is followed by an on-site safeguarding visit for a random sample of 10% of schools. This further supports the statutory requirements placed upon the Local Authority, ensures our compliance and serves as further evidence for Ofsted. The safeguarding arrangements in schools selected are examined in much the same way as for OFSTED inspection. The site visits also serve as a deep dive to help form a clearer understanding of underlying issues, to capture emerging best practice and also to gather any feedback about the audit exercise itself and how this could be improved. Outcomes from the audit are collated on a data base for analysis. 2
3 Responses to the audit and conduct of on-site visits 3.1 The audit was sent to 124 maintained schools, academies, children s centres and nurseries in Croydon. 121 responses to the School Safeguarding Audit were received. 112 responses to the School Safeguarding Self-Evaluation were received. 3.2 A copy of the Safeguarding Audit is shown in Appendix 1 with recorded responses for each part and summarised comments. A copy of the Self-Evaluation is shown in Appendix 2 and a breakdown of recorded responses for the key areas of safeguarding is shown as a bar chart in Appendix 3. 3.3 10% of schools were selected as a random sample for on-site visits. Following the visit, each of the schools concerned received a brief report summarising the outcomes and highlighting any areas for immediate action or recommendation. The key learning points from the audit, the self-evaluation and the on-site visits are included below. 4 Key learning points 4.1 There is a significant degree of overlap between the two parts of the audit. Feedback from the audit visits indicates that this would benefit from streamlining, merged as a single form covering the key thematic areas. This would also avoid the confusion expressed by some schools about whether both parts of the audit need to be returned. Schools accept the need for an audit, and for follow up visits; most commented that although they found the process bureaucratic and time-consuming, they did find it useful and gave examples of where issues highlighted through the audit had already been taken up by the governing body or SMT for further action. 4.2 There is a high level of compliance with safeguarding requirements. This is indicated in the schools own responses and was borne out by the on-site visits. Lapses were mostly accounted for by the time taken to approve policies, or by individuals due to update their training in the very near future. Some instances of policy documents that were clearly out of date (e.g. changes of personnel in the Local Authority, policies that were approved well over a year ago) were however noted. There is also considerable variation in terms of the evidence file for safeguarding arrangements, and the extent to which impact can be demonstrated. Other less secure areas highlighted by the Self-Assessment are summarised in section 5 below. 3
4.3 A similar variation can also be seen in the level of recording and systems used for analysing the various types of data and indicators (attendance, behaviour, medical, parental needs, lunchtime supervisor reports) that together can be used to identify those children who may be vulnerable or at risk. A number of schools are adopting an internal multi-agency approach in this respect. 4.4 Many schools are now developing an extended team that together carries out the range of child protection and safeguarding work. In addition to the designated lead, there are commonly another two or three staff who have the necessary training and seniority to assist in this role. Other key staff will often include the SENCO, the family support worker, the school nurse, the attendance officer and pastoral/ behaviour team leads. 4.5 Other instances of good practice seen on visits included: quick guides with key safeguarding messages and information for visitors and temporary staff; fixed display signs in playground areas devised by children to convey feeling safe playground rules for their peers; use of a set checklist for meetings between the safeguarding governor and the designated lead; bringing a fresh set of eyes to health and safety audits by rotating the responsibility on the governing team; use of the SWGFL 360 e-safety audit tool; safety talks for children delivered by contractors during on-site building works; trained pupils acting as Squabble Busters and Playground Friends. 5 Analysis of the Self-evaluation Responses (see Appendix 3) 5.1 A breakdown of how schools rated themselves on the Level 1-4 scale in each category of safeguarding is shown by the bar chart in Appendix 3. While the overall rating (final column) of good or better (1 or 2) in over 95% of schools is encouraging, there are clearly some areas that are less secure for a significant proportion. These are highlighted as follows: 5.2 Consistency and cross-referencing of procedures rated 3 by 24/121. A sample of policies seen on visits suggests this is an area that needs further consideration. 5.3 Training the high number of no responses (19/121) indicates a lack of certainty or record-keeping over when training last took place. Ofsted will require this information as part of the pre-inspection. 4
5.4 Code of conduct for safe practices the lowest rated category with less than 75% good or better. This may reflect a national picture: the latest statutory guidance in Keeping Children Safe in Education (April 2014) now makes this a mandatory policy requirement. 5.5 Procedures for managing allegations against staff over 10% rated 3 or 4. This is a matter of awareness raising for all staff. 5.6 Child welfare and protection record keeping as noted earlier, there is some variation in what schools consider needs to be recorded, particularly for low level concerns. 5.7 e-safety: Teaching this is clearly an area that is still under development for a number of schools. 6 Recommendations 6.1 The audit should be streamlined and reconfigured as a single form, structured around the key safeguarding themes, combining the necessary checklist to monitor compliance and the opportunity for self-assessment. 6.2 The content of the audit should be reviewed and updated where necessary to reflect the latest statutory guidance in Keeping Children Safe in Education (April 2014) and the revised Ofsted framework (from September 2014). Particular attention should be given to the additional detailed guidance on safeguarding provided in Inspecting safeguarding in maintained schools and academies 6.3 A summarised version of learning points and examples of good practice should be circulated to all schools in Croydon. 6.4 The content of Croydon LA safeguarding training events should be revised in order to offer further support to schools in the areas highlighted by the audit. 6.5 CCSB should consider introducing a recognition scheme for Centres of Safeguarding Excellence in Croydon to help raise awareness and to disseminate good practice. 5
Appendix 1 The format of the Safeguarding Audit is shown here with a summary of all responses received. Any comments/ planned actions area also summarised. 121 recorded responses London Borough of Croydon, Schools Child Protection/Safeguarding Audit 2013-2014 Employment Yes No Awaiting Comments/Action needed/planned checks (Number) All newly appointed staff employed (since 12 th May 121 0 (8) 2006), have had enhanced Declaration and Barring Services (DBS formerly CRB) checks. All supply staff and (where necessary) volunteers 121 0 (6) have had DBS/ CRB checks. All governors have had enhanced DBS/ CRB 117 4* (12) *Some stated this was no longer a requirement checks. All newly appointed staff/volunteers/governors are 120 1 (2) required to make full disclosures (details of all convictions, cautions, warnings and reprimands) in the application form. All newly appointed staff/volunteers including 119 2 (1) temporary have had a List 99 (still accessible via DBS) check carried out and are being supervised whilst awaiting for a DBS check. All existing staff/volunteers have been DBS/ CRB checked within last three years. 115 6* (4) *Some stated this was no longer a requirement 6
Employment Yes No Awaiting Comments/Action needed/planned checks (Number) There is a system in place for renewing checks 115 6* (2) *Some stated this was no longer a requirement every three years. A single central record of checks on all staff/volunteers and governors is in place. (See template below*) 121 0 All job descriptions/advertisements include a reference to school s commitment to safeguarding. 119 2* * 2 schools identified this as an action for job descriptions only Training Yes No Date Comment/Action needed/planned trained The Senior Designated Person (SDP) for safeguarding has attended SDP training within last 111 10* * Most have this as an action with a planned date for renewal two years. The Deputy Designated person for safeguarding 111 10* * Not all the same centres as above has attended DSP training within last two years. Whole school Safeguarding training has taken 115 6* * All scheduled place in past three years. An induction to the safeguarding procedures takes 120 1 place for new staff at the beginning of the academic year. Head teacher has completed Safer Recruitment 111 10 training within the last 5 years Nominated governor has completed Safer 106 15 Recruitment training within the last 5 years. All staff /volunteers have received training in safer 112 9 working practices (not a statutory requirement) Appropriate staff have received Common assessment Framework training. 116 5 One statement: no longer required 7
Policies and procedures Yes No Are the child protection policy & procedures compliant with the LA model document 120 1 Policy and procedures Child protection policy & procedure Anti bullying policy & procedures Behaviour policy and procedures Behaviour and Exclusion Policy and procedures Health & Safety policy and procedures Anti harassment and discrimination policy and procedures Code of conduct setting out expected standards of acceptable behaviour for staff E-safety and ICT acceptable use policies Managing allegations of abuse against staff. Race Equality Policy and procedures Gender Equality Policy and procedures Disability Policy and procedures Admission Policy and procedures Whistleblowing Policy Date ratified by the governing body How are Parents/carers made aware Comments/Action needed/planned/next review Responses in this section broadly indicate most schools have most policies in place and up to date. Some are pending review or approval by GBs or IEBs. Most schools make policies available via websites; some in paper form through handbooks or on request. A few are reviewing their position on this. 8
Recording and monitoring Yes No Any action needed/planned Child protection records are kept separately from 121 0 child s main school file and in a locked cabinet Child protection concerns are recorded legibly, dated 121 0 and signed. Information contained in child protection records is only 121 0 shared on a need to know basis Verbal referrals and followed with a written one, within 24 hours. 121 0 How many positive DBS/ CRB disclosures have been received in the last academic year? None: 55; between 1-4: 62; over 4: 5* * Four unusually high (20; 33; 40; 61)suggesting variation in interpretation/ readiness to record How many times has the school needed to contact the None: 61; between 1-4: 60 LADO in the last academic year? How many racist incidents were recorded by the school in the last academic year? How many bullying incidents were recorded by the school in the last academic year? None: 51; between 1-4: 48; between 5-9: 14; over 9: 8* * Includes some very high incidences suggesting variation in interpretation/ readiness to record None: 49; between 1-4: 35; between 5-9: 16; over 9: 12* * Includes some very high incidences suggesting variation in interpretation/ readiness to record Extended School Activities All providers of extended services being delivered on school site have confirmed in writing that they : Yes No Any action needed/planned Operate safe recruitment procedures and DBS/ CRB 113 8* *1 not in writing; 8 n/a checks have been carried out on staff. Have child protection policy and procedures/or have 110 11* *4 n/a; 7 unsure/ under review adopted school s procedures Have procedures for liaising with the school s designated person on child protection concerns or allegation against staff. 106 15* *8 n/a; not in writing: 8 9
Appendix 2 The format of the Self-Evaluation is shown here and is left blank. Responses to the level ratings are shown in Appendix School Child Protection /safeguarding Self-Evaluation Audit 2013-2014 The audit enables you to: Assess your school s safeguarding practice, and identify any gaps and development areas Develop an action plan to address these (including timescales and progress reports) Review the audit and progress on the action plan half way through the year Ensure that key people within the school (including governing body) know how the school is working on safeguarding Report to the Local Authority as required Ensure your Self evaluation documents accurately reflect the school s safeguarding practice Assemble your evidence of impact of practice for any Ofsted inspection Name of school/ Academy:..DfE: number:. Address: Headteacher Please complete Tick appropriate box Yes No The school has a Designated Senior Person (DSP) for CP in post who is a member of SMT The school has one or more Deputy DSP in post The school has a nominated CP Governor The school has a Designated Teacher assigned to Looked After Children (LAC) The Governing body have been briefed on their responsibilities with reference to LAC The Designated Teacher for LAC has made contact with the Virtual School The Designated Teacher for LAC has undergone training to successfully carry out this role All newly appointed staff/volunteers/ including agency/ supply/temporary have been DBS/ CRB checked at Enhanced level All newly appointed staff/volunteers/governors are informed of the need to make full disclosures (including details of all convictions, cautions, warnings and reprimands) and details of any such 10
disclosures are discussed with the applicant All newly appointed staff/volunteers including temporary have as a minimum been List 99 checked if DBS result still awaited and are supervised pending outcome There is a system in place for renewing checks every three years. The Headteacher has set up a safeguarding evidence folder, which is kept up to date Single Central Record checked against Croydon s model and is kept up to date The Designated Senior Person for CP has completed Induction Training for s.175 role All job descriptions/advertisements include reference to the school s commitment to safeguarding There is a clear, well-defined policy and set of procedures for dealing with racist incidents and bullying Date Headteacher successfully completed most recent accredited Safer Recruitment training Date of most recent whole-school CP training Date of most recent Designated Senior Person completed by the current DSP Identify which of the statements below currently best describes your school at the moment. The levels 1-4 reflect Ofsted judgments. 1. School Child Protection policy 4 The school doesn t have a written CP policy 3 The school has a CP policy but it needs updating 2 The school has a CP policy reviewed in the past 2 years, shared with and accessible to families but it is not fully effective in that not all staff are aware of it 1 The school has an up to date CP policy that is known to everyone working in the school and the governing body, and it includes reference to an annual CP audit, reviewed mid-year. It is easily accessible to parents and carers through the prospectus and/or website 2. Child Protection procedures (including multi-agency procedures and Government guidance) 4 Procedures are in place (including what to do about concerns about a pupil) but known only by the Designated Senior Person 3 Procedures are in place but only the Designated Senior Person, members of LG, and the Nominated CP Governor are aware of them 2 All teaching staff and relevant governors are aware of the established child protection procedures 1 All school staff and regular visitors (including volunteers) know the established procedures 11
3. Consistency and cross-referencing of procedures 4 Although CP procedures are in place, other policies and procedures which come under the safeguarding umbrella (eg anti-bullying, complaints, ICT, behaviour) contradict or do not reference them 3 The school has made a start on looking at other policies and procedures that should be consistent with and reference the child protection policy 2 The school has reviewed all policies, identified those any that are inconsistent with the child protection policy, and has drawn up an action plan to ensure appropriate cross-reference and consistency 1 All policies are aligned; the school undertakes some quality assurance checks on implementation; an annual safeguarding audit is undertaken by Governing Body, and the school has evidence of an action plan implemented and reviewed during the year 4. Training 4 The Designated Senior Person has not yet received multi-agency child protection training 3 The Designated Senior Person has received multi-agency CP training but not in the past 2 years 2 The Designated Senior Person has received multi-agency CP training less than 2 years ago; most members of staff and the nominated governor have received CP training less than 3 years ago; and the school has a record of all the training 1 The Designated Senior Person and nominated governor have both received training appropriate to their role in the last two years, and all staff have received appropriate CP training during the past 3 years; and the school has a record of all the training 5. Safeguarding and the curriculum 4 There are no planned opportunities within the curriculum for children/young people to learn about staying safe including personal safety and child protection 3 The school has audited its curricular provision as regards staying safe, including child protection and safeguarding, and has an action plan identifying areas to develop. 2 The curriculum provides some opportunities for children / young people to learn about staying safe, consider risky situations and explore strategies for seeking help and support. 1 Through PSHE education and other areas of the curriculum there are planned and assessed opportunities for children/young people to learn ways of staying safe including recognising and reducing 12
risk, minimising harm and getting help in emergency and risky situations 6. Anti-bullying practice: The extent to which pupils feel safe from bullying and racist incidents 4 Pupils and parents/carers have little confidence in the schools ability to deal with bullying issues. All incidents are not given due priority and are not dealt with consistently across the school. 3 Pupils say they feel safe generally at school and parents and careers agree. Effective procedures for dealing with racist incidents and bullying and all reported racist incidents are in place across the school 2 Pupils generally understand bullying. Pupils are confident that issues raised will be dealt with promptly and effectively by the school. Staff and pupils are aware of what constitutes a racist incident i.e. any incident which is believed by anyone to have a racial motivation or involves a racist element is considered and investigated as a racist incident, even if other motivations are also involved. 1 Pupils have an excellent understanding about what constitutes bully in various forms. They maintain a well-tuned perspective on their own safety and that of others. Pupils feel safe at school at all times. The school Anti-Bullying Policy and recording procedures specifically refer to racist bullying as distinct from other forms of bullying 7. Safer Recruitment 4 Recruitment and selection procedures have not yet been revised in line with DFE guidance Safeguarding Children and Safer Recruitment in Education 3 Recruitment and selection processes are being reviewed to ensure that they are in line with DFE guidance; the Head teacher has completed required Safer Recruitment training; the school s Single Central register meets all the DFE requirements 2 Recruitment and selection processes have been reviewed and are fully compliant with the DFE guidance as above and all interview panels include a member who has completed Safer Recruitment training 1 Recruitment and selection are carried out as above, and induction for all new staff has a child protection unit which includes safeguarding and safe professional practice guidance. 8. Code of conduct for safe practice 4 There isn t a code of conduct for safe working practice for staff 3 A code of conduct for safe practice exists (in line with DFE and Croydon Council guidance) for some staff groups but needs widening to include everyone who regularly has contact with children. Not all staff are aware of the code of conduct 13
2 There is a code of conduct for safe practice which reflects DFE and Croydon Council guidance, which applies to and is known to all staff, visitors and volunteers who come into school regularly. Every member of staff has been given a copy, and have signed to confirm that they have read it 1 As above, and in addition the school has done safer working practice training and / or discussed it in a staff meeting. 9.Procedures for managing allegations of abuse made against staff 4 Not all members of the senior management team are aware of the Croydon Council procedure on how to respond to allegations of abuse made against staff in accordance with DFE guidance 3 All members of SMT are aware of the Croydon Council procedure for managing allegations against members of staff, including awareness of the allegations flowchart 2 All members of staff are aware of the procedure for responding to and managing allegations against staff, and are clear about how to report any concerns they may have 1 As 2 above; in addition the allegations flowchart is displayed in staff rooms. Where there have been allegations about adults working in the school, there is evidence that the procedure for managing has been properly used by the school, with allegations being reported to the Local Authority Designated Officer (LADO) and clear records kept as required 10. Child welfare and child protection record keeping 4 The school does not yet have a policy on recording, retaining and sharing records of child welfare and child protection concerns 3 The school has a policy on child welfare and child protection record keeping, but this has not been reviewed against Croydon Council guidance for schools 2 The school has reviewed its policy on child welfare and child protection record keeping against Croydon Council guidance and it is consistent with that guidance (including recording outcomes for each concern); the school has a pro-forma for recording child welfare and child protection concerns 1 The school s policy is consistent with Croydon Council guidance, and is effective in that all staff are aware of the policy, and concerns and outcomes are routinely and clearly recorded (including actions and outcomes) 11. e-safety: Policy 4 There is no e-safety policy 3 The school is in the process of establishing an e-safety policy. 14
2 The school has an e-safety policy, which is aligned with national, regional and LA policies. 1 The school has an e-safety policy, which is aligned with national and regional policies and has been developed in consultation with a wide range of staff and pupils / students. There is whole school ownership of the policy. The policy is reviewed annually. 12. e-safety: Teaching 4 There is no planned programme of e-safety education. 3 A planned programme of e-safety education is being developed 2 A planned e-safety education programme takes place through PHSEC / ICT / other lessons and is regularly revisited. Students are aware of e-safety issues and are empowered to stay safe. Appropriate e-safety resources are used. The school is aware of the need to educate and protect vulnerable children who may be put at particular risk from their and others actions on-line 1 A planned e-safety education programme takes place through PHSEC / ICT / other lessons and across the curriculum and is regularly revisited. There is breadth and progression. Students are aware of e- safety issues and understand and follow the e-safety and acceptable use policies. Appropriate e-safety resources are used. The school is effective in the education and protection of vulnerable children who may be put at particular risk from their own and others actions on-line. The school regularly evaluates the effectiveness and impact of e-safety programmes. Final self-assessed level Given the grades/scores you have assessed in the areas above, now indicate below what level you think your school is working at overall 4 3 2 1 15
If your school is scoring mostly Level 4, you need to make safeguarding planning a very high priority. Under the Ofsted Inspection Framework, safeguarding is one of the limiting factors. If you are judged to be working at level 4 on safeguarding, you are likely to be judged Grade 4 overall. Seek help and advice urgently from the LA Schools Advisor, (Child Protection)and DFE Guidance Safeguarding Children and Safer Recruitment in Schools If your school is scoring mostly Level 3 or 2, you have clearly made a good start but still have some work to do. If your school is scoring mostly 1s well done, and keep up the good work. Additional information 1. Designated Senior Person for CP/ Safeguarding: Name:. Job title:.. E-mail address 2. Deputy Designated Senior Person for CP/ Safeguarding: Name:. Job title:.. E-mail address 3. Nominated Child Protection Governor Name:. E-mail address 4. Designated Teacher LAC Name. E-mail address Signature Headteacher Date Nominated CP/ Safeguarding Governor.. Date Review date: 16
Appendix 3 Responses to the Self-evaluation Levels 1-4 are broadly linked to Ofsted judgments (1 highest 4 lowest) 112 recorded responses 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% No response 4 3 2 1 17