Following on from the shocking revelations brought to light by Everyone’s Invited, it came as no surprise that the Independent Schools Inspectorate (ISI) announced changes to its inspection framework, with a renewed focus on sexual abuse.
The ISI’s focus on sexual abuse sits alongside this year’s substantial September update to Keeping Children Safe in Education (KCSIE). As expected, this updated guidance took a zero-tolerance stance to peer on peer abuse and reinforced the concept of a “whole school approach” to safeguarding.
Preparing for inspections
Since the release of the new guidance over the summer, schools will by now have had a chance to update their policies and train staff on the new requirements. As we enter the second half of the autumn term, this would be a good time for schools to take a moment to prepare for upcoming inspections by reflecting on how well they have implemented the new KCSIE requirements and whether staff are in practice following the school’s policies.
Two of the key themes throughout the updated KCSIE guidance were;
- the need for schools to have processes in place for managing allegations of peer-on-peer abuse, including sexual abuse and sexual harassment, and
- the need for staff to be aware of and to follow those processes.
The dangers of creating a culture of unacceptable behaviour
KCSIE warns against the dangers of creating a culture of unacceptable behaviour and the normalising of peer-on-peer sexual abuse. A very clear obligation is now placed on staff to ensure that victims should be taken seriously, kept safe and never be made to feel like they are creating a problem for reporting peer-on-peer sexual violence or sexual harassment.
Everyone’s Invited highlighted the prevalence of sexual violence and sexual harassment not just at school, but also outside of school and online, as well as within intimate personal relationships. KCSIE’s guidance now takes this into account. Staff need to understand that the absence of reports of sexual violence or sexual harassment does not mean that it is not happening. Staff should be ready to challenge and report any concerning behaviour and must maintain an attitude of “it could happen here”.
The updated guidance has also incorporated the helpful reminder that KCSIE must be read alongside the Government’s updated guidance on Sexual Violence and Sexual Harassment between Children in Schools and Colleges – a document with which all SLTs, DSLs and governors should make sure they are very familiar.
An overhaul to guidance for handling allegations against staff
Research that fed into the Independent Inquiry into Child Sexual Abuse highlighted that minor breaches of the staff code of conduct have historically often been the first signs that someone working with children would later go on to abuse children. In order to combat this, there has been a significant overhaul in the KCSIE guidance for handling allegations against staff, with the introduction of a section on “low level concerns”.
It is now necessary to distinguish between allegations against staff that may meet the harms threshold and those that do not meet the threshold. It is vital that schools’ policies now include a clear process by which low level concerns can be raised and that that process is compliant with the KCSIE guidance. Schools should also look back over the last couple of months to consider whether the reality of how low-level concerns have been handled since the start of term reflects the requirements of their policy, and to ensure that staff are not applying their own artificial thresholds to assess whether a concern is serious enough to be reported.
The need to stay vigilant
A further key theme of the updated KCSIE is the need to ensure that staff are vigilant to the possibility that pupils may be the victims of child criminal exploitation and child sexual exploitation. The updated guidance helps to clarify what these two types of abuse entail and the different ways in which boys and girls may be impacted by them.
The updated positioning of this guidance in Part 1 of KCSIE spells out the need for staff to be proactively alert to the indicators of these types of abuse, and it is crucial that staff understand the importance that is now being placed on safeguarding against such abuse.
A firm focus on online safety
Significant new obligations have been placed on schools in relation to online safety and the need for staff to be trained in online safety and to ensure that children are taught about online safety. KCSIE’s guidance seeks to combat the four main areas of online risk – the “4Cs” – content, contact, conduct and commerce. KCSIE also highlights the potential for initiation rituals to take place online, as well as peer on peer abuse.
In preparation for their inspections, school need to keep both staff training and pupil teaching on online safety under review, with continual updates to ensure that their training and teaching incorporates the very latest areas of online danger and risk.
The KCSIE update contains new guidance on contextual safeguarding, and the part schools play in social care assessments. There is additional guidance on the record keeping processes that school should adhere to, and you should ensure that includes welcome guidance on handling reports of historic abuse, which schools should make sure is incorporated into their policies and processes.
How Moore Barlow can help
If you would like assistance in updating any policies to ensure they are compliant with the latest guidance, please get in touch and we would be happy to help.
One of the lessons of the testimonies shared on Everyone’s Invited is that protecting children needs to be an ongoing process, and not simply a one-off exercise of writing a child protection policy.
Schools need to ensure that every concern is investigated and action should be taken against any staff who fail to follow the reporting procedures set out in the policies. If you would like assistance in conducting any investigation or disciplining any staff for policy breaches, we are available to guide you through the process.
