Safeguarding and Prevent Policy

The School implements safeguarding measures to protect at-risk students, including children and vulnerable adults, from abuse and exploitation. Safeguarding promotes their welfare by addressing significant risks while upholding the duty of care. Safeguarding is the protection of individuals' welfare; abuse refers to mistreatment causing harm; and neglect is the failure to provide necessary care. This policy applies to all students, staff, visitors, and contractors, ensuring clarity around roles and responsibilities within the safeguarding framework.

A member of the Student Success Team assumes the role of Designated Safeguarding Lead (DSL), responsible for overseeing safeguarding policies and procedures. They ensure the welfare of students by providing support and guidance in safeguarding matters. All staff, students, and volunteers must understand their responsibilities in safeguarding, including recognising signs of distress, reporting any concerns promptly and accurately, and maintaining confidentiality regarding sensitive information. They are required to follow established protocols and procedures to maintain a safe and supportive environment for everyone.

All staff members must complete a Disclosure and Barring Service (DBS) check prior to recruitment.

The School’s Harassment and Student Safety Policy ensures a safe, inclusive, and respectful environment for all members of our community. Harassment, abuse, sexual misconduct, and discrimination are strictly prohibited. All students and staff must adhere to the School’s policies, with disciplinary action enforced for breaches, whether they occur on or off School premises, in person, or via digital platforms such as the AGS, social media, emails, or text messages.

The Staff and Student Relationship Policy prohibits specific relationships between staff and students to prevent conflicts of interest and safeguarding issues. All relationships must be disclosed to ensure transparency and uphold professional boundaries.

The School assigns each student a Personal Academic Tutor (PAT) to offer both academic guidance and broader support throughout their studies.

The School has a dedicated Mental Health Policy detailing various methods for supporting students with their mental health needs. 

The Student Success Team provides free, independent, and confidential support for academic, financial, and personal well-being issues. Students can seek assistance from the Team, their Personal Academic Tutor (PAT), or any staff member at any time. The School’s strategy places students at the centre, linking educational and life experiences to enhance overall success and satisfaction. This approach integrates academic and personal support to offer a holistic student experience, ensuring comprehensive care and addressing all aspects of student life effectively.

All staff and students must report safeguarding and Prevent concerns promptly. To report suspicions or incidents, individuals should contact the Safeguarding and/or Prevent Leads (Designated Leads) via the ticketing system on the AGS, email, or in person. Support for those making reports includes access to counselling services. The School guarantees confidentiality throughout the reporting process, ensuring that individuals feel safe to disclose information without fear of repercussions. This structured reporting informs the School’s safeguarding strategy, allowing teams like the Student Success Team to address issues, make informed decisions, and allocate resources effectively. Students are also encouraged to participate in feedback sessions, ensuring their voices shape decision-making processes.

The School implements robust risk assessment procedures, including via its risk register, to identify and manage potential risks to student safety, particularly for vulnerable groups. Regular assessments are conducted to evaluate environments and activities, considering factors like physical safety, mental health, and external threats. Action plans are developed and submitted to mitigate identified risks, ensuring appropriate measures are in place to protect all students.

The School has established clear emergency procedures to guide responses in critical situations. These include detailed contact numbers for emergency services, internal support teams, and the Safeguarding and Prevent Leads (Designated Leads). Response protocols outline steps for evacuations, lockdowns, and medical emergencies, ensuring that all staff and students are informed and prepared to act swiftly and effectively.

This section sets out how the School identifies and supports students who may require early intervention before a formal safeguarding or Prevent referral is made. It provides a proportionate and structured approach for recognising emerging concerns, coordinating welfare support, and ensuring that appropriate action is taken to protect student wellbeing while maintaining a supportive academic environment.

The School recognises that students, including those studying flexibly or online, may face personal, academic, or environmental pressures that affect wellbeing and engagement. In a small and closely connected learning community, staff are well placed to notice emerging concerns quickly. This procedure ensures that such concerns are managed systematically, drawing together welfare, safeguarding and Prevent responsibilities, so that risk is identified and addressed at the earliest opportunity. It applies to all enrolled students and to all staff who may observe, receive or hold information indicating that a student could be at risk.

• Proportionality and Support: All actions are guided by the principle of providing timely support while avoiding unnecessary escalation.
• Integration: The procedure operates in conjunction with the Student Resources, Support and Wellbeing Policy, and the Personal Academic Tutoring (PAT) Policy.
• Confidentiality and Data Protection: Information is shared only on a need-to-know basis, in accordance with data-protection legislation.
• Equality and Respect: The School will apply this procedure in a manner consistent with the Equality Act 2010 and the Human Rights Act 1998, ensuring that no individual is treated less favourably on the basis of protected characteristics or personal beliefs.

Concerns about a student may arise from changes in behaviour, attendance, participation, communication, or academic engagement, or from explicit statements or actions that suggest distress or vulnerability. Indicators may be academic (e.g. sudden disengagement), social (e.g. withdrawal from group activity), or behavioural (e.g. expressions of extremism or discrimination). Staff and students are expected to remain alert to these indicators as part of their safeguarding responsibilities. Where a concern is identified, it should be reported following the process described in the “Cause for Concern” section below.

Where a member of staff or student identifies behaviour or information that raises concern about an individual’s wellbeing, safety, or potential vulnerability to radicalisation, they should report it without delay via the Prevent Support Ticket system or directly to a Designated Lead. This internal reporting mechanism constitutes the School’s Cause for Concern process. All reports are logged and triaged in accordance with this Procedure and, where appropriate, will be escalated under the relevant regulations and policies. 

Upon receiving a report, the relevant Designated Lead should undertakes an initial review to determine the nature and immediacy of the concern. They must consult with the student’s Personal Academic Tutor (PAT) and, where appropriate, the Student Success Team. They must apply the School's policies. The aim of triage is to ensure that each concern is directed to the most suitable pathway — academic support, wellbeing support, or safeguarding / Prevent intervention — in a timely manner.

If a student is judged to be at risk but not in immediate danger, the Designated Lead may coordinate appropriate support. This may include:

• referral to counselling, wellbeing or external medical services;
• adjustments to learning or assessment arrangements;
• increased contact with a PAT or Student Success Team; or
• structured welfare check-ins.

Where the risk relates to potential radicalisation or safeguarding, the Prevent Lead should assume responsibility for managing escalation in line with the referral and Channel procedures.

If at any stage a student is considered to be in immediate danger or poses a serious risk to themselves or others, staff must contact emergency services and notify the Designated Leads and Executive Committee without delay. The emergency procedures detailed in the following section of this policy apply in such circumstances.

All Student at Risk cases are documented within the secure AGS platform. Access is limited to members of the Executive Committee, Designated Leads, Student Success Team, and relevant PATs. An anonymised record of cases and outcomes is maintained to support institutional learning, ensure accountability, and inform risk monitoring.

Designated Leads provides anonymised semesterly summaries of student-at-risk activity to the Executive Committee and the Quality, Compliance and Audit Committee, for reporting to the Board of Governors. These reports enable senior leaders to evaluate patterns, resource implications, training needs, annual planning, and regulatory reporting, ensuring that the School’s approach remains proportionate and effective. Lessons learned feed into the annual report, risk assessment, and action plan, reinforcing continuous improvement.

All staff must complete an induction on the School’s policies and receive ongoing training. This training covers the identification of safeguarding issues and how to provide appropriate support.

The School meets its statutory obligations under the Counter-Terrorism and Security Act 2015 through a structured framework that integrates governance, operations, risk management, and assurance.

Governance

Ultimate accountability for Prevent rests with the Board of Governors, which receives semesterly and an overall annual Prevent report and approves the accountability declaration for submission to the Office for Students (OfS). Oversight is exercised through the Quality, Compliance and Audit (QCA) Committee, which reviews Prevent performance, risk exposure, and policy alignment, and reports to the Board of Governors. The Academic Board provides academic oversight of freedom of speech and academic freedom, ensuring these principles are upheld within teaching, research, and events. The Executive Committee ensures institutional coordination and operational delivery of Prevent responsibilities.

Operations

Operational leadership sits with the School’s Prevent Lead, who is appointed by the President from the Executive Committee. The Prevent Lead works closely with the Safeguarding Lead (Designated Leads) and is supported by the Student Success Team, People Team, and other relevant staff. Their Prevent responsibilities are embedded across several key institutional policies, including the Safeguarding and Prevent Policy, Freedom of Speech and Academic Freedom Policy, External Speakers and Events Policy, and IT and Digital Safeguarding Policy. For example, a three-tier Prevent training framework (induction, refresher, and role-specific) ensures all staff understand their duties. Prevent awareness and support are also embedded within the Student Handbook and Student Engagement Policy.

Risk Management

Key Prevent-related risks are managed via the School’s central Risk Register, owned by the Prevent Lead and reviewed regularly by them, with reports to the Executive Committee. These reports are aggregated for QCA Committee oversight and reported to the Board of Governors each semester. The reports cover academic delivery, student experience, staff wellbeing, financial exposure, and institutional reputation. Mitigations include structured referral pathways, external event approvals, Prevent training, and digital safeguarding controls.

Assurance and Continuous Improvement

Assurance is achieved through a cadence-based reporting and review structure, aligned to Board of Governors meetings. The Prevent Lead submits regular, semesterly updates to the Executive and QCA Committee, and an annual report, risk assessment, and action plan. These are reviewed and submitted by the QCA Committee to the Board of Governors for approval. The Academic Board also receives semesterly updates from the Executive Committee on academic freedom and free speech. The School maintains comprehensive records of Prevent activity on the AGS—including training, referrals, and event approvals. Engagement with the OfS Prevent Team and the regional HE/FE Prevent Coordinator supports self-assessment, scenario testing, and continuous improvement.

The Executive Committee conducts an annual Prevent-related risk assessment, based on work undertaken by the Prevent Lead throughout the year, which is submitted to the QCA Committee for oversight, and then reviewed and approved by the Board of Governors. Prevent policies and associated documents (e.g. risk registers, action plans) are reviewed as part of this to ensure alignment with current legislation and best practice.

To support this, the Prevent Lead provides formal reports on Prevent-related activity, risks, training, and referrals to the Executive Committee each semester. The full annual Prevent report is then submitted to the QCA Committee, which in turn provides assurance to the Board of Governors.

This cycle supports annual oversight.

As part of its statutory obligations, the Prevent Lead coordinates Prevent training to all staff. Training is tiered according to role and level of engagement, and includes:

• Mandatory core induction for all staff
• Annual refresher training
• Targeted sessions for those in high-risk roles or involved in online delivery

The Prevent Lead is responsible for overseeing the content, delivery, and maintenance of training records. Materials are reviewed annually to ensure alignment with current regulatory guidance and institutional needs.

In addition to staff training, events-related and student-facing information is shared to promote awareness of safeguarding responsibilities and available support pathways.

Staff with Prevent-related concerns are advised to speak with the Prevent Lead or raise the matter with their line manager for referral.

Students are informed of the School’s Prevent responsibilities through the Student Handbook, onboarding sessions, and training materials.

Feedback mechanisms — including online contact forms via the AGS, feedback surveys, and one-to-one support — enable students to raise concerns, request support, or suggest improvements. These insights directly inform the School’s whole-institution approach to Prevent and its annual review of Prevent implementation, ensuring alignment with student needs and expectations.

Student representatives contribute to Prevent-related discussions through membership on governance bodies, and are consulted on updates to key student-facing policies and institutional strategies. Where appropriate, short-term working groups or consultation panels may be convened to ensure that student perspectives are actively reflected in the School’s safeguarding and Prevent approach.

In certain academic disciplines, staff or students may require access to material related to terrorism or extremist ideologies for legitimate teaching or research purposes.

The School permits access to such material only where it is essential to an approved programme of study or formally supervised research. Prior approval must be obtained by discussing the proposed use with the Prevent Lead. A written risk assessment will be conducted to identify and implement appropriate safeguards, including secure access, academic supervision, and clear research or pedagogical justification. The OfS and relevant external bodies may be contacted for feedback.

This process ensures compliance with the Prevent Duty under the Counter-Terrorism and Security Act 2015, while upholding the principle of academic freedom. It also protects staff and students from undue risk when engaging with sensitive content.

Unsupervised or unauthorised access to such material is strictly prohibited and may lead to disciplinary action.

All proposed events falling within the definitions set out in the External Speakers and Events Policy — including Internal, External, and Collaborative LSI Events held on-site, online, hybrid, or asynchronously — must be submitted in advance through the AGS Event Request process for structured risk assessment.

Risk assessment considers the event’s classification, topic, audience, and speaker profile, including potential for unlawful or extremist content, safeguarding concerns, reputational impact, or breach of the Freedom of Speech and Academic Freedom Policy. Outcomes, including any mitigations, conditions, or decisions to modify or decline events, must be recorded in the Event Register and retained in accordance with the School’s record-keeping policy.

All organisers are required to complete role-specific Prevent and Events training to ensure consistent application of approval and escalation procedures.

The School recognises its responsibilities under the Prevent Duty to identify and manage online risks, including exposure to extremist or unlawful material, or content that may support radicalisation.

The School applies proportionate filtering and monitoring controls across its digital platforms to prevent access to harmful or illegal material, while preserving academic freedom and privacy in accordance with the Data Protection Policy. Where a specific safeguarding or Prevent-related risk is identified, enhanced monitoring or content restriction may be introduced under the direction of the Director of Technology and Prevent Lead, with all actions recorded in the Digital Risk Register.

All users are expected to use the School’s digital systems responsibly and lawfully, in accordance with the IT and Digital Safeguarding Policy. Any concerns about online content or behaviour — including extremist, violent, or radicalising material — must be reported immediately through the Prevent Support Ticket system or directly to the Prevent Lead.

Any serious Prevent-related incident or material change must be reported promptly to the OfS. This includes:

• Substantial changes to Prevent-relevant policies or structures

• A new Prevent Lead or governance structure

• Significant operational shifts (e.g. new campuses or delivery modes)

• Incidents involving reputational or safeguarding concerns

Reports are submitted via the OfS portal or to the Prevent team directly, with relevant documentation and explanation.

The School conducts an annual review of Prevent implementation as part of its institutional risk and compliance framework. This process ensures alignment with statutory requirements, supports continuous improvement, and provides assurance to governance bodies.

The review includes:

1. Assessment of Prevent-related risks, with updates to the risk register, mitigations, and annual action plan. 

2. Evaluation of Prevent training, including staff completion rates and effectiveness.

3. Review of relevant activity logs, such as external speaker approvals, incidents, and associated risk assessments.

4. Analysis of Prevent-related complaints, referrals, or concerns raised.

5. Feedback collection from staff and students via surveys, consultations, or focus groups.

The Prevent risk assessment identifies areas of vulnerability across institutional activity. The annual report, risk assessment, and action plan outline targeted, proportionate measures—such as training, policy updates, or enhanced referral mechanisms—to mitigate these risks.

The QCA Committee reviews the Prevent-related risks and plan, and provides reports and assurance to the Board of Governors.

The Board of Governors is responsible for reviewing and formally approving the annual report, risk assessment, and action plan, as part of its oversight of statutory compliance and regulatory reporting. Findings and progress are documented in an internal Prevent report, and tracked by the Executive Committee.

The School maintains open communication with the OfS Prevent Monitoring Team and relevant external partners, including local Prevent Coordinators. This includes:

• Participation in Prevent Review Meetings (PRMs) if selected

• Responding to OfS requests for information or thematic reviews

• Contributing to sector-wide initiatives and good practice sharing

The School supports case-level coordination with Prevent partners when appropriate, including contribution to Channel Panels and liaison with police or safeguarding services. These interactions are led by the Prevent Lead and ensure a joined-up response to risk, reinforcing the School’s safeguarding framework and statutory responsibilities.

The Prevent Lead will maintain a Prevent Engagement Log documenting all formal engagement with external Prevent partners, including the local authority Prevent Coordinator, Channel Panel, and police liaison where applicable. Records of meetings, advice received, and resulting actions will be retained and reviewed semesterly by the Executive Committee to evidence ongoing partnership working and information-sharing in accordance with statutory guidance, and to inform annual planning.

Concerns related to radicalisation, vulnerability to extremism, or other Prevent indicators can be raised by any member of staff or student. These may arise through face-to-face interaction, online engagement, or observations of behaviour.

All concerns should be submitted via the Prevent Support Ticket system on the AGS (for students) or reported to the Designated Safeguarding Lead or Prevent Lead. The Prevent Lead is responsible for assessing the concerns under the Prevent Duty, consulting safeguarding colleagues if appropriate, and determining whether further referral (e.g. to Channel or local Prevent coordinators) is needed.

Following any Prevent referral, the School will determine and implement appropriate support measures. These may include internal pastoral support, counselling, or referral to external safeguarding services. Every case is handled sensitively and proportionately, prioritising individual welfare and institutional responsibilities. Where required, appropriate referrals will be made to external agencies such as the Channel panel, Prevent coordinator, or police, in accordance with the School’s statutory obligations.

All serious Prevent-related incidents must be reported to the Office for Students (OfS) without delay.

A serious incident includes, but is not limited to:

• Reputational damage linked to extremism or radicalisation;
• An internal safeguarding failure involving Prevent concerns;
• Police involvement or emergency response relating to radicalisation; or
• A Channel referral or multi-agency case requiring escalation.

Upon identification, the Designated Prevent Lead must ensure that the incident is entered into the Prevent Log within 24 hours, with details of the nature of the concern, immediate actions taken, and any agencies involved.

The Prevent Lead will then notify the OfS Prevent Team within five (5) working days, via the OfS portal and by email, in accordance with statutory reporting requirements. The submission must include a description of the incident, actions taken, and any resulting policy or procedural changes.

Evidence of notification and all related correspondence must be retained in the Prevent Evidence Register. Each reported incident will be reviewed by the Executive Committee at its next meeting for assurance and to determine whether further governance or procedural action is required. It will inform annual planning.

The School must report material changes that may impact its implementation of the Prevent Duty. These include:

• Substantive revisions to Prevent-related policies (e.g. welfare, IT, external speaker management)

• Appointment of a new Prevent Lead, Designated Safeguarding Lead, or significant leadership restructure

• Major changes to institutional operations (e.g. mergers, campus expansion, or delivery format changes such as from online to in-person)

• Major changes to partnership or franchise arrangements affecting Prevent responsibilities

All declared material changes must be recorded on the Automated Governance System (AGS) under the Prevent Evidence Register. Each submission will be reviewed by the Executive Committee prior to formal notification to the OfS. Reports should be submitted through the OfS portal and by email, accompanied by relevant documentation (e.g. revised policies, updated governance charts) and an explanation of the likely impact on Prevent delivery. A consolidated summary of all reported material changes will be presented within the Annual Prevent Report to the Quality, Compliance and Audit (QCA) Committee and the Board of Governors.

The Prevent Lead is responsible for coordinating the identification, documentation, and reporting of both serious incidents and material changes. Where relevant, they will liaise with:

• The Designated Safeguarding Lead (DSL)
• The President or relevant Executive Committee members
• The QCA Committee and Academic Board 
• Other staff

The Prevent Lead will:

1. Record the incident or change using the Prevent logs on the AGS
2. Collate relevant documents and a summary explanation
3. Discuss it with School bodies.
4. Submit the report via the appropriate OfS channel (portal and email)
5. Inform the Executive Committee, QCA Committee, and, consequently, the Board of Governors at the next scheduled meeting or earlier if urgent

Staff involved in safeguarding, compliance, or leadership changes must notify the Prevent Lead immediately when a reportable matter arises.

The Prevent Lead will own a central ‘Prevent Evidence Register’ within the Automated Governance System (AGS). This register serves as the single institutional record of Prevent-related evidence and assurance, incorporating the following component sub-registers:

1. Student-at-Risk Register – records referrals and support cases raised under the Safeguarding and Prevent Policy, including outcomes and follow-up actions.
2. Prevent Training Log – captures quantitative and qualitative data on staff and student training completion, survey data, and awareness activities.
3. Event Register – documents all external speaker and event approvals, risk assessments, mitigations, and outcomes in accordance with the External Speakers and Events Policy.
4. Digital Risk Register – records any Prevent or safeguarding risks arising from online activity, filtering and monitoring actions, and digital incident reviews under the IT and Digital Safeguarding Policy.
5. External Engagement Log – documents all formal contact and collaboration with external Prevent partners, including the Office for Students, the regional HE/FE Prevent Coordinator, Channel Panels, and local safeguarding networks.
6. Material Change Record – captures any significant organisational or policy changes relevant to Prevent compliance, recorded through the AGS in line with the Material Change Notification Procedure.
7. Prevent Research Ethics Register - records research ethics applications engaging the Prevent duty.

The Prevent Evidence Register will form the evidential basis for the annual Prevent report and return to the Office for Students (OfS), and will be updated continuously throughout the academic year, under the ownership of the Prevent Lead. It will be also reviewed semesterly by the Executive Committee, and subject to semesterly verification by the QCA Committee as part of its reporting to the Board of Governors.

The School conducts an annual self-assessment of Prevent implementation as part of its institutional risk and compliance framework. This structured review ensures statutory alignment, supports continuous improvement, and provides assurance to governance bodies.

The process, led by the Prevent Lead, includes:

• Risk Assessment and Action Planning – evaluation of Prevent-related risks, with updates to the central Risk Register, review of mitigations, and development of the aannual report, risk assessment, and action plan.
• Training and Awareness Audit – analysis of staff and student training completion, effectiveness, and feedback.
• Activity and Incident Review – examination of Prevent activity logs within the AGS, including the Event Register, Student-at-Risk Register, and Digital Risk Register, as well as any incidents, referrals, or complaints.
• Governance and Reporting Evaluation – assessment of reporting lines, escalation routes, and Prevent-related decision-making across the Executive Committee, Academic Board, and QCA Committee.
• Engagement and Feedback – consultation with students and staff through surveys, focus groups, or governance representation to inform proportional improvements.

Findings are compiled into an internal Prevent Self-Assessment Report, which identifies areas of good practice, vulnerabilities, and actions required. The report and accompanying annual Prevent risk asssessment and action plan are reviewed by the Executive Committee, scrutinised by the Quality, Compliance and Audit (QCA) Committee, with comments from the Academic Board for freedom of speech and academic freedom, and formally approved by the Board of Governors as part of the School’s Prevent Assurance Cycle.

As part of the annual self-assessment, the School will conduct hypothetical scenario testing to evaluate how staff would respond to Prevent-related risks. Scenarios may include:

• An external speaker proposing controversial content

• A safeguarding referral for potential radicalisation

• IT misuse involving extremist material

• A student expressing views that cause concern among peers

Findings will be discussed in small-group workshops or working groups, with outcomes documented and used to refine procedures and training content.

The School will use feedback from Prevent Review Meetings (PRMs), internal audits, or external quality reviews to update its policies, procedures, and risk assessment. Any recommendations from OfS engagement or sector evaluations must be recorded, reviewed by the Executive Committee, and acted upon within a defined timeframe.

Where possible, the School will participate in sector-wide activities led by the OfS or related bodies, including:

• Thematic reviews or deep dives on topics such as staff training or welfare

• Case-sharing workshops and peer-learning events

• Pilot studies or evaluation frameworks linked to Prevent

Participation is coordinated by the Prevent Lead and recorded in the School’s Prevent activity log.

The School implements this policy in accordance with its obligations under the Equality Act 2010 and the Human Rights Act 1998. All Prevent-related and safeguarding activity will be applied in a proportionate and equitable manner, ensuring that no student, member of staff, or visitor is treated less favourably on the basis of protected characteristics or personal beliefs. Decisions made under this policy will always balance safeguarding responsibilities with the School’s commitments to equality, inclusion, academic freedom and freedom of speech.

The School implements procedures for the regular review and updating of its safeguarding policy. This includes scheduled evaluations at least annually and mechanisms for gathering feedback from students and staff, such as surveys and focus groups. These processes ensure that the policy remains effective, relevant, and responsive to the changing needs of the School community.