1.4 Code of conduct
All adults who work with or have contact with students must maintain professional boundaries and act in a manner that promotes the safety and wellbeing of students at all times.
Staff and other adults working with students must:
- Treat all students with dignity and respect.
- Recognise that adults working with students are in a position of trust.
- Act as positive role models and maintain professional behaviour at all times.
- Avoid inappropriate physical contact or behaviour that could be misinterpreted.
- Maintain appropriate professional boundaries and avoid developing personal relationships with students.
- Use appropriate language and behaviour in all interactions with students.
- Ensure that any communication with students is conducted through approved channels and in accordance with organisational guidance.
- Avoid situations where they are alone with a student in enclosed spaces where possible.
- Respect students’ privacy, particularly in accommodation settings.
- Report any safeguarding concerns immediately to the Designated Safeguarding Lead.
Adults working with students must not engage in any form of inappropriate relationship or behaviour that could place students at risk. Under section 16 of the Sexual Offences Act 2003, it is a criminal offence for an adult in a position of trust to engage in sexual activity with a person under the age of 18. This applies even if the relationship is consensual, and even if the adult does not directly teach the child. Staff behaviour policies must reflect this requirement.
All forms of harassment and sexual misconduct including sexual harassment, sexual violence, and the non-consensual sharing of nude or semi-nude images are expressly prohibited and will be treated as serious disciplinary and safeguarding matters. The Group’s full framework for preventing and responding to harassment and sexual misconduct, including reporting routes, support available, investigation procedures, and the definitions of consent and misconduct, is set out in the Student Harassment and Sexual Misconduct Policy and Procedures (version 1.1, reviewed June 2025). All staff and students are expected to be familiar with that policy. Where a concern involves a student under the age of 18 or a vulnerable adult, safeguarding duties under this policy take precedence and the DSL must be informed immediately.
2. Roles and Responsibilities
Safeguarding is the responsibility of everyone working within Malvern International PLC and its subsidiaries. All employees and individuals working on behalf of the organisation are in positions of trust and must act in a way that promotes the safety and wellbeing of students.
The organisation maintains a clear safeguarding governance structure to ensure that safeguarding and Prevent responsibilities are effectively managed across all operations. This structure ensures that safeguarding concerns can be identified, reported and escalated appropriately.
In accordance with sections 157 and 175 of the Education Act 2002, and as an independent school, Malvern International PLC has a duty to safeguard and promote the welfare of children. This policy fulfils that duty and reflects the requirements of KCSIE September 2025.
2.1 Executive Board and Executive Sponsor
The Malvern International PLC Executive Board holds overall responsibility for ensuring that appropriate safeguarding arrangements are in place across the organisation.
Executive oversight of safeguarding and Prevent responsibilities is delegated to the Chief Operating Officer (COO), who acts as the Executive Sponsor for Safeguarding.
The COO is responsible for:
- providing executive leadership for safeguarding and Prevent compliance
- ensuring safeguarding policies and procedures are implemented across the Group
- ensuring appropriate resources are allocated to safeguarding arrangements
- receiving reports on safeguarding performance and significant incidents
- ensuring safeguarding governance is aligned with organisational risk management frameworks.
2.2 Group Safeguarding & Prevent Coordinator
The Group Safeguarding & Prevent Coordinator supports the organisation in coordinating safeguarding arrangements across all centres and operational divisions.
Responsibilities include:
- supporting the implementation of the Group Safeguarding and Prevent Policy
- providing guidance and support to Designated Safeguarding Leads (DSLs)
- monitoring safeguarding trends and concerns across centres
- supporting safeguarding training and awareness activities
- assisting with safeguarding audits, compliance reviews and reporting
- supporting the management of safeguarding records and documentation.
2.3 Designated Safeguarding Leads (DSLs)
Each centre or operational division appoints a Designated Safeguarding Lead (DSL) who has responsibility for safeguarding and Prevent matters within their area.
In accordance with KCSIE 2025 (para 102), the DSL must be an appropriate senior member of staff from the leadership team. The DSL’s safeguarding responsibilities — including lead responsibility for online safety and understanding of the organisation’s filtering and monitoring systems — must be explicit in their job description. The proprietor must not be appointed as DSL.
The DSL acts as the primary contact for safeguarding concerns and is responsible for:
- receiving and responding to safeguarding disclosures or concerns
- ensuring safeguarding procedures are followed
- maintaining child protection files for each student, held separately from the main student file, and ensuring safeguarding records are accurate, secure and complete
- making referrals to appropriate external agencies where required
- providing advice and guidance to staff on safeguarding matters
- supporting staff in responding to safeguarding concerns
- liaising with partner institutions where programmes operate within university premises
- ensuring that, where a student transfers to another school or college, the child protection file is transferred to the receiving DSL within 5 working days for an in-year transfer, or within the first 5 days of the start of a new term, and sent separately from the main student file
- taking lead responsibility for online safety, including understanding and overseeing the organisation’s filtering and monitoring systems, in line with KCSIE 2025.
Deputy Designated Safeguarding Leads may be appointed to provide support and cover when the DSL is unavailable.
Any deputy DSL must be trained to the same standard as the DSL. Deputies must be able to act with the full authority of the DSL in their absence.
Allegations involving the DSL or Deputy DSL: Where an allegation is made against the DSL or Deputy DSL, this must be referred to the Executive Sponsor (COO) and the Local Authority Designated Officer (LADO) must be contacted within one working day. Where the allegation involves the sole proprietor, it must be reported directly to the LADO without involving the proprietor. In no circumstances should the subject of an allegation be involved in managing or investigating it.
2.4 Senior Management and Centre Leadership
Centre Directors, Academic Managers and other senior leaders are responsible for implementing safeguarding procedures within their operational areas.
Their responsibilities include:
- Ensuring that staff understand and follow safeguarding procedures.
- Ensuring that safeguarding information is provided to students during induction.
- Supporting the DSL in managing safeguarding concerns.
- Ensuring that appropriate supervision and welfare arrangements are in place for students, particularly those under the age of 18.
- Working collaboratively with partner institutions where programmes are delivered within external premises.
- Promoting a safeguarding culture where concerns can be raised and addressed appropriately.
Allegations involving the Principal or Centre Director: Where an allegation is made against the Principal or Centre Director, this must be referred to the Executive Sponsor (COO) and the Local Authority Designated Officer (LADO) must be contacted within one working day. Where the allegation involves the sole proprietor, it must be reported directly to the LADO without involving the proprietor. In no circumstances should the subject of an allegation be involved in managing or investigating it.
2.5 All Staff, Volunteers, Contractors and Agency Workers
All individuals working on behalf of the Group share responsibility for safeguarding students.
All staff must:
- Be familiar with this policy and understand their safeguarding responsibilities.
- Have read and understood Part One (or Annex A, if appropriate) of KCSIE September 2025 — provided at induction and updated annually.
- Remain vigilant to possible signs of abuse, harm or welfare concerns.
- Follow the Group’s Code of Conduct when interacting with students.
- Report any safeguarding concern immediately to the DSL or Deputy DSL.
- Record safeguarding concerns accurately and promptly in accordance with reporting procedures.
- Participate in safeguarding training and updates appropriate to their role.
3. Training and Induction
Malvern International PLC is committed to ensuring that all employees and individuals working with students have the knowledge and skills required to safeguard students effectively.
3.1 Induction Training (Level 1 – All Staff)
All employees, volunteers, agency workers and relevant contractors must receive Level 1 safeguarding training as part of their induction before working with students.
This training ensures that staff understand:
- The organisation’s Safeguarding and Prevent Policy
- Their personal safeguarding responsibilities
- The role of the Designated Safeguarding Lead (DSL) and the identity of the DSL and deputies
- How to recognise potential safeguarding concerns
- How to report concerns or disclosures
- Appropriate professional boundaries and behaviour when working with students
Where individuals work directly with students, they must receive Part One or Annex A (a condensed version) of Keeping Children Safe in Education (KCSIE) September 2025 as part of their induction. A record of this must be retained. Staff must confirm in writing that they have read and understood this guidance.
3.2 Advanced Safeguarding Training (Levels 2-3)
Staff with designated safeguarding responsibilities must receive more advanced safeguarding training appropriate to their role.
Level 2 Training
Typically required for staff who have significant welfare responsibilities or who support safeguarding processes.
Level 3 Training
Required for the Designated Safeguarding Lead (DSL) and Deputy DSLs. Level 3 training ensures that DSLs are able to manage safeguarding disclosures, make referrals, advise staff, manage records and oversee procedures.
3.3 Refresher and Update Requirements
- Level 1 training should be refreshed at least annually.
- Level 2 and Level 3 safeguarding training should be refreshed every two years or in accordance with best practice guidance.
- Additional safeguarding updates may be provided periodically to reflect changes in legislation, guidance or emerging risks.
Training updates may include areas such as:
- Child Sexual Exploitation (CSE)
- Female Genital Mutilation (FGM)
- Prevent Duty and radicalisation risks
- Peer-on-peer (child-on-child) abuse
- Online safety and digital safeguarding
- Honour-based abuse or forced marriage
- Child criminal exploitation (CCE) and county lines
- Serious violence and knife crime
- Misinformation, disinformation and conspiracy theories as safeguarding harms (KCSIE 2025, para 135)
- Risks from generative AI tools and online platforms
- Safeguarding of students with additional vulnerabilities.
3.4 Online Safety, Filtering and Monitoring
As learning and communication increasingly take place through digital platforms, safeguarding also includes ensuring that students are protected from harm online.
The Group will implement appropriate filtering and monitoring systems where relevant to help safeguard students when using organisational systems and networks. In accordance with KCSIE 2025 (para 143), filtering and monitoring requirements apply to the use of generative AI tools in educational settings. The DSL holds lead responsibility for understanding and overseeing filtering and monitoring arrangements. Staff should refer to the DfE’s guidance on the use of generative AI in education (2025) when using AI tools with or for students.
Employees must ensure that:
- communication with students takes place through authorised organisational platforms
- online teaching environments maintain appropriate professional boundaries
- any safeguarding concerns arising through digital interaction are reported in accordance with safeguarding procedures.
3.5 Relationships, Sex and Health Education (RSHE)
Revised RSHE statutory guidance was published by the Department for Education in July 2025, for implementation from September 2026. Schools and colleges should be aware of this timeline and ensure that curriculum and safeguarding arrangements are updated accordingly when the new guidance comes into effect. The DSL should liaise with the Academic Manager to ensure that RSHE content aligns with safeguarding priorities.
4. Safe Recruitment of Employees
Malvern International PLC is committed to implementing robust recruitment procedures to ensure that all employees and individuals working with students are suitable to do so.
4.1 Recruitment Process
All recruitment activities must reflect the Group’s commitment to safeguarding. During the recruitment process:
- Candidates may be asked to explain any gaps in employment history.
- Candidates must provide appropriate references from previous employers.
- Referees will be asked specifically whether they have any concerns regarding the candidate working with children or young people.
- Proof of identity and relevant qualifications must be verified.
- Where appropriate, candidates may be asked to complete a criminal self-declaration.
Employment offers are conditional upon satisfactory completion of all required checks.
4.2 DBS Checks, Barring Checks and Background Verification
In accordance with KCSIE 2025 (Part Three) and the Safeguarding Vulnerable Groups Act 2006, all required pre-appointment checks must be completed and recorded on the Single Central Record (SCR) before an individual commences work. The following checks are required:
- Enhanced Disclosure and Barring Service (DBS) check — required for all staff working with children in regulated activity
- Children’s Barred List check — this is a SEPARATE required check, recorded as a distinct entry on the SCR.
- Prohibition from Teaching check required for all teaching staff
- Section 128 Direction check required for all individuals in management positions at independent schools. This check confirms the individual is not prohibited from taking part in the management of an independent school.
- Overseas criminal records check / Certificate of Good Conduct required for all staff who have lived or worked outside the United Kingdom, regardless of how long ago. The relevant embassy or government authority for each country of residence must be contacted. This must be recorded on the SCR.
- DBS Update Service verification, where applicable
- Right to work check
- Identity verification
- Qualifications check (all roles)
- References at least two, one from the most recent employer
Employees must normally receive satisfactory clearances before commencing work. In exceptional circumstances where a DBS certificate is pending, a risk assessment must be undertaken and appropriate supervision arrangements must be implemented until the check is completed. The children’s barred list check must always be completed before the individual commences work — there are no exceptions to this requirement.
Agency and supply staff: Where the Group engages agency or supply staff to work with children, the agency must confirm in writing that all required checks (including enhanced DBS with barred list check) have been carried out, and the date of those checks. The Group must verify this confirmation and retain written evidence. The SCR must include a record for all agency staff working with students, including those engaged for a single day.
Volunteers and temporary workers: All volunteers and temporary workers who will have unsupervised access to students must be subject to the full range of applicable checks before commencing work. A risk assessment must be undertaken for any volunteer working in a supervised capacity where checks have not been completed.
4.3 Single Central Record (SCR)
The organisation maintains a Single Central Record (SCR) of all recruitment and vetting checks. The SCR must include a record for every person working at the organisation, including employees, agency staff, volunteers and contractors. The SCR must record, for each person: identity check; enhanced DBS check (with barred list) date; children’s barred list check date (recorded separately); prohibition from teaching check date; Section 128 check date (for management roles); overseas checks (where applicable); right to work check; qualifications check; references received. The SCR must be available for inspection at all times.
4.4 General HR procedures
The Group maintains appropriate human resources procedures to support safeguarding and ensure ongoing suitability of staff working with students. These procedures include induction processes, ongoing monitoring of professional conduct, and procedures for reporting concerns relating to staff behaviour.
5. Student Enrolment and Welfare
5.1 Individuals and Groups Enrolments
For students under the age of 18, written parental or guardian consent must be obtained prior to enrolment. Parents or guardians must provide emergency contact details. Information relating to medical conditions, allergies or additional support needs must be disclosed where relevant.
In line with KCSIE 2025 (para 101), the organisation will, where reasonably possible, hold more than one emergency contact number for each student. This is particularly important for students under 18 and provides additional options to make contact with a responsible adult where a student is absent and a welfare or safeguarding concern arises.
Where students enrol as part of organised groups, appropriate communication will take place with the responsible group leader or organisation to ensure safeguarding responsibilities are clearly understood.
5.1.1 Age-differentiated Safeguarding Provisions
Malvern International PLC recognises that while all students under the age of 18 are children in law and are afforded full safeguarding protections under this policy, the practical application of those protections must be proportionate to the age and maturity of the individual student. In particular, students aged 16 require an additional layer of active oversight and parental or guardian involvement compared to students aged 17. This distinction is reflected in the provisions set out below and must be applied consistently across all centres.
Students aged 16
Students aged 16 are subject to the following mandatory provisions in addition to all standard safeguarding measures applicable to under-18s:
- Written parental or guardian consent must be obtained before enrolment, before any change to accommodation arrangements, and before participation in any overnight or extended off-site activity.
- A named parent, guardian or responsible adult must be identified for each student aged 16 and their contact details recorded on enrolment. This contact must be notified promptly in any of the following circumstances: unexplained absence; welfare concern; safeguarding referral; medical incident; any change to the student’s accommodation or supervision arrangements; or any situation where the DSL considers notification appropriate.
- Contact with the named parent, guardian or responsible adult must be attempted and the outcome documented within 24 hours of any of the above circumstances arising. The DSL must be informed if contact cannot be established within this timeframe.
- Where a student aged 16 is accommodated in homestay for a period of 28 days or more, the local authority must be notified of the arrangement in accordance with KCSIE 2025 (Annex D). The DSL is responsible for identifying such arrangements and ensuring notification is made.
- Supervision ratios for off-site and social activities must reflect the age of the group. Where a group includes students aged 16, the supervising staff-to-student ratio must be no less than [1:15], and a risk assessment must be completed and approved by the DSL or a senior leader before the activity takes place.
- Students aged 16 must be given a clear named point of contact at their centre and must know how to reach that person at all times, including outside teaching hours.
Students aged 17
Students aged 17 are subject to all standard safeguarding measures applicable to under-18s. While a greater degree of independence is recognised as appropriate for this age group, the following provisions apply:
- Written parental or guardian consent must be obtained before enrolment.
- Emergency contact details for a parent, guardian or responsible adult must be held on file and kept up to date.
- The DSL should use their professional judgement when deciding whether to notify a parent or guardian in connection with a welfare concern involving a student aged 17, giving appropriate weight to the student’s wishes while prioritising their safety and wellbeing. Where a safeguarding referral is made to an external agency, the parent or guardian should normally be informed unless doing so would place the student at greater risk.
- Students aged 17 must be given a clear named point of contact at their centre.
General principle
Where any doubt exists about whether a situation warrants parental or guardian notification, the presumption should always be in favour of notification, particularly for students aged 16. Staff should never allow concerns about inconvenience, potential parental reaction, or the student’s request for privacy to override their safeguarding duty. The DSL’s decision on notification must be documented, including where a decision is made not to notify.
5.2 Accommodation and Homestay Arrangements
Where accommodation is arranged by the Group, appropriate measures are implemented to ensure that accommodation providers offer safe and suitable environments for students. This may include assessment and approval of accommodation providers, background checks where appropriate, provision of guidance to hosts regarding safeguarding expectations, and ensuring that hosts understand their responsibilities when accommodating students under 18.
5.3 Airport Transfers and Travel
Where airport transfer services are provided for students under the age of 18, appropriate arrangements must be confirmed in advance. Drivers or representatives must be appropriately identified. Clear procedures must be in place for managing delays, missed connections or unexpected issues.
5.4 Student Welfare Monitoring
Malvern International PLC provides pastoral and welfare support to all students throughout their programme of study. All staff have a responsibility to remain alert to welfare concerns and to report them promptly to the Designated Safeguarding Lead (DSL).
Staff may monitor student welfare through regular contact during classes or activities, one-to-one meetings where appropriate, observation of changes in behaviour or presentation, and communication with accommodation providers or homestay hosts where relevant. Any welfare concern, however minor it may appear, must be reported to the DSL rather than managed independently by the member of staff who identified it.
Where a welfare concern involves a student under the age of 18, the DSL must assess the concern and determine the appropriate level of response. In doing so, the DSL must have regard to the age of the student, in accordance with Section 5.1A of this policy.
Students aged 16 — additional welfare monitoring provisions
For students aged 16, the following enhanced welfare monitoring measures apply:
- Welfare checks must be conducted at regular intervals throughout the student’s programme. The frequency of these checks must be documented on enrolment and must be no less than weekly during term time.
- Any change in behaviour, mood, presentation or engagement that gives cause for concern must be reported to the DSL on the same day it is observed. The DSL must consider whether the student’s named parent, guardian or responsible adult should be contacted in accordance with Section 5.1A.
- Where a student aged 16 is living in homestay accommodation, the DSL or a designated welfare officer must maintain regular contact with the accommodation provider to confirm the student’s welfare. Any concern raised by the accommodation provider must be treated as a safeguarding concern and escalated accordingly.
- Where a welfare concern cannot be resolved through internal support, or where the student’s wellbeing appears to be deteriorating, the DSL must consider whether an early help referral or a referral to children’s social care is appropriate, and must notify the student’s parent, guardian or responsible adult unless doing so would place the student at greater risk.
Students aged 17
For students aged 17, welfare monitoring follows the standard provisions set out above. The DSL must use professional judgement in determining the level of parental or guardian involvement appropriate to the specific concern, giving appropriate weight to the student’s own views while prioritising their safety and wellbeing.
All students under 18
All welfare concerns involving students under the age of 18 must be recorded on the student’s child protection file in accordance with Section 10 of this policy, regardless of whether a formal referral is made. The record must include the nature of the concern, the action taken, and the reasons for any decision made including decisions not to escalate or to notify a parent or guardian.
5.5 Attendance and Absence Procedures
Attendance is monitored for all students to ensure continued engagement with their studies and to identify potential welfare concerns at the earliest opportunity. The organisation complies with its obligations to notify UKVI of student absences in accordance with sponsor licence requirements.
Where a student fails to attend classes without prior notification or explanation, the following steps must be taken:
- Reasonable attempts must be made to contact the student directly using the contact details held on file.
- If contact with the student cannot be established within a reasonable timeframe, the accommodation provider, homestay host or group leader must be contacted where applicable.
- A welfare check must be initiated where the student’s whereabouts remain unknown or where the circumstances of the absence give cause for concern.
- All attempts to make contact and the outcomes of those attempts must be documented.
Students aged 16 — additional absence provisions
For students aged 16, unexplained absence triggers mandatory additional steps beyond those set out above:
- Any unexplained absence must be treated as a potential safeguarding concern from the outset and reported to the DSL immediately on the same day the absence is noted.
- The DSL must ensure that the student’s named parent, guardian or responsible adult is contacted within 24 hours of an unexplained absence, in accordance with Section 5.1A. The outcome of that contact must be documented. If contact cannot be established with the parent or guardian, this must be escalated by the DSL without delay.
- Where a student aged 16 is absent and their whereabouts are unknown after reasonable attempts to locate them, the DSL must consider whether a referral to children’s social care or the police is required. This assessment must be made promptly and must not be deferred pending further information.
- UKVI must be notified of any absence in accordance with the organisation’s sponsor licence obligations, and this must be recorded.
Students aged 17
For students aged 17, unexplained absence must be reported to the DSL on the same day. The DSL must use professional judgement in determining whether parental or guardian notification is appropriate, giving consideration to the student’s circumstances, the nature of the absence, and any prior welfare concerns. Where there is any doubt, the presumption is always in favour of notification and escalation.
All students under 18
Where a pattern of absence is identified, the DSL must consider whether this indicates a wider welfare or safeguarding risk and whether an early help assessment or referral to statutory services is appropriate. All absence-related safeguarding actions must be recorded on the student’s child protection file in accordance with Section 10.
5.6 Social Activities, Alcohol, Tobacco and Supervision
The Group may organise social and extracurricular activities as part of students’ learning and cultural experience. Where students under 18 participate, appropriate supervision ratios must be maintained, risk assessments must be undertaken, and staff supervising activities must be aware of safeguarding responsibilities. Students under 18 must comply with applicable laws relating to alcohol, tobacco and other controlled substances.
6. Safety Measures and Conduct
6.1 Teaching and Classroom Interactions
Teaching staff must maintain safe and respectful classroom environments where students feel supported and protected. Staff must treat all students with dignity and respect, maintain professional boundaries, avoid situations where they are alone with a student in enclosed spaces where possible, and challenge inappropriate behaviour or language.
6.2 Communication with Students
Communication between staff and students must remain professional and appropriate at all times. Staff must use approved organisational communication channels, avoid sharing personal contact details with students unless required for legitimate operational reasons, and avoid engaging in private or secretive communications with students.
6.3 Safety on Site
The Group maintains procedures to ensure that teaching and operational environments remain safe for students, staff and visitors. Safety measures may include supervision of students during organised activities, visitor management procedures, safe access to buildings and facilities, and reporting of hazards or incidents.
6.4 Online Conduct and E-Safety
The Group recognises that digital technologies are an integral part of teaching and communication. Safeguarding therefore extends to online environments where students may interact with staff or access educational content.
Emerging risks associated with artificial intelligence technologies, online platforms and digital manipulation are recognised as part of the evolving safeguarding landscape and will be addressed through staff training and safeguarding guidance. Staff should be aware of the DfE guidance on the use of generative AI in education (2025). Concerns relating to online contact with children, including Child Sexual Exploitation Online, should be referred to CEOP Education (formerly Thinkuknow now CEOP Education following rebranding by the National Crime Agency) at www.ceopeducation.co.uk.
6.5 Filtering and Monitoring Systems
Where organisational digital systems are used by students, the Group implements appropriate filtering and monitoring measures designed to help safeguard students from harmful or inappropriate online content. In accordance with KCSIE 2025, these systems must cover the use of generative AI tools where these are accessed via organisational networks. The DSL is responsible for ensuring filtering and monitoring arrangements are in place, understood, and reviewed regularly. Schools and colleges can use the DfE’s ‘Plan Technology for your school’ service to self-assess against the filtering and monitoring standards.
6.6 Support for Gender Questioning Students
The Group recognises that some students may be exploring questions relating to gender identity or expression. Staff must ensure that all students are treated with respect and sensitivity and that support is provided in a manner that prioritises the student’s wellbeing and safety. Where safeguarding concerns arise in relation to a student’s welfare, the matter should be referred to the DSL. The DfE has indicated that revised statutory guidance on gender questioning children will be published in due course. This section will be updated in line with any new guidance when published, as signposted in KCSIE 2025.
7. Prevent Duty and Extremism
Malvern International PLC recognises its responsibility under the Counter-Terrorism and Security Act 2015 to have due regard to the need to prevent individuals from being drawn into terrorism. Radicalisation can occur through many forms of contact, including online interaction, social networks, peer influence or exposure to extremist ideologies.
Staff should also be aware that misinformation, disinformation and conspiracy theories are recognised safeguarding harms in KCSIE 2025 (para 135) and may contribute to the radicalisation process. Where students are found to be engaging with or promoting content of this nature, this should be raised with the DSL.
7.1 Identification and Prevention of Radicalisation
While there is no single indicator of radicalisation, staff should be aware of possible signs such as:
- significant changes in behaviour, beliefs or attitudes
- expressions of extremist views or intolerance
- access to extremist materials or online content
- isolation from peers or support networks
- attempts to impose extremist views on others.
- engagement with or promotion of misinformation, disinformation or conspiracy theories
Staff must approach concerns sensitively and avoid making assumptions about individuals based on their background, beliefs or personal characteristics.
7.2 Reporting Prevent Concerns
Any concerns that a student may be vulnerable to radicalisation or extremist influence must be reported immediately to the DSL. The DSL will consider the information and determine the most appropriate course of action, which may include referral to appropriate external agencies including Prevent partners. All Prevent-related concerns must be recorded in line with safeguarding record-keeping procedures.
8. Forms of Abuse and Harm
8.1 Definition of Abuse
Abuse is a form of maltreatment that results in harm or the risk of harm to a child or adult at risk. Abuse can occur as a single incident or as a pattern of behaviour over time. It may involve the misuse of power, authority or trust.
8.2 Recognising Signs of Abuse
Possible indicators may include: unexplained injuries or physical harm; sudden changes in behaviour, mood or personality; withdrawal from social interaction; expressions of fear, distress or anxiety; inappropriate sexualised behaviour or knowledge; persistent absence; signs of neglect or lack of care.
8.3 Types of Abuse
Physical Abuse
Physical abuse involves deliberately causing physical harm to a person.
Emotional Abuse
Emotional abuse involves persistent behaviour that harms a person’s emotional wellbeing or sense of self-worth. This may include intimidation, humiliation, threats, bullying or controlling behaviour.
Sexual Abuse
Sexual abuse involves forcing or encouraging a person to participate in sexual activities without consent. This may include inappropriate touching, sexual exploitation, grooming or exposure to sexual material.
For the full framework governing the reporting and investigation of sexual misconduct and harassment between students, or between students and staff, see the Student Harassment and Sexual Misconduct Policy and Procedures.
Neglect
Neglect occurs where a person’s basic physical or emotional needs are not adequately met.
Additional Safeguarding Risks
In addition to the main categories of abuse, safeguarding concerns may also include:
- Child Sexual Exploitation (CSE)
- Child Criminal Exploitation (CCE)
- Female Genital Mutilation (FGM)
- Forced marriage or honour-based abuse
- Bullying and cyberbullying
- Peer-on-peer (child-on-child) abuse
- Grooming or exploitation
- Online abuse or exploitation
- Controlling or coercive behaviour
- Serious violence, including knife crime and youth violence linked to county lines (KCSIE 2025)
- Misinformation, disinformation and conspiracy theories as safeguarding harms (KCSIE 2025, para 135)
- Upskirting: a criminal offence under the Voyeurism (Offences) Act 2019
- Consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery) — KCSIE 2025
- Initiation or hazing type violence and rituals, including where these involve an online element — KCSIE 2025
Where there are concerns about a young person’s own sexual thoughts or behaviours, staff can signpost to the Lucy Faithfull Foundation’s Shore Space service (www.shorespace.org.uk), which offers confidential support for young people concerned about their own or someone else’s sexual thoughts and behaviours (KCSIE 2025, Annex B).
Peer-on-Peer Abuse
Safeguarding concerns may arise where harm occurs between students. Peer-on-peer abuse may include bullying, harassment, sexual harassment, sexual violence or other harmful behaviours. Such behaviour must always be taken seriously and addressed through safeguarding procedures.
8.4 Harm to Adults at Risk
Safeguarding responsibilities also extend to adults at risk. Forms of harm affecting adults at risk may include: financial exploitation; psychological abuse; discriminatory abuse; neglect or self-neglect; coercion or manipulation. Staff must report concerns relating to adults at risk in the same way as safeguarding concerns involving children.
9. Handling Disclosures, Concerns and Allegations
9.1 Low-Level Concerns
A low-level concern refers to behaviour by an adult working with students that may be inconsistent with the organisation’s code of conduct but does not meet the threshold for a formal safeguarding allegation. Such concerns should be reported to the DSL or an appropriate senior manager, recorded, and reviewed to identify any patterns of behaviour before they escalate.
9.2 Handling a Disclosure
If a student makes a disclosure, staff should: listen carefully and remain calm; take the disclosure seriously; avoid asking leading or investigative questions; reassure the student that they have done the right thing; and explain that the information will need to be shared with the appropriate safeguarding lead. Staff should not promise confidentiality or attempt to investigate the matter themselves.
As soon as possible after the disclosure, the staff member must record the information accurately and report the concern to the DSL.
9.3 Reporting Safeguarding Concerns
All safeguarding concerns may be reported directly to the Designated Safeguarding Lead (DSL) at the relevant centre, or submitted to the Group’s central safeguarding inbox at safeguarding@malvernplc.com. This inbox is monitored and triaged by the Group Safeguarding & Prevent Coordinator, who holds responsibility for coordinating the Group’s response to all concerns received through this channel. The Chief Operating Officer (COO), as Executive Sponsor for Safeguarding, has oversight access to this inbox. Upon receiving a report, the Coordinator will acknowledge receipt, assess the concern, and liaise with the relevant DSL, centre leadership, and where necessary external agencies, in accordance with this policy. All reports submitted via this inbox are treated as confidential safeguarding documents and handled in accordance with the Group’s data protection obligations.
Staff are reminded that where a child is believed to be in immediate danger, the emergency services (999) must be contacted first. The safeguarding inbox is not a substitute for contacting the DSL directly in urgent situations.
Detailed guidance on how to make a report including what information to include, and important do’s and don’ts is set out in Annex G: How to Report a Safeguarding Concern.
9.4 Managing Allegations Involving Staff
Allegations that a member of staff has behaved in a way that has harmed a student, may have harmed a student, may have committed a criminal offence against a student, or behaved in a way that indicates they may not be suitable to work with children must be taken seriously and reported immediately to the DSL or appropriate senior leader.
Where allegations meet the safeguarding harm threshold, the organisation must contact the Local Authority Designated Officer (LADO) within one working day. The LADO must be involved in all cases where an allegation is made against a person who works with children and the allegation meets the harm threshold. The LADO’s contact details for the relevant local authority must be recorded in this policy and kept accessible to the DSL at all times. Please see annex G.6 for LADO contacts at each site.
Appropriate action may include temporary suspension of duties where necessary, internal safeguarding investigations, and referral to external safeguarding agencies or law enforcement where appropriate. The organisation will ensure that allegations are managed fairly and in accordance with safeguarding procedures and employment policies.
9.5 Early Help and Multi-Agency Working
Where appropriate, the organisation may work with local safeguarding authorities, social services, police, healthcare professionals, and partner institutions. Early intervention may help prevent concerns from escalating and ensure that students receive appropriate support. The organisation is committed to cooperating with safeguarding authorities and supporting multi-agency approaches to protecting children and adults at risk.
10. Record Keeping and Information Storage
Accurate and secure record keeping is an essential component of effective safeguarding practice. All safeguarding records must be handled in accordance with the organisation’s data protection obligations and relevant safeguarding legislation.
10.1 What Must Be Recorded
All concerns, discussions and decisions made and the reasons for those decisions should be recorded in writing. This will also help if/when responding to any complaints about the way a case has been handled. Records should include:
- a clear and comprehensive summary of the concern
- details of how the concern was followed up and resolved
- a note of any action taken, decisions reached and the outcome
- the reasons for the decisions made — including decisions not to refer to children’s social care
In line with KCSIE 2025, it is good practice — and expected by ISI inspectors — to keep concerns and referrals in a SEPARATE child protection file for each child. This file must be held separately from the main student file. Access must be restricted to the DSL, Deputy DSL(s), and the Group Safeguarding & Prevent Coordinator where appropriate.
10.2 Location and Security of Records
Safeguarding records must be stored securely, either within a restricted digital safeguarding system or in secure physical storage where access is controlled. Access to safeguarding records is restricted to the DSL, Deputy DSLs, and the Group Safeguarding & Prevent Coordinator.
10.3 Child Protection File Transfer
When a student transfers to another school or college, the DSL must ensure that the child protection file is transferred to the receiving institution’s DSL as soon as possible, and: (a) within 5 working days for an in-year transfer; or (b) within the first 5 days of the start of a new term. The file must be sent SEPARATELY from the main student file, directly to the DSL at the receiving institution. When a student transfers, the DSL should also consider whether it would be appropriate to share any information with the new school or college in advance of the start date particularly where there are ongoing concerns.
10.4 Disclosure of Information Requests
Safeguarding information is sensitive and confidential. Information relating to safeguarding concerns will only be shared where it is necessary to protect the safety and wellbeing of a student or to comply with legal obligations. Data Subject Access Requests (DSARs) will be managed in accordance with the organisation’s data protection procedures, with appropriate consideration given to protecting the confidentiality and safety of individuals concerned.
Requests can be made at gdpr@malvernplc.com.
10.5 Compliance with Data Protection Legislation
The organisation processes safeguarding information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Personal data is processed lawfully, fairly and transparently; information is collected only for legitimate safeguarding purposes; access is limited to authorised personnel; and safeguarding records are retained in accordance with the organisation’s data retention policies.
11. Policy Review, Monitoring and Compliance
11.1 Policy Review
This Safeguarding and Prevent Policy will be reviewed annually, or sooner if required due to changes in safeguarding legislation or statutory guidance, organisational changes, safeguarding incidents or emerging risks, or updates to relevant government guidance. This policy must be reviewed and updated each September to align with any new version of Keeping Children Safe in Education.
Policy reviews will normally be coordinated by the Group Safeguarding & Prevent Coordinator, in consultation with Designated Safeguarding Leads and senior leadership. Updates to the policy must be approved through the organisation’s governance framework.
11.2 Monitoring and Oversight
Safeguarding arrangements are monitored through safeguarding reporting from DSLs, review of safeguarding records and trends, safeguarding training compliance monitoring, internal compliance reviews or audits, and feedback from staff and students.
11.3 Governance and Reporting
Safeguarding oversight is maintained through the organisation’s governance structure. The COO acts as the Executive Sponsor for Safeguarding and Prevent. Significant safeguarding matters may be reported to the Malvern International PLC Executive Board as part of organisational governance and risk management processes.
11.4 Continuous Improvement
Lessons learned from safeguarding incidents, internal reviews or external guidance will be used to strengthen safeguarding procedures, improve staff training and enhance the overall safeguarding culture within the organisation. All staff are encouraged to contribute to safeguarding improvements by raising concerns, sharing feedback and supporting the effective implementation of safeguarding procedures.
Policy Sign-off
