Safeguarding Policy

If you are in need of support regarding a safeguarding issue, please contact your training officer or safeguarding lead. The following websites may also be helpful:


This policy outlines the responsibilities of Capital 4 Training in relation to the protection of children, young people and vulnerable adults in response to:

  • The Children Act 1989
  • The Protection of Children Act 1999
  • The Children Act 2004
  • Working Together to Safeguard Children 2006
  • What to do if you’re worried a child is being abused. DfES 2006
  • Safeguarding Children and Safer Recruitment in Education 2007
  • Safer practice, safer learning 2007
  • Keeping children safe in Education 2016
  • Data protection act 1998 / General Data Protection Regulations (GDPR) 2018
  • Working Together to Safeguard Children (HM Government 2015)

Capital 4 Training is dedicated to the health, safety, and welfare of all children, young people and vulnerable adults involved in courses or activities which come under the responsibility of the company.

This policy covers all Capital 4 Training customers whether they are based on site or in workplace learning, covering all aspects of a learner’s programme regardless of where it takes place. It is the responsibility of all staff to understand their role in supporting safeguarding across all aspects of provision and for familiarising themselves with the appropriate procedures and other policies that support this overarching document.

What is Abuse?

Abuse and neglect are forms of maltreatment.

Abuse can be:

  • Financial or material abuse – including theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
  • Physical abuse – including assault, hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.
  • Neglect and acts of omission – including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.
  • Sexual abuse – including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault, or sexual acts to which the adult has not consented or was pressured into consenting.
  • Psychological / Emotional abuse – including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks
  • Organisational abuse – including neglect or poor care practice within an organisation or specific care setting, such as a hospital or care home. It can also be in relation to care provided in your own home. This may range from one-off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.
  • Discriminatory abuse – including forms of harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation or religion.
  • Self neglect – this covers a wide range of behaviour such as neglecting to care for your personal hygiene, health or surroundings and includes behaviour such as hoarding.
  • Domestic abuse – including psychological, physical, sexual, financial, emotional, or so-called ‘honour’ based violence.
  • Modern slavery – encompasses slavery, human trafficking, forced labour and domestic servitude. Trafficking and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

Capital 4 Training is committed to ensuring that the company:

  • Provide a safe environment for children, young people and vulnerable adults to learn in.
  • Identifies children, young people and vulnerable adults who are suffering, or likely to suffer, significant harm, and
  • Takes appropriate action to see that such children, young people and vulnerable adults are kept safe.
Designated Senior Staff

Safeguarding Officer: Andrew Hughes

The senior designated person – Andrew Hughes, Safeguarding Officer, holds strategic responsibility for the safeguarding processes and procedures are robust and consistently applied and that Capital 4 Training fulfils its legal duties within the legislation.

As the company’s senior representative, Andrew will be responsible for taking the lead for raising awareness within the staff of issues relating to the welfare of children, young people and vulnerable adults, and the promotion of a safe environment for learners within the company.

The senior designed Safeguarding Officer is responsible for:

  • Overseeing the referral of cases of suspected abuse or allegations to Children’s Social Care.
  • Ensuring that all staff receive basic training in safeguarding issues and are aware of the company’s safeguarding procedures.
  • Provide an annual report to the Director of the company setting out how any deficiencies in the procedure or policy have been identified.
  • Providing advice, guidance and support to staff on issues relating to safeguarding.
  • Establishing a secure system for the safe, confidential storage of records of any safeguarding concerns (even where that concern does not lead to a referral).
  • Ensuring that employers and employees working with Capital 4 Training are aware of the company’s Safeguarding Children, Young People and Vulnerable Adults Policy.
  • Liaising with the LA, Safeguarding Children’s Board, Children’s and Adult Social Care and other appropriate agencies as and when required.

The designated  Safeguarding Officer is required to receive regular training in safeguarding issues and inter-agency working, as required by the Safeguarding Children’s Board, and will receive refresher training annually unless legislation dictates sooner.

Key Principles

Capital 4 Training has a duty to ensure that all staff fulfill their responsibilities in safeguarding children, young people and vulnerable adults. We will ensure that:

• All people will be treated with respect and with courtesy by staff and customers in an environment that is free from harassment or discrimination.

• All training rooms, facilities and equipment will comply with legislative health and safety standards and provide a safe and secure environment for learning with appropriate supervision and support of staff.

• Capital 4 Training will work with learners, employers and other agencies to promote a safe and healthy culture in particular the local Safeguarding Children’s Boards to ensure that learners are safeguarded through the effective operation of the company’s safeguarding children, young people and vulnerable adults procedures. The company’s Safeguarding Children, Young People and Vulnerable Adult Policy will be made available to all engaged parties.

• Capital 4 Training will develop partnerships to proactively protect students at risk of abuse, neglect or at risk of radicalisation.

• Staff will be trained and have a clear understanding of personal safety and good safeguarding practices as well as what factors may make learners vulnerable to a range of safeguarding concerns and can recognize outward signs of abuse, or unexplained changes in behavior or performance which may be indicative of abuse. All staff will be made aware of the signs of abuse and the procedures for reporting abuse.

• Capital 4 Training will work with learners to promote their own personal health, well-being and safety including their safety online.

• Capital 4 Training will work proactively to raise awareness of radicalisation and extremism in order to prevent people from being drawn into terrorism.

• Learners and employers will receive confidential advice, guidance and support for a range of issues that they may face. They will be signposted to external agencies where specialist support is required.

• Capital 4 Training will support students to have personal resilience and be able to make informed and sensible decisions about their safety and wellbeing in an attempt to prevent them from being exploited and or abused.

•Capital 4 Training has established and will regularly review procedures for reporting suspected abuse taking account of any new government legislation, regulations or best practice documents to ensure staff are kept fully up to date with their responsibilities and duties with regard to the safety and well-being of children.

•Capital 4 Training will deal with any allegations of abuse by staff according to the Company Disciplinary Procedures as appropriate.

Safeguarding against antisemitism

Antisemitism is prejudice or hatred against Jews. It has existed in various forms for more than 2,000 years, based at different times on actual or perceived differences between Jews and others, along religious, racial, ethnic and national lines.

One of the best contemporary definitions of antisemitism is that adopted, in May 2016, by the International Holocaust Remembrance Alliance, a coalition of 31 member states and 11 observer states. On 12 December 2016, the Government announced that the UK would be one of the first countries to formally adopt the definition.

In recent years, the rate of antisemitic incidents has been stubbornly high, according to research by the UK Jewish community’s third-party reporting agency, the Community Security Trust. In this period, antisemitism has sometimes shown increases in direct correlation to increases in violence in the Israeli-Palestinian conflict, but this is not the only ‘trigger’. Like other forms of prejudice, antisemitism has been evident in direct interpersonal interactions, as well as on social media.

Some examples of antisemitic sentiments may include:
• Support for – or failure to oppose – terrorism against Jews in the UK or abroad
• Celebration, denial, trivialisation or revision of the Holocaust;
• Anti-Jewish conspiracy theories about ‘Jewish control’ over politics, the media or finance
• Theological antisemitism;
• Crude stereotypes about Jewish physical appearance or relationship to money or power.
• Exceptional treatment of Israel, where the world’s only Jewish state is uniquely subjected,
among all the countries in the world, to hostile behaviours such as denial of its right to exist
or holding it to standards not expected or required of any other democratic nation.

Antisemitic behaviour might include:
• Racist abuse – including name-calling or Nazi gestures
• Physical bullying – including violence or intimidation
• Graffiti – on public or personal property
• Exclusion by peers

Safe recruitment

Capital 4 Training will comply with the best practice in the recruitment and training of its staff, in line with legislative requirements. Capital 4 Training’s recruitment Policy supports this document. Staff will undergo the appropriate pre-employment checks including DBS checks for their role where applicable, and undertake mandatory safeguarding training appropriate to their role. Staff will understand the principles of safe working practices, and how not to put themselves in situations that compromise themselves or learners. All new employees will receive an appropriate induction, including safeguarding training.

Safeguarding learners

Capital 4 Training has a legal obligation to protect young people and vulnerable adults from abuse. Capital 4 Training has an appropriately trained safeguarding officer (Andrew Hughes) and all staff are trained in Safeguarding L2 who will ensure that disclosures made by learners are dealt with quickly, sensitively and appropriately. All staff will be trained in the appropriate response to a disclosure and the correct procedure for dealing with concerns about a learner. Allocated staff members will work with learners and employers to proactively protect them from abuse and neglect and prevent learners being placed in an abusive situation. Refresher training will be carried out every 2 years, unless legislation dictates sooner and any updates or Safeguarding issues are discussed in quarterly team meeting to ensure all staff remain current and competent.

Remote Teaching

Keeping learners and teachers safe during remote education is essential. The same principles set out above, also apply to remote teaching.

Capital 4 Training has clear reporting routes so that learners can raise any safeguarding concerns in relation to remote online education.

For more information

  • reporting harmful online content to the UK Safer Internet Centre
  • getting government advice and trusted resources from Educate Against Hateon safeguarding from radicalisation, building resilience to extremism, and promoting shared values

Capital 4 Training maintains a professional practice when communicating online with learners. When possible we communicate within business hours (or agreed hours), and we advise learners not to share personal information

Capital 4 Training Use secure online learning platforms. All lessons are taught from a quiet or private room with consideration to the background.

Due to the official guidelines concerning the coronavirus changes from day to day. Our guidelines and the way we operate change according to the government guidelines. We do however implement general practices to our staff, teachers, and learners.

  • Watch for signs of anxiety.
  • Give people control and offer simple reassurance.
  • adopt good hygiene and social-distancing habits
  • Stay in touch via phone, email, or video calls.
  • Encourage people to keep moving – exercise works wonders!
Important safeguarding adults messages

Safeguarding adults falls to the responsibility of everyone. It is imperative that we are watchful and alert towards the signs and indicators of abuse and neglect.

If you have a concern about an adult at risk you should report it:

Community Health and Social Care Direct (8am to 5pm) – Telephone: 0191 278 8377

Outside of these hours – Telephone: 0191 278 7878

In an emergency always dial 999


The company will keep clear, comprehensive records of any disclosures and/or allegations of abuse.

The company will comply with the requirements of the Data Protection Act 1998, which allows for disclosure of personal data where this is necessary to protect the interests of a learner.

Links with external agencies

Capital 4 Training work with Local Safeguarding Children Boards, the Local Authority Designated Officer, the Multi Agency Safeguarding Hub and other professions to ensure a comprehensive safeguarding network is in place. Advice will be taken from professionals within these organisations as appropriate.

NSCB – 0191 277 2500

Durham LSCB – 03000 265 770

Capital 4 Training will work proactively with the regional Prevent coordinators when appropriate.

Prevent North East regional Co-ordinator – Chris Sybenga 07384 456640,

Safeguarding policy update following Ofsted’s review of sexual abuse in schools and colleges

Ofsted’s recent review into the prevalence of peer-on-peer sexual abuse in schools and colleges revealed an alarmingly high rate of sexual harassment and sexual violence, including online, within all education settings. Capital4Training has a responsibility to ensure that all our learners are protected from sexual harassment, abuse and violence. While the majority of our learners are over 18, we recognise that the behaviours and abuses described in the Ofsted review are not confined to schools and colleges and are in fact symptomatic of a larger societal problem. As such, all staff are aware of the findings of the Ofsted review and we as a company will work to ensure all of our learners are able to work and learn in environments free from sexual abuse, harassment and harmful behaviour.


Capital4Training use the DfE’s definitions of sexual abuse and peer-on-peer abuse, as follows:

Peer-on-peer sexual abuse

The term ‘peer-on-peer’ sexual abuse includes:

  • sexual violence, such as rape, assault by penetration and sexual assault
  • sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be stand-alone or part of a broader pattern of abuse
  • upskirting, which typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or to cause the victim humiliation, distress or alarm
  • sexting (also known as ‘youth-produced sexual imagery’)

Harmful sexual behaviour

When we refer to harmful sexual behaviour, we use the same definition as the DfE:

Sexual behaviours expressed by children and young people under the age of 18 years old that are developmentally inappropriate, may be harmful towards self or others, or abusive towards another child, young person or adult.

Sexual harassment and sexual violence

When we refer to sexual harassment and sexual violence, including online, we use the definitions and the language of victim and perpetrator in the DfE’s guidance. However it is important to recognise that not everyone who has been subjected to sexual harassment and/or sexual violence, including online, considers themselves a victim or would want to be described in this way.

Responses and interventions

Any young or vulnerable person who exhibits harmful sexual behaviour may need a safeguarding response or intervention. Professionals should respond with interventions that address the behaviour of the perpetrator, while also providing an appropriate level of support. As the majority of learners enrolled on apprenticeship programmes with Capital4Training are over the age of 18, any instances of learners perpetrating sexual abuse or harassment must also be considered criminal activity and treated accordingly.

Prevalence of sexual harassment among young people

The review by Ofsted states that 79% of young people aged 16 to 17, and 86% of those aged 18 and above, said that rumours about sexual activity occurred a lot or sometimes between peers. 54% of those aged 16 and above said unwanted touching occurred a lot or sometimes. As these age groups are those which Capital 4 Training learners may fall into it is important that training staff in particular are aware of the prevalence of these behaviours among young people and are capable of challenging and assumption by learners that these behaviours are normal or acceptable.

Creating a positive and safe environment

All staff have a responsibility to promote a safe learning and working environment free from sexual harassment and abuse. Any instances of sexual harassment, including sexual comments, remarks or jokes should be challenged and it should be made clear that sexual harassment or abuse in any form is unacceptable and will not be tolerated by Capital 4 Training.

Encouraging safeguarding reports and disclosures

All learners are informed and regularly reminded how to contact the designated safeguarding lead. It is important that staff in regular contact with learners, particularly Training Officers, regularly discuss with learners how to report a safeguarding concern or make a disclosure, and ensure that learners are aware that these concerns / disclosures can include sexual harassment, abuse or harmful sexual behaviours, including peer-on-peer abuse by other learners.

Any staff to whom a safeguarding concern is reported or disclosure made must follow the safeguarding protocol as detailed in the overall safeguarding policy.

If you have any questions please get in touch

If you have any questions please get in touch

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