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Name for policy: Safeguarding Policy  
Date approved by College Council: 27 November 2024  
Policy owner: Senior Tutor  
Next review date: Michaelmas 2026  
 

1. Aims 

1.1 The College aims to a high standard and to take all reasonable steps in relation to the safety and welfare of children and adults at risk. The College encounters children and some adults at risk through its teaching and research activities, as well as through its recruitment and outreach programmes and certain conferencing activities. 

1.2 Within its scope this policy aims to: 

(a) help the College protect adults at risk and children and keep them safe from harm; 

(b) safeguard the interests of groups which come into contact with adults at risk or children in the course of the College’s activities; 

c) ensure that roles and responsibilities are made clear in respect of safeguarding matters; 

d) ensure appropriate information, training and support is provided to those within scope; c) deal with safeguarding concerns effectively and in a timely manner; 

e) prevent employment by the College of individuals to work with children or adults at risk where they have been barred by the Disclosure and Barring Service (DBS) or are deemed by the College to pose a risk; 

f) manage effectively the safeguarding risks associated with activities and events involving children and adults at risk. 

2. Scope of the policy 

2.1 The policy applies to any of the College’s Fellows, employees, workers, volunteers, students or anyone working on behalf of the College (in a paid or unpaid capacity) when engaged or preparing to engage in or be involved in any activities within scope (‘College Participants’). 

2.2 The policy applies to all events and activities organised by the College, its Fellows/Bye-Fellows and its authorised agents, and events and activities organised by its students, and visits from members of the public. 

2.3 Events organised by external bodies utilising the College’s premises or facilities are not covered on the grounds that they will only be accepted, if they involve children or adults at risk, where the external body has its own safeguarding policies and procedures in place, which it shares with the College, and agrees it takes responsibility for the safeguarding of children and adults at risk involved in the activities. 

2.4 The policy covers specifically ‘regulated activities’ as defined below.

3. Definitions

3.1 Safeguarding: describes arrangements to protect Children and Adults at Risk from abuse or neglect.

3.2 Adult at Risk: adults participating in activities, which, if provided to any person aged 18 or over who needs to engage in that activity, will mean that the adult will be considered at risk at that particular time. It is therefore the activity and the need for it, rather than the setting or the adult’s particular personal characteristics, which determines whether an adult is at risk at any given time. These activities are summarized in 3.5.1.

3.3 Child / Children: anyone under the age of 18.

3.4 College Participants: College’s Fellows, Bye-Fellows, Senior Teaching Associates, Teaching
Associates, employees, workers, volunteers, students or anyone working on behalf of the College (in a paid or unpaid capacity) when engaged or preparing to engage in or be involved in any activities within the scope of this policy.

3.5 Abuse: includes physical, sexual, psychological/emotional, financial/material or professional. It can arise from neglect.

3.5.1 Regulated activity in relation to Adults at Risk: in outline, activities provided to any adult which, if any adult requires them, will mean that the adult will be considered at risk at that particular time. Any time a person engages in one or more of the activities set out below in relation to any adult, they are deemed to be engaging in regulated activity and that adult is deemed to be at risk at that time:

(a) Providing health care (whether physical or mental, including palliative) provision by any health care professional who is regulated by General Medical Council, General Dental Council, Nursing and Midwifery Council, Health Professions Council.
(b) Providing psychotherapy and counselling which is related to health care the adult is receiving from, or under the direction or supervision of a health care professional.
(c) Providing first aid, when any person administering it is doing so on behalf of an organization
established to provide first aid (e.g. Red Cross).
(d) Providing personal care as a result of physical or mental illness, including physical assistance with eating or drinking, going to the toilet, washing, bathing, dressing etc., or supervising, training or providing advice/guidance to an adult to undertake these activities themselves where they cannot make the decision to do so unprompted.
(e) Providing social work.
(f) Assisting with general household matters (e.g. managing a person’s money, paying their bills,
shopping on their behalf).
(g) Assisting in the conduct of a person’s affairs (e.g. undertaking lasting or enduring power of attorney for an adult under the Mental Capacity Act 2005, being an independent mental health advocate etc.).
(h) Conveying (e.g. driving a person specifically to convey them to and from places to receive care as detailed above).

3.5.2 Full definitions of regulated activity in relation to adults can be found here:

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3.5.3 The roles of anyone working in the College’s Heath Centre are considered to involve engaging in regulated activity with adults as defined by the relevant legislation.
3.5.4 The roles of the College’s Dean, Tutors (including Postgraduate Tutors, Senior Tutor, Deputy Senior Tutor [Postgraduates] and Tutor for Discipline), Directors of Studies, Supervisors, the Precentor and Porters are not ordinarily considered to involve engaging in regulated activity with adults as defined by the relevant legislation.
3.6 Regulated activities in relation to Children:
3.6.1 In outline, regulated activities are those activities which people who have been barred by the DBS are prohibited from undertaking.
3.6.2 A regulated activity in relation to children comprises:

(a) unsupervised activities: teaching, training, instructing, caring for or supervising, or providing advice/guidance on wellbeing, provide personal care, or driving a vehicle only for children;
(b) working for a limited range of establishments, with opportunity for contact e.g. schools, children’s homes, childcare premises;
(c) Relevant personal care; or
(d) Registered childminding; and foster-carers.

3.6.3 Work under (a) or (b) is considered regulated activity only if done regularly.
3.6.4 Full definitions of regulated activity in relation to children, including definitions of regularity, can be found here:  
3.6.5 The roles of all those working in the College’s Admissions Office are considered to involve engaging in regulated activity with children under 18 regularly as defined by the relevant legislation.
3.6.6 The roles of the College’s Dean, Tutors (including Postgraduate Tutors, Senior Tutor, Deputy Senior Tutor [Postgraduates] and Tutor for Discipline), Directors of Studies, Supervisors, the Precentor and Porters are not considered to involve engaging in regulated activity with children under 18 regularly as defined by the relevant legislation. Nor are supervisors on the College’s outreach schemes due to the procedures and measures the College has in place to mitigate risks (these are supervised activities).

4. Roles

4.1 The Senior Tutor is the College’s designated Safeguarding Officer. As such, they take overall ownership of the policy and will promote the importance of safeguarding within the College.

4.2 The three Deputy Safeguarding Officers are the Deputy Senior Tutor (Postgraduates), Head of Health and Wellbeing and College Nurse and the Tutor for Admissions and Outreach. The Deputies provide leadership, advice and decisions in the absence of the Senior Tutor. They provide an additional resource to monitor and provide more detailed awareness of safeguarding matters in the College.

4.3 Given the complexity of safeguarding matters, it is essential that any concerns are reported to the Safeguarding Officer to ensure that one person has access to all the relevant information. This is particularly important where a number of seemingly minor issues may collectively give rise to a more substantial concern.

4.4 In the event that a complaint or accusation is made about the Safeguarding Officer, this will be considered independently by the Master.

4.5 Each Head of Department is accountable for the adoption and implementation of this policy and for promoting safeguarding within their Department if (i) they are initiating or accepting activities which involve Children or Adults at Risk or Regulated Activities or (ii) if they are advised by a Head of Department who is initiating or accepting activities which involve Children or Adults at Risk or Regulated Activities that their department will be involved in its delivery and are advised of the extent of safeguarding issues which arise.

5. Planning activities

5.1 No activities which in the planning and assessment stage give rise to higher than normal and unmanageable risks will be undertaken.

5.2 Particular care should be afforded to children under the age of 16.

5.3 It is the responsibility of Heads of Department to retain oversight for any regulated activities within their area and to ensure:
a) appropriate training and supervision is available to those who are likely to be College Participants;
b) occasions in which College Participants will need to work alone in an unsupervised way are minimised; and
c) that the regulated activities are appropriately risk assessed;
d) that Adults at Risk and Children engaged in regulated activities are given clear information about how, and to whom, they can report any safeguarding concerns.
 

5.4 College Participants who are working off the college premises and in other institutions such as schools and colleges should work with the host institution to ensure that they understand and comply with the host institution’s relevant safeguarding policies and procedures.

6. Risk Assessment

6.1 It is the responsibility of Heads of Department to ensure:
a) that a risk assessment is undertaken for regulated activities within their area which
• considers how the risks identified can be minimised or eliminated
• outlines the local processes for reporting concerns
• takes account of health and safety considerations and
• records training requirements;
b) that completed risk assessments are made available to College Participants who are involved in the activity; and
c) that the implementation and review of actions identified within a risk assessment is undertaken in a timely manner.
d) That particular care is taken where children under the age of 16 are involved.

6.2 If the College makes its facilities available to external parties for activities which are not covered by this policy, it is the responsibility of the Head of Department, normally the Conference Office or in relation to the Senior Combination Rooms, the President, who makes the arrangements with the external parties to ensure that they have their own policies in relation to safeguarding and have prepared risk assessments thereunder before permitting the external party to use the College’s facilities (as in 2.3). If in doubt they should consult with the Safeguarding Officer.

7. Induction and training

7.1 It is the responsibility of the Head of Department to:
a) Ensure that College Participants within their area are familiarised with relevant parts of this policy.
b) Ensure that College Participants complete safeguarding training appropriate to the activities they will be engaged in, including any identified in the risk assessment.
c) Record and monitor on-going requirements for such persons.

8. Recruitment and Disclosure and Debarring Service (DBS) checks

8.1 Recruiting to the role of Senior Tutor, and roles in the Admissions Office or Health Centre will require:
(a) Enhanced DBS check
(b) A member of the interview panel to have completed safer recruitment training
(c) Any additional pre-employment checks which appear to the interviewers to be appropriate to the individual’s circumstances
(d) checking the applicants’ professional qualifications and standing 
(e) references from recent previous employers.¹

The Head of Department must agree with the Head of HR if an enhanced DBS check is required under this policy and take steps to obtain it.

8.2 The Safeguarding Officer will refer someone to the DBS if they:
a) Have had their employment with the College terminated because they harmed someone;
b) Have had their employment with the College terminated or job role limited because they might have harmed someone; or
c) Would have had their employment with the College terminated for either of these reasons, but they resigned first.

¹ College Porters are DBS checked as a matter of good recruitment practice, but not as a matter of the expectation of regulated activities under this policy.

9. Arrangements for supporting students under the age of 18

9.1 The College does not take on the authority, rights or responsibilities of parents. However, when admitting a student under the age of 18 when coming into residence, the College will consider the following, while they remain under 18:
a) The format of tutorial support and teaching and will seek, insofar as their educational experience would not be compromised, to avoid singleton supervisions. It is recognised, however, that one-to- one contact with Tutors, Directors of Studies and Supervisors at meetings may be necessary. Where Supervisors are teaching a student under the age of 18 once a week or more regularly, they will either need to be supervised or be DBS checked. It is the responsibility of the Director of Studies to arrange this mitigation.
b) IT – Use of the internet by under-18s will not be differentiated.
c) Alcohol and student-arranged activities – at activities covered by this policy, students under the age of 18 will not be provided with alcohol. It is acknowledged that individual students must also bear responsibility for their actions at any event. Safeguarding issues will be covered at the sign-off stage with student organisers. Consideration should be given to any risk posed by students over 18 at these events.
d) The College Bar – the College has existing systems and practices to prevent underage drinking. No student under 18 is permitted to work in the College bar.
e) Liaison with Faculties and Departments – the College will inform/consult with the relevant Faculty or Department as early as possible about any student who will be under 18 when admitted so that the University can put appropriate measures in place to meet its safeguarding obligations.

9.2 Residential accommodation will not be provided on a shared basis for under 18s, unless in exceptional individual circumstances which are justifiable for the safety of the individual.
The College will take particular care when making admissions arrangements for incoming students under the age of 18, and will consider any reasonable amendments which need to be made in relation to each individual.

10. Residential events for young people under the age of 18 organised by the College

10.1.1 The College may from time to time run residential events for young people under the age of 18 as part of its outreach programmes. These will not normally be offered to students under the age of 16.

10.1.2 A member of the Admissions Office must be present and on-site at all times during the course of a residential event, and must act as the point of contact between participants and the Safeguarding Officers.

10.1.3 The College will employ adult undergraduate helpers to assist Admissions staff with delivery of residential events, such that the ratio of participant to staff is never greater than 10:1.

10.1.4 A risk assessment for each residential event will be carried out in advance by Admissions staff in consultation with the Safeguarding Officer or a Deputy Safeguarding Officer.

10.2 Online activities with young people under the age of 18
a) Events hosted by Schools
1. Where College Participants are participating in an event which is hosted by a school through their own platform, the Head of Department organising the event must ensure the school:
a. has its own safeguarding procedures in place.
b. provides a member of staff to be present throughout the event to act as moderator
c. disables direct/private messaging between individual school participants and College Participants to be disabled.
2. Where these requirements cannot be met, the Head of Department will ensure alternative arrangements offer the same level of security.

b) Events hosted by the college
1. All online events will be logged centrally and record of these will be kept for five years, and staff should record the length, time, date and attendance of any sessions held. The names of all presenters will be recorded. No personal data relating to attendees will be held for these purposes. This file is stored on the Caius shared drive in a password protected folder called ‘Logs of online events’. Recordings, where appropriate (see 7.), will only be made of webinars, where no attendee interaction or data is captured, and will be kept for at least one year.
2. Staff should let their team members be aware of online events that are planned.
3. Staff should consider whether participants need to join live webinars with sound and audio. Where there are large numbers of participants, staff should consider running the session in Webinar mode where participants can only communicate through the chat and Q and A and video and voice are disabled, unless there are clear pedagogical reasons to do otherwise. The mode of communication should be made very clear to participants prior to the event. Staff should be aware that some participants may not want to join with video or audio, so should be given the choice, where possible.
4. Staff running a programme of events should consider the risks associated with extended work with the same groups of students and mitigate these identified risks.
5. Staff should ensure that any members of their own household are aware of any recording ahead of time, so that we can limit the chance of anyone not connected to college or the schools we work with appearing in the background. Backgrounds should be blurred where there is any possibility of interruption.
6. Staff should be clear about the expectations of student behaviour before and during the session. Participants should be asked to agree to a code of conduct prior to the event. Participants will be reminded at the beginning of the session about:
a. Appropriate behaviour around using the chat, Q and A and unmuting and speaking where this is enabled.
b. What to do if they have any safeguarding concerns.
The event organiser reserves the right to end a session or remove a participant if their behaviour or behaviour of anyone in their household contravenes the code of conduct. The lead member of staff should follow up on this with a teacher or parent/carer, as appropriate. An incident report should be completed if necessary.
7. Wherever possible, online sessions should be run by 2 or more staff and one of these should be DBS checked. Where there is not the capacity to have 2 staff in a session, other team members should “drop in” to the session if they are able. Otherwise a recording of the event should be made and the event must be delivered in webinar form; there person delivering the event must be DBS checked.

11. Raising and dealing with a concern or allegation of abuse

11.1 College Participants can raise a concern or allegation of abuse with the Deputy Safeguarding Officers who will escalate matters to the Safeguarding Officer, or directly with the Safeguarding Officer

11.2 Any person, with good reason, may raise a safeguarding concern with the Safeguarding Officer in relation to Children or Adults at Risk where it is connected with College Participants or an event organised by the College.

11.3 To ensure the safety and welfare of the Adult at Risk or Child is prioritised the Safeguarding Officer will ensure that they (or a nominated deputy) are available during normal working hours to respond to allegations, and for procedures to be in place should issue arise outside of normal working hours.

11.4 In the event there is a risk of immediate serious harm to a Child or Adult at Risk, the emergency services should be contacted via 999 without delay. Anybody can make a referral in these circumstances. The Safeguarding Officer should then be notified of the case.

11.5 A referral should be made to the Safeguarding Office (or Deputy) even where concerns are seemingly minor; in some instances it is a pattern or range of minor incidents which, when taken together, amount to a more significant concern requiring investigation.

11.6 Appropriate records will be retained by the Safeguarding Officer in accordance with the College’s Data Protection Policy. Where the matter relates to both staff and students, the Safeguarding Officer will determine where the file should be kept.

11.7 In consultation with the Master, Senior Bursar, Domestic Bursar and Head of HR the Safeguarding Officer will be responsible for contacting any statutory agencies such as the Local Safeguarding Children Board (LSCB) or the Police, if necessary. The Safeguarding Officer will also have responsibility for fulfilling any legal obligations to report an individual to the DBS.

11.8 The College is not expected and will not attempt to investigate suspicions of abuse independently.

11.9 Where a suspicion needs to be investigated by the relevant authority, it may be necessary for the College to do one or more of the following:
a) move the victim of an alleged safeguarding breach to a safe place;
b) suspend the person(s) about whom an allegation or suspicion has arisen;
c) prevent the person(s) about whom an allegation or suspicion has arisen from engaging in any regulated activities.

11.10 Serious safeguarding breaches may constitute gross misconduct under the College’s disciplinary policy and may lead to summary dismissal.

12 Relevant legislation

12.1 The following legislation is relevant to this policy because it has influenced its introduction and/or its content:
a) Health and Safety at Work Act 1974
b) Rehabilitation of Offenders Act 1974
c) Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
d) The Police Act 1997
e) Protection of Children Act 1999
f) Management of Health and Safety at Work Regulations 1999
g) The Human Rights Act 1998
h) Sexual Offences Act 2003
i) The Children Act 2004
j) Safeguarding Vulnerable Groups Act 2006
k) Equality Act 2010
l) Protection of Freedoms Act 2012
m) Working Together to Safeguard Children 2015.

The Protection of Freedoms Act 2012 is of particular importance as all decisions made to bar individuals from working with children or adults at risk are now made by the Disclosure and Barring Service (DBS) under this legislation.