Key Information

Safeguarding Policy

Click here to download our Safeguarding Policy (2021)

Policy for Safeguarding

Columbia Primary School


This policy sets out our commitment to safeguarding and describes the systems in place to safeguard children in our school.


Safeguarding is what all of us do in many different ways to ensure the best outcomes for children at all times.  

Child protection is what we do when we act in response to a concern which has been raised about a child in order to protect that child from harm.


Safeguarding Team:

Designated Safeguarding Lead: Julie Fountain (Assistant Head for Inclusion and Safeguarding)

Deputy Designated Safeguarding Lead: Oliver Woodward (Headteacher)

Deputy Designated Safeguarding Lead: Lesley Reynolds (Deputy Head)

Deputy Designated Safeguarding Lead: Hena Afsar (Pastoral Teaching Assistant)

Deputy Designated Safeguarding Lead: Barney Lom (Early Years Teacher)

Designated Safeguarding Governor:  Juliana Iwobi

Chair of Governors: Tom Best


The designated safeguarding leads can be contacted in the following ways:

  • Phone: 02077393835
  • Post: Columbia Primary School, Columbia Rd, London E2 7RG
  • Email: [email protected]


The safeguarding governor can also be contacted by post at the above address.


This policy is organised under 4 headings:

  • Columbia Primary School’s commitment to safeguarding
  • our shared responsibility,
  • climate and curriculum,
  • aspects of safeguarding which are unique to our school and local area,
  • training and awareness.  
  • Roles and responsibilities in our school
  • Systems and procedures
  1. Raising concerns.
  2. Keeping records. 
  3. Sharing information
  4. Monitoring 
  5. Attendance and exclusions
  6. Private fostering
  7. Issues which are covered in separate policies (Allegations against Staff, Physical Intervention, Whistleblowing, Use of cameras and phones, Safer Recruitment)

  • Vulnerable groups and issues of particular concern, including:
  • Children with SEN and/or disabilities
  • Children exposed to domestic abuse
  • Child sexual exploitation
  • Children missing education
  • Violence against women and girls
  • Peer on peer abuse (relate to behaviour policy)
  • Sexual harassment/sexual violence
  • Children who have been looked after
  • Child criminal exploitation
  • Children exposed to Extremism and/or at risk of Radicalisation
  • Homelessness


This policy is written in accordance with: 

  • Keeping Children Safe in Education 2021
  • ‘What To Do If You’re Worried A Child Is Being Abused’ 2015 
  • Safeguarding Disabled Children Practice Guidance, July 2009
  • Working Together to Safeguard Children 2018
  • Prevent Duty Guidance 2015


The safeguarding policy is linked to several others, each of which goes into detail about a specific aspect of our approach to maintaining a safe, respectful environment which values transparency, clear communication and fosters good relationships. 


The systems and practices detailed in these policies all contribute to this aim of Columbia’s; keeping children safe and well.  The safeguarding policy is underpinned by them and should be read with reference to them:


Acceptable Use agreement,  Managing allegations against staff,  Anti-bullying,  Attendance,  Behaviour,  Code of Conduct,  Complaints procedure,  E-Safety, Equality,  Meeting medical needs,  Health and Safety,  Trips,  PSCHE (Personal, Social, Citizenship and Health Education),  Safer Recruitment,  Relationships and Sex Education and Health Education,  Physical Intervention,  Inclusion,  Whistle Blowing.

  • Columbia Primary School’s commitment to Safeguarding.

This section sets out our attitude to safeguarding and describes our approach to it.


We agree with the definition of safeguarding children as:


  • protecting children from maltreatment; 
  • preventing any impairment of children’s mental or physical health or development;
  • making sure that children grow up in circumstances which provide them with safe and effective care; and 
  • taking action to ensure the best possible outcomes for children. 


We practise Safer Recruitment and run rigorous checks on all adults (including other community users of our facilities) to ensure their suitability before they work with children.  See Safer Recruitment policy for detail.


Robust procedures are in place for responding to concerns raised by members of staff or volunteers who believe that a child has been abused or is at risk of abuse.  This includes procedures to cover any circumstance in which a member of staff is accused or suspected of abuse.  See section 3. Systems and Procedures; a. Raising concerns (page10)


(Abuse is when a child is hurt or harmed by another person in a way that causes significant harm to that child and which may have an effect on the child’s development or wellbeing.  Other definitions for terms which are commonly used in documents and conversations about safeguarding can be found in appendix 1 of this policy.


How we set the climate

We take full responsibility for the children’s safety and wellbeing while they’re in school and know that good communication is essential if we are to carry that responsibility out thoroughly.  Building good, respectful relationships is central to everything we strive to do; we make sure the climate is one in which children feel confident that adults will listen to them and take them seriously when they speak.


We talk to children explicitly about what they can do and the people they can go to for help if they are worried about something or in difficulty.  We understand the importance of being approachable because we want children to share their concerns.  We listen to them openly and calmly without judgement because we know that expressing shock or dismay could cause children to ‘shut down’.  In the event of them making a disclosure to us, we explain the actions we will take and ask them how they feel in order to reassure them and take their feelings into account.



Columbia Primary School is committed to being transparent and open when working with parents and carers. We always aim to work in partnership with families to keep children safe.  Through workshops, newsletters and parent meetings, we help parents to understand the school’s safeguarding duty.  This includes the need for safeguarding policies and procedures, information sharing and working with other agencies.  Parents should also ensure that the school has at least two emergency contacts for their child.


Other agencies

We are committed to building effective working relationships with all other agencies involved in safeguarding our pupils.  We aim to communicate well, respond promptly and attend or contribute to meetings relating to the families of our pupils.


What we teach

We aim to develop children’s awareness of the part they can play in keeping themselves safe.  There are several points in the PSCHE curriculum at which (amongst other things) children are taught about different situations and risks they will encounter and practise discerning for themselves what makes a safe and healthy choice.  The PSCHE curriculum is reviewed regularly to make sure it reflects current issues.


Our commitment to positive relationships is founded on respect for ourselves and one another, and good communication.  Adults model respect and care for one another.  This attitude underpins every aspect of school life and drives our planning throughout the curriculum.  Consequently, teachers talk to children about caring for their own well-being in many different contexts throughout the school year including 1:1, small group, whole class and whole school assemblies.


Columbia Primary School’s unique safeguarding context:

Tower Hamlets’ character and population is unique in the UK and Columbia Primary School, because of its location, is unusual within Tower Hamlets.  We take these factors into account when planning strategies to safeguard the children and adults at our school.


Our immediate local area is currently a hub of drug and gang activity.  Dealing and drug-related behaviour is visible on the streets around our school. This puts our children who live in the nearby area at risk of exposure to drugs and all the negative effects they can have on families and communities.  It also makes them vulnerable to grooming by (slightly older) gang members.


Tower Hamlets has been identified as high priority for support through the PREVENT strategy because of its long history of extremist political activity from left and right wing groups, its shifting immigrant populations and high profile instances of young people’s recruitment by an extremist Islamist group.


We work closely with the LBTH PREVENT co-ordinator and with Children’s Social Care to safeguard children and families who are already identified as being at risk but in addition to this all members of staff are alert to the signs which could indicate a cause for concern about any vulnerable child.


We have a number of families who come from areas of the world where FGM is practised.  Key members of staff have had specific training from the VAWG team and share the role of talking to families who might be affected by this with the DSL. 


Finally, because of our location, we have many children from families whose parents are highly educated, articulate and economically secure.  We are careful to monitor our own prejudices in order to be as alert to risk factors in these families as we are in all others. 


Training and awareness

We all agree that safeguarding children is our most important responsibility and that it is shared by every member of staff.  We expect every adult in school to be engaged with that responsibility at all times. 


The DSL and DDSLs attend high quality safeguarding training which is targeted at their role at least every 2 years.  They also have safer handling training every 2 years and safer recruitment training every 5 years.  In addition DSLs attend relevant training throughout the year according to need and opportunity in order to maintain a broad picture of current safeguarding issues. The designated safeguarding governor attends targeted training every 2 years and also attends the school’s termly INSET sessions.  


At the start of the school year all members of staff take part in INSET about

  • the staff Code of Conduct, including confidentiality,
  • the Behaviour policy,
  • who the Designated Safeguarding Leads are and what their role is,
  • procedures for when children are missing education,
  • when and how to raise a concern about a child See section 3. Systems and Procedures; a. Raising concerns.(page10)
  • the Whistleblowing policy.


In addition to this, all staff are required to have read Part 1 and Annex A of KSCIE 2021

and to have read and signed the Acceptable Use Agreement relating to use of ICT.


Members of staff and volunteers joining Columbia part-way through the year receive induction training which covers all these aspects.


In order to raise and maintain awareness of our duty to safeguard children, there is a fixed safeguarding item on the business meeting agenda every week.  All staff receive a text update of this.  This ensures that all adults have the same information.  

Staff also have safeguarding INSET three times a year as a fixed item on the school’s termly inset days.  These longer sessions facilitate greater depth of understanding and are used to learn about issues which are current, relevant to our context and/or of particular concern. All members of staff are required to attend.  These updates and inset sessions ensure that


  • all teaching, non-teaching staff, governors, volunteers are aware of our commitment to safeguarding children and of their personal responsibilities in identifying and reporting their concerns about children;
  • all staff are alert to signs of abuse and can recognize them;
  • all staff know what to do and to whom they should go if they have a concern.


  1. Roles and Responsibilities in our school.


This section sets out the specific responsibilities of key adults in relation to safeguarding.  They are:

  • The Headteacher
  • The Governing Body
  • Designated Safeguarding Lead and deputies
  • Office staff


The school (led by the Designated Safeguarding Lead) ensures that all action taken is in line with the Tower Hamlets SCP arrangements 2019. The role of the school within this procedure is to contribute to the identification, referral and assessment of children in need, including children who may have suffered, are suffering, or who are at risk of suffering, significant harm. The school may also have a role in the provision of services to children in need and their families.


The school’s role is NOT investigating safeguarding concerns.  Its role is to recognise and refer.


The Head teacher ensures that:

  • The policies and procedures adopted by the Governing Body to safeguard and promote the welfare of pupils are fully implemented and followed by all staff, including volunteers. The procedures laid down by the London Child Protection Procedures 5th Edition are followed.
  • Selection and appointment of staff and volunteers meet Safer Recruitment obligations.
  • A Designated Safeguarding Lead is in post.
  • Sufficient time and resources are made available to enable the Designated Safeguarding Lead to discharge their responsibilities, including attending inter-agency meetings, contributing to the assessment of pupils, supporting colleagues and delivering training as appropriate.
  • All staff and volunteers receive appropriate training which is updated at least annually. This includes ensuring that all staff understand the role of the Designated Safeguarding Leads.
  • All staff have read Part 1 and Annex A of Keeping Children Safe in Education 2021 and have signed to verify they have read, understood and will comply with all school policies and guidance, as well as Part 2 of the Teachers’ Standards: Personal and Professional Conduct.
  • All temporary staff, volunteers and visitors are made aware of the school’s safeguarding policy and arrangements.
  • All staff and volunteers feel safe about raising concerns about poor or unsafe practice in regard to the safeguarding and welfare of the pupils and such concerns will be addressed sensitively and effectively.
  • Parents/carers are aware of and have an understanding of the school’s responsibilities to promote the safety and welfare of its pupils.  A key part of this is meeting all parents in admissions interviews when their children are admitted to the school.  This applies to children who start at regular transition points and those who start at other points in the year.
  • Confidential child protection files are securely stored in a separate filing cabinet apart from normal pupil records and with access confined to the Designated Safeguarding Lead and the Deputy Designated Safeguarding Leads.  Recent child protection data is stored digitally and securely on CPOMS and this replaces the paper records.   


The Governing Body of the school will ensure that: 

  • A member of the Governing Body is identified as the Designated Governor for Safeguarding and receives appropriate training. The identified governor will provide the governing body with appropriate information about safeguarding and will liaise with the Designated Safeguarding Lead.
  • There is a senior member of the school’s leadership team who is designated to take strategic responsibility for safeguarding within the school.
  • The Designated Safeguarding Lead undertakes training, in addition to basic child protection training, and refresher training at two-yearly intervals.
  • The school’s safeguarding policy is regularly reviewed and updated and the school complies with local safeguarding procedures.
  • When the safeguarding policies are reviewed and shaped, the experiences and expertise of their staff will be taken into account.
  • The school operates safer recruitment and selection practices including appropriate use of references and checks on new staff and volunteers.
  • Procedures are in place for dealing with allegations of abuse against members of staff and volunteers and these are in line with local procedures.
  • All staff and volunteers who have regular contact with pupils receive appropriate training which is updated annually.
  • Appropriate filters and monitoring systems are in place that do not lead to unreasonable restrictions as to what children can be taught. In practice, an example of this would be making sure that the school does not block so much internet traffic that the children are then unable to learn about making wise choices.
  • Children are taught about safeguarding, including on line, through teaching and learning opportunities, as part of a broad and balanced curriculum. 
  • The curriculum is monitored to ensure aspects of safeguarding are embedded and that there is continuity across the key stages.


The Designated Safeguarding Lead (DSL):

  • Has a specific responsibility for championing the importance of safeguarding and promoting the welfare of pupils registered in the school.


This specific responsibility is specified in the Job Description and CANNOT be delegated.


The DSL will:

  • Act as the first point of contact with regards to all safeguarding matters.
  • Attend Designated Safeguarding Leader training every two years and annual update training.
  • Provide an annual report with relevant information to the Designated Governor for Safeguarding who will feedback to the Governing Body on how the school carries out its safeguarding duties.
  • Provide support and training for staff and, where appropriate, volunteers and make sure that they receive refresher training annually.
  • Ensure that the school’s actions are in line with the Local Safeguarding Children Board Procedures framework, Government Guidance and all London Child Protection Committee established procedures are followed.
  • Refer cases of suspected abuse or allegations to the Assessment Team following the London Child Protection procedures and protocols.
  • Inform parents of referrals unless it would pose a risk to the child.
  • Represent or ensure representation at inter-agency meetings, in particular conferences, strategy meetings, core groups and network meetings.
  • When requested, ensure written reports are provided to the Chair of Conference before an initial CP Conference and Review CP conference, using the agreed template.
  • Ensure the school effectively monitors children about whom there are concerns.
  • Keep copies of all referrals to external agencies related to safeguarding pupils.
  • Ensure that all staff and volunteers receive information on safeguarding policies and procedures from the point of induction.
  • Manage and keep secure the school’s safeguarding records.
  • Ensure that all staff and volunteers understand and are aware of the school’s reporting and recording procedures and are clear about what to do if they have a concern about a child.
  • Liaise with the headteacher and Safeguarding Governor as necessary about any safeguarding issues.
  • Ensure that the Safeguarding Policy is regularly reviewed and updated.
  • Publish the Safeguarding Policy on the school website.
  • Keep up to date with changes in local policy and procedures and be aware of any guidance issued by the DfE concerning Safeguarding.
  • Send pupils’ child protection or safeguarding files separately from the main files to the new establishment if pupils leave the school. Keep copies securely in school. 
  • Ensure that any absence of two days, without satisfactory explanation, of a pupil who has a child protection plan is referred to their Attendance and Welfare Officer and / or Social Worker.
  • Take lead responsibility for promoting educational outcomes by knowing and sharing  the welfare, safeguarding and child protection issues that children in need are experiencing and identifying the impact that these issues might be having on children’s attendance, engagement and achievement at school.
  • Help promote educational outcomes by sharing the information about the welfare, safeguarding and child protection issues that children, including children with a social worker, are experiencing, or have experienced, with teachers and school and college leadership staff.
  • Ensuring that the school or college, and their staff, know who these children are, understand their academic progress and attainment and maintain a culture of high aspirations for this cohort; supporting teaching staff to identify the challenges that children in this group might face and the additional academic support and adjustments that they could make to best support these children


Deputy DSLs (DDSL)

  • deputise in the DSL’s absence, ensuring that all the responsibilities listed above are carried out.
  • have the same training as the DSL.
  • work as a team with the DSL day-to-day, problem solving, monitoring for best practice, sharing information and workload etc.


Office Staff

  • carry out initial safeguarding checks on visitors to the school.
  • inform visitors about their own responsibilities in relation to safeguarding whilst they’re in the building.  
  • promptly share information they receive in their admin roles on families about whom there are concerns with the DSL and DDSLs.
  • The office manager ensures information about children’s contacts is kept up to date on the school Management Information System.  This includes ensuring that files transferred electronically and folders received on entry match the information provided by parents.  Any discrepancies will be reported to the headteacher for investigation.

  • Systems and Procedures

This section sets out systems and procedures particular to Columbia.  It is organised under the following broad headings:

  • Raising concerns.
  • Keeping records. 
  • Sharing information
  • Monitoring 
  • Attendance and exclusions
  • Private fostering
  • Issues which are covered in separate policies (Allegations against Staff, Physical Intervention, Whistleblowing, Use of cameras and phones, Safer Recruitment)

  • Raising concerns

This following procedure applies to all members of staff, volunteers and visitors at Columbia:

Child protection procedures are to be followed at all times. This means that any knowledge or suspicion that a child may be at risk must be reported to the Designated Safeguarding Lead (DSL) or a Deputy Designated Safeguarding Lead (DDSL) immediately.  Adults worried about children must not weigh up for themselves whether or not the concerns are serious, nor must they discuss the concern with colleagues.


Staff must report to the DSL or DDSL as soon as possible, ensuring that the concern is not left to the end of the day.  Teachers in class can send a message asking the DSL to attend.  Any of the following could be cause for concern:


  • an unexplained mark
  • seeming more tired than usual
  • withdrawn or unusual behaviour
  • dirty clothes
  • shorter temper than usual
  • inability to focus
  • inappropriately sexual behaviour
  • age-inappropriate language or knowledge
  • a disclosure by the child or someone else
  • something indefinable.


If a child discloses something, adults will not agree to keep it secret.  It is important however to ask how the child feels about the actions that will be taken and respond appropriately to their response in order to reassure them.

The DSL or DDSL will listen and then ask the staff member to record what they’ve said on CPOMS.

The DSL will decide what to do, often in conference with a deputy.

The staff member will go back to the DSL the following day to find out what action has been taken.


Informing parents and carers:

We always aim to work in partnership with families to keep children safe.  As such, parents and carers will almost always be informed when concerns are raised about the safety and welfare of their child.  It follows that parents and carers will almost always be informed when a referral is made to an external agency.  Parents will only not be informed beforehand if it is felt that informing them might put the child at further risk.  In such cases the DSL or a DDSL will take advice from the Child Protection Advice Line.

  • Keeping records

Columbia Primary School will keep and maintain up-to-date information on pupils on the school roll including where and with whom the child is living, attainment, attendance, referrals to and support from other agencies.  We endeavor to have 2 emergency contact numbers for each child or family.


Where a concern is raised, the DSL will ask the adult to record what they’ve discussed on CPOMS.  The record will be factual, as free from opinion as possible, will record what the child said (if anything) and will name all individuals involved, giving their roles.


If possible, the DSL will confer with a DDSL but will act immediately and independently if necessary.


All recorded concerns are noted on CPOMS as soon as possible.  Once the action decided upon has been taken, CPOMS will be updated for that child.


The School Business Manager maintains the Single Central Record of all staff members’ personal data including DBS status.  

  • Sharing information and confidentiality:

In addition to everyday team working the Safeguarding team meets regularly so that everyone has the same information and is up-to-date with all developments relating to individual safeguarding concerns.


Otherwise, in school, information is shared on a strictly need-to-know basis:

  • Class teachers are kept up-to-date with concerns relating to individual pupils in their classes although they may not need to know details of the concerns raised.
  • Office staff are told which families are currently cause for concern so that they can carry out their front-line responsibilities properly.
  • All staff are kept up-to-date with the list of children who are or have been CIN, on a CP plan, Looked After or causing concern.  This is so that those children are always kept in mind and flagged up immediately to the Safeguarding Team in the event of any change or concern.  Staff do not normally know details of the causes for concern relating to these children.


The school will notify relevant external agencies if:

  • a child subject to a child protection plan is about to be excluded.
  • there is an unexplained absence of a pupil who is subject to a child protection plan of more than two days from school.
  • an agreement to do so has been made as part of any child protection plan or core group plan.


Columbia’s practice related to sharing of personal data is GDPR compliant, so when other agencies ask for information about pupils it is sent securely.

  • Monitoring

Monitoring happens formally and informally through:

  • Fortnightly team meetings,
  • Termly visits from the safeguarding governor,
  • Half-termly spot-checks of record keeping, office practice, SCR and medicines/medical records.
  • DSL’s own line management with the headteacher.


The DSL and School Business Manager (DDSL) run a rolling audit in the form of a half-termly checklist which covers all the safeguarding administration tasks, and includes training updates and monitoring points.

  • Attendance and Exclusions

Columbia’s systems for monitoring attendance are set out in the school’s attendance policy.

The learning mentors, who monitor everyday attendance, inform the DSL when children in need or children on CP plans are absent so that social workers can be alerted.  The learning mentors make home visits to children about whom there are concerns and who are absent for unexplained reasons.


Columbia Primary School implements the statutory requirements in terms of monitoring and reporting pupils missing in education and off-rolling. 


Young people who require access to alternative provision will have a personalised learning or behaviour support plan designed to meet their needs. Their attendance and progress will continue to be monitored by Columbia Primary School.  We recognise that it is our duty to ensure that the adults working with children in alternative provision have undergone appropriate checks.


The DSL is informed when an exclusion is imminent or likely in order to think through any possible safeguarding implications.

  • Private Fostering

A private fostering arrangement is one that is made privately (without the involvement of a local authority) for the care of a child under the age of 16 years (under 18, if disabled) by someone other than a parent or close relative, in their own home, with the intention that it should last for 28 days or more. (*Close family relative is defined as a ‘grandparent, brother, sister, uncle or aunt’ and includes half-siblings and step-parents; it does not include great-aunts or uncles, great grandparents or cousins.)


Most frequently, young people are in private foster care for the following reasons:

  • children from other countries sent to live in the UK with extended family
  • host families for language schools
  • parental ill-health
  • where parents who have moved away, but the child stays behind (e.g. to stay at the same school to finish exams)


Schools have a duty to inform the local authority, if they believe a private fostering arrangement is taking place for one of their pupils.  There is no duty for anyone, including the private foster carer or social workers to inform the school. The term ‘Looked After Children’ means children who are looked after by the local authority. Privately fostered children are outside the care of the local authority. Schools should not therefore code children in private foster care as ‘LAC’.

  • Issues for which there are separate policies

Managing allegations and concerns against staff, supply teachers and volunteers

The school follows the procedures recommended by the Local Authority and the Tower Hamlets SCP arrangements 2019 when dealing with allegations made against staff and volunteers. Please see the separate policy called Managing Allegations against Staff.  Allegations about a member of staff should be reported to the headteacher.  If the allegation relates to the headteacher, it should be reported to the Chair of Governors.  


The school works with the Local Authority Designated Officer who is Melanie Benzie – [email protected] or [email protected] Telephone: 0207 364 0677



All staff have a duty to raise concerns, where they exist, about the attitudes or actions of colleagues.

Please see the separate policy, Whistleblowing which draws the attention of all staff to the procedures in the place at Columbia School and the Protect Website ( ) and their helpline: 020 3117 2520


Physical Intervention 

Please refer to the separate policy relating to physical intervention.


Under normal circumstances, staff and volunteers will not use physical restraint. However, adults’ first duty is to keep children safe, so if the adult perceives a real risk of harm to a child he or she must do whatever is necessary to safeguard the child.


Following an incident which demands the use physical restraint for the child’s own or others’ safety, key staff members meet to prepare a plan for that child in order to reduce the likelihood of needing to use restraint for him or her in the future.


Use of Cameras and mobile phones

The appropriate use of cameras and mobile phones is covered in the Acceptable Use agreement which is updated annually and which all staff and volunteers are required to read and sign annually.  Children are not allowed to bring mobile devices into school.


Safer Recruitment

We maintain a comprehensive record of the checks that have been carried out to ensure that adults are suitable to work with children. This information is held in the school’s single central record which is available to those entitled to examine this document. It is the Headteacher’s responsibility to ensure that this document is kept up to date and holds all of the relevant information. 


We ensure that a member on every recruitment panel has received appropriate recruitment and selection training.  We also check that all relevant staff are appropriately qualified and have the relevant employment history and checks undertaken to ensure they are safe to work with children/young people. 


Volunteers who, on an unsupervised basis teach or look after children regularly, or provide personal care on a one-off basis in schools and colleges, are considered to be in regulated activity. We obtain an enhanced DBS certificate (which should include barred list information) for all volunteers who are new to working in regulated activity. Existing volunteers in regulated activity do not have to be re-checked if they have already had a DBS check (which includes barred list information). However, we may conduct a repeat DBS check (which should include barred list information) on any such volunteer should they have concerns. We are not legally permitted to request barred list information on a supervised volunteer as they are not considered to be engaged in regulated activity.


We will undertake a risk assessment and use our professional judgement and experience when deciding whether to obtain an enhanced DBS certificate for any volunteer not engaging in regulated activity. In doing so they should consider: 

  • the nature of the work with children; 
  • what the establishment knows about the volunteer, including formal or informal information offered by staff, parents and other volunteers; 
  • whether the volunteer has other employment or undertakes voluntary activities where referees can advise on suitability; 
  • whether the role is eligible for an enhanced DBS check

Relevant staff are asked to inform the school that they are not disqualified from working within the Childcare Act (2006) (as amended) and we remind staff that if there are any changes to their status, they must inform the school.


We ensure any contractor, or any employee of the contractor, who is to work at the school, has been subject to the appropriate level of DBS check. This is always checked upon arrival to the school. Contractors engaging in regulated activity will require an enhanced DBS certificate (including barred list information). For all other contractors who are not engaging in regulated activity, but whose work provides them with an opportunity for regular contact with children, an enhanced DBS check (not including barred list information) will be required. In considering whether the contact is regular, it is irrelevant whether the contractor works on a single site or across a number of sites. No contractor is permitted to work unsupervised or engage in regulated activity if they do not have the relevant checks. If self-employed, we will consider obtaining the DBS check. 


Where a pupil is placed with an alternative provision provider, we continue to be responsible for the safeguarding of that pupil, and should be satisfied that the provider meets the needs of the pupil. We may obtain written confirmation from the alternative provider that appropriate safeguarding checks have been carried out on individuals working at the establishment, i.e. those checks that we would otherwise perform in respect of our own staff. 


4: Vulnerable Groups and safeguarding issues of particular concern


At Columbia we are alert to signs of abuse or neglect in all children.  Staff and volunteers are familiar with the information about recognising signs of abuse which is set out in appendix 1 of this policy.


We pay particular attention to the presentation of children in the following groups and act promptly to ensure their safety.  Staff awareness of these groups is raised and maintained through termly training and updated in weekly bulletins.


Children with disabilities are defined as ‘children in need’ by the Children Act 1989, Section 17. We understand that children with SEN and or disabilities are 3-4 times more likely to be neglected or abused (both physically and emotionally) than typical children.  They are more vulnerable to peer-on-peer abuse and at high risk of social isolation. 


At Columbia we aim to identify the children who might be at risk early on and pre-empt social difficulties by providing additional, sensitive pastoral support.  


Children exposed to Domestic Abuse can find it hard to concentrate, sometimes feel responsible for the domestic abuse, are worried about their parents, may have their own needs neglected and may act out angrily or be withdrawn.  We know that these children are at risk of developing negative patterns in their own future relationships. 

See Annex A of KCSIE 2021 for further information.


At Columbia we work hard to build and keep trusting relationships with parents and carers and our communication systems are always under review in order to improve them.  In this context we are alert to signs of distress and can respond quickly by communicating immediately with the people who need to know and can help.  We have robust systems for reporting and flexible human resources for providing pastoral support.  Experienced learning mentors provide practical support to parents, making phone calls, accompanying to appointments if necessary and signposting to other services.


Child Sexual Exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.


Some of the following signs may be indicators of sexual exploitation:

  • Children who appear with unexplained gifts or new possessions;
  • Children who associate with other young people involved in exploitation;
  • Children who have older friends and/or boyfriends or girlfriends;
  • Children who suffer from sexually transmitted infections or become pregnant;
  • Children who suffer from changes in emotional well-being;
  • Children who misuse drugs and alcohol;
  • Children who go missing for periods of time or regularly come home late; and
  • Children who regularly miss school or education or do not take part in education


DfE’s guide to Child sexual exploitation – Definition and a guide for practitioners is available here at


Staff are aware that children going missing from education, particularly repeatedly, can be a warning sign of a range of safeguarding possibilities as listed in Annex A of KCSIE 2020. They recognise that early intervention is essential to help prevent the risks of a child going missing in future.  Staff are aware of the school’s unauthorised absence and CME procedures.


Children from pockets of our community which continue to condone VAWG might be at risk of FGM, and of exposure to the fall-out from so-called ‘honour’-based violence or forced marriage.  


KCSIE 2021, Annex B provides detailed guidance and references on what staff must do when responding to concerns relating to Honour Based Violence.


So called “Honour-based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. All forms of so called HBV are abuse and should be handled and escalated as such. If in any doubt, staff should speak to the designated safeguarding lead.  Staff need to be alert to the possibility of a child being at risk of HBV, or already having suffered HBV. 


It is important that professionals look out for signs that FGM has already taken place so that the girl receives the care and support she needs to deal with its effects. At the same time enquiries can be made about other female family members who may need to be safeguarded from harm; and/or criminal investigations into the perpetrators, including those who carry out the procedure, can be considered to prosecute those who have broken the law and to protect others from harm. 

There are a number of indications that a girl has already been subjected to FGM: 

  • a girl asks for help explicitly/indirectly or confides in a professional that FGM has taken place; 
  • a mother/family member discloses that a female child has had FGM; 
  • a family/child is already known to social services in relation to other safeguarding issues; 
  • a girl has difficulty walking, sitting or standing or looks uncomfortable; 
  • she finds it hard to sit still for long periods of time and this was not a problem previously;
  • a girl spends longer than normal in the bathroom or toilet due to difficulties urinating; 
  • a girl spends long periods of time away from a classroom during the day with bladder or menstrual problems; 
  • a girl has frequent urinary, menstrual or stomach problems; 
  • a girl avoids physical exercise or requires to be excused from physical education (PE) lessons without a GP’s letter; 
  • there are prolonged or repeated absences from school or college (see 2015 guidance on children missing education); 
  • increased emotional and psychological needs, for example withdrawal or depression, or significant change in behaviour; 
  • a girl talks about pain or discomfort between her legs. 


Remember: this is not an exhaustive list of indicators.  Further warning signs that FGM may be about to take place, or may have already taken place, can be found on pages 38 – 41 of Multi agency statutory guidance on FGM.


We report all FGM disclosures to the police as well as to the LADO, Melanie Benzie – [email protected] or [email protected] Telephone: 0207364 0677


Teachers are aware of their mandatory obligation to report to the police when they believe that FGM has taken place, but that if they believe a child to be at risk of FGM, they report the concern as normal to the DSL.


Children suffering peer on peer abuse may be subject to bullying (including cyber-bullying), gender based violence and abuse, sexual harassment, assault and sexting, upskirting and initiation/hazing abuse.  It can take many forms.  All staff are trained to ensure the child’s wishes and feelings are taken into account when determining what action to take and what services to provide.


Abuse is abuse and cannot be tolerated in the Columbia school community.  It is always taken seriously.  Please see the Behaviour and Anti-bullying policies for further information about how peer on peer abuse is addressed.  This is a safeguarding matter, therefore concerns about peer on peer abuse will be referred to the DSL.  


Sexual violence and sexual harassment between children.

We are aware that there is a risk in primary schools that staff and volunteers could underplay children’s concerns in this respect because they are young. 


It is therefore crucial that staff and volunteers at this school understand that sexual violence and sexual harassment can occur between two children of any age and gender.   Detailed information about what constitutes sexual violence and sexual harassment can be found in ‘Sexual Violence and Sexual Harassment between children in schools and colleges’ (DfE, 2017).


This can occur between two children of any age and sex, or through a group of children sexually assaulting or harassing a single child or group of children. This is likely to be stressful and distressing for the victim.  Sexual violence and harassment exist on a continuum and may overlap. They can happen on and offline. It is important that all victims are taken seriously and offered appropriate support. Some groups, e.g. girls, SEND and LGBT children are at greater risk.


Staff will 

  • Make it clear that sexual violence and harassment is not acceptable, will not be tolerated and is not an inevitable part of growing up
  • Not dismiss it as banter or just having a laugh or “boys being boys”
  • Challenge and report behaviours (potentially criminal in nature) such as groping etc
  • Report all instances of upskirting or similar behaviour to the DSL.
  • Challenge issues where consent is misunderstood
  • Report concerns raised by themselves or by a child
  • Ensure the victim is reassured that they have done the right thing, is not dismissed as creating a problem and taken seriously. Explain the actions that will be taken, ask the victim how they feel and respond to reassure them further.


Sexual harassment and sexual violence is a safeguarding concern, therefore all concerns will be referred to the DSL.  Victims and perpetrators at Columbia will receive support from our pastoral team.


Sexting is defined as images or videos generated by children under the age of 18, or of children under the age of 18, that are of a sexual nature or are indecent. These images are shared between young people and/or adults via a mobile phone, handheld device or website with people they may not even know.  For further information see ‘Sexting in schools and colleges, responding to incidents, and safeguarding young people’ (UKCCIS, 2016).


Staff report all peer on peer abuse, sexual violence and sexual harassment or sexting to the headteacher or DSL.  The headteacher (or DSL) will talk to the victim and record what has happened on CPOMS, reassuring the child that s/he has done the right thing by telling an adult.  The headteacher will then determine the next step which might involve: education for the alleged perpetrator linked to the human development and relationships policy, a consequence, talking to parents, an Early Help Assessment or a referral to MASH.  Following the incident, a referral to the school pastoral support team might also be appropriate for both the victim and (alleged) perpetrator. 


The Relationship and Sex Education and Health Education Policy and PSHCE Curriculum outline how the school prepares children for age appropriate relationships and physical contact. It also aims to empower them, helping them to understand that they have dominion over their own bodies and that they are entitled to say no to anything that makes them feel uncomfortable.


There is potential for children who have previously been looked after to be vulnerable as a consequence of early childhood experiences.  Staff at Columbia know that where there has been a traumatic start, children’s capacity for coping with everyday stresses can be undermined.  Staff and volunteers are aware of the potential difficulties and alert to any signs   that may give cause for concern.  Normal safeguarding procedures are followed when concerns are raised.  Children who have previously been looked after are monitored and when appropriate, referred to the pastoral team for additional support.


The DSL works in close partnership with any other professionals who may continue to be involved in the children’s lives.


In a similar way to sexual exploitation Child Criminal Exploitation or CCE is when there is a power imbalance where children are used by individuals or gangs to take part in criminal activity, this can include drug running, stealing etc all of which have potential to lead to serious violence. The child often believes they are in control of the situation. Violence, coercion and intimidation are common. ‘County Lines’ is a national issue involving the use of mobile phone ‘lines’ by groups to extend their drug dealing business into new locations outside of their home areas. This issue affects the majority of police forces and often includes the exploitation of vulnerable adults or children.


The national picture on county lines continues to develop but there are recorded cases of: 

  • Children as young as 12 years old being exploited by gangs to courier drugs out of their local area; 15-16 years is the most common age range.
  • Both males and females being exploited and White British children being targeted because gangs perceive they are more likely to evade police detection.
  • The use of social media to make initial contact with children and young people.


Gangs are known to target vulnerable children; some of the factors that heighten a child’s vulnerability include:

  • Having prior experience of neglect, physical and/ or sexual abuse; Lack of a safe/stable home environment, now or in the past (domestic violence or parental substance misuse, mental health issues or criminality, for example);
  • Social isolation or social difficulties; 
  • Economic vulnerability; including homelessness
  • Connections with other people involved in gangs; 
  • Having a physical or learning disability; or mental health issue;
  • Being in care (particularly those in residential care and those with interrupted care histories).


Indicators that a child might be subject to CCE and at risk of involvement with serious violence:

  • Persistently going missing from school or home and / or being found out-of-area; 
  • Unexplained acquisition of money, clothes, or mobile phones 
  • Excessive receipt of texts / phone calls
  • Relationships with controlling / older individuals or groups 
  • Leaving home / care without explanation 
  • Suspicion of physical assault / unexplained injuries 
  • Parental concerns 
  • Carrying weapons 
  • Significant decline in school results / performance 
  • Gang association or isolation from peers or social networks 
  • Self-harm or significant changes in emotional well-being



If staff have a concern that a child is at risk of or is being criminally exploited, they should follow schools’ procedures raising a concern for the DSL who may follow this up with discussion with Children’s Social Services and/or the police. If staff are aware a crime has been committed, it should be reported directly to the police.


Children exposed to Extremism and/or at risk of Radicalisation.

Children who are vulnerable for any reason (could be as a result of domestic, economic, social or mental health difficulties, low self-esteem etc etc) are also at risk of radicalization by adults who look to exploit vulnerability.  Disaffection also makes them candidates for involvement in extremist activity. 


Although Columbia is a primary school many of our children have older siblings whose lead they want to follow and who may be affected themselves.  Their local area of Bethnal Green has been a focus for extremist political activity for several decades.


The school adheres to guidance outlined in detail in The Prevent Duty (DFE 2015) and the DCSF document ‘Learning together to be safe’. We draw on the strong support for this duty provided by LBTH, attending training and receiving training on-site from their provider.


Columbia School’s values are threaded through everything we do and teach, and are intended to foster a climate in which tolerance, fairness and collaboration can thrive.  We hope that this will help to immunize the children against the appeal of radicalization and extremism.  


However, staff are alert to any signs of unusual behaviour, change of dress, attitude, demeanour or any talk which expresses sympathy for extremist views.  These signs are additional to the universal signs of vulnerability for which staff and volunteers are always sensitive.


Appendix 3 of this policy sets out the referral route for concerns which might indicate a child is at risk of radicalisation. 



Being homeless or at risk of homelessness is a real risk to a child’s welfare. The DSL is aware of contact details and referral routes to the Local Housing Authority so they can raise concerns at the earliest opportunity. However, this does not replace a referral to children’s social care where a child has been harmed or is at risk of harm.


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Columbia Primary School,
Columbia Road,
E2 7RG


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