Introduction and Purpose
Safeguarding is everyone’s responsibility within Primary Goal and is of paramount importance. Primary
Goal will take every reasonable step possible to safeguard and promote the welfare of all learners and
staff. This policy sets out the responsibilities of all those working within Primary Goal to protect children,
young people and vulnerable adults from abuse, harm, exploitation or neglect. As such, this policy sets
out the commitment Primary Goal makes to ensuring our safeguarding policies and procedures are
compliant with current legislation and guidance, are robust, and are fit for purpose.
This policy is to be read, understood and adhered to at all times by all those working with, or on behalf, of
Primary Goal. This includes all employees, Board members, volunteers, agency or associate staff,
employers and learners.
Statutory Framework
This policy has been written in accordance with the following guidance documents and legislation:
• Keeping Children Safe in Education 2024 (Part 1), Department for Education
• Working Together to Safeguard Children 2023, Department for Education
• The Children Act 1989 and 2004
• The Education Act 2002
• The Care Act 2014
• The Equality Act 2010
Should any new legislation be introduced, or changes are made to the existing legislation, this policy will
be reviewed and updated accordingly.
Procedures
The following procedure should be followed in all cases of an actual or potential safeguarding concern
occurring:
In all cases, a Safeguarding Cause for Concern Form should be completed to record details of the
safeguarding concern. As much information as possible should be documented to ensure that
appropriate action may be taken. In situations where the safeguarding concerns is of an urgent
nature, the Safeguarding Cause for Concern Form should be filled out once appropriate action has
been taken to ensure the safety of those involved (i.e. the emergency services have been contacted).
Reports must be made to the Designated Safeguarding Lead as soon as possible and within 24 hours
of the concern occurring. Reports are reviewed as soon as possible, but always within 1 working day
by Barbara Veeramallay-Permaul (Chief Operating Officer / Designated Safeguarding Lead), or
another appropriate Senior Manager in the DSL’s absence.
If an individual would like to discuss a potential or actual safeguarding concern in more detail, they
can do so via the following channels:
• Contact Barbara Veeramallay-Permaul (Chief Operating Officer/Designated
Safeguarding Lead) via 02475 267 601
• If the DSL is unavailable, contact your line manager
• Email safeguarding@primarygoal.ac.uk
• Call 02475 267 601
Staff should not attempt to investigate safeguarding concerns themselves. All concerns should be
reported to the Designated Safeguarding Lead to conduct any such investigations.
Safeguarding Learners
The safeguarding and welfare of learners is of paramount importance within Primary Goal.
Safeguarding and Prevent information and procedures form part of the onboarding process for
learners, including providing information on how to report safeguarding concerns. All learners are
provided with a Learner Handbook at the start of their programme which also provides relevant
information on safeguarding.
Safeguarding and Prevent topics are embedded within the curriculum throughout a learner’s
programme. This is done in a variety of ways which include, but are not limited to live training sessions,
email and Teams communications, and conversations with their Coaches/Trainers in coaching
sessions and progress reviews. The Delivery Team are responsible for the delivery of awareness
coaching/training in the workplace to apprentices to ensure they have a full understanding of keeping
themselves safe from harm. Coaches and Trainers also provide awareness to learners on national and
local risks that they may be exposed to.
The Delivery team is also responsible for educating apprentices in understanding how they might be
drawn into radicalisation. It is the Delivery Team’s responsibility to identify changes in behaviour or
vulnerabilities of the learners that could be indicator of abuse, and to report their concerns to the
Designated Safeguarding Lead. Learners requiring additional learning support (ALS) are also
monitored more regularly as it is recognised that they may present more vulnerabilities to
radicalisation.
Learners and staff have access to the ‘Community Support Index’ which provides signposting
information to national charities, agencies and organisations to support with a variety of
safeguarding concerns. The Delivery Team will draw attention to the Community Support Index to
further support learner safeguarding.
Online Safety
As a digital and IT apprenticeship provider with an understanding of the risks posed in the online
space, our commitment to safeguarding extends into the digital realm. We understand that although
safeguarding policies and processes should be applied regardless of whether concerns are present
online or offline, there may be additional factors in considering and responding to online concerns.
Primary Goal aims to ensure both learner and staff safety online through effective education and
training.
Primary Goal staff should ensure that apprentices are aware of online safety practices and report any
concerns about digital safety to the Designated Safeguarding Lead as per reporting procedures. In
turn, apprentices are expected to use digital resources responsibly and report any issues or
concerns to a member of Primary Goal staff.
Online and digital safeguarding forms party of the mandatory training completed by all Primary Goal
staff upon commencement of employment and is updated annually as a minimum. Staff should seek
to regularly upskill themselves on advancements in digital technologies and their associated risks in
order to inform and support learners.
Additionally, all Primary Goal owned devices utilised by staff are monitored by Senso.cloud which
offers IT monitoring and management software for the purposes of safeguarding. The system will
monitor the keystrokes of users to support in identifying vulnerable or at-risk and users who may pose
a risk to others, as well as any inappropriate or harmful behaviour. This spans across all Primary Goal
and non-Primary Goal systems accessed via Primary Goal devices, including but not limited to emails,
Teams messages, internet searches and personal notes. The DSL is notified of urgent violations that
have been detected by the system allowing for the review and appropriate action to be taken if a risk
is identified.
Missing Learners
Primary Goal is aware that unexplained, unusual or lengthy absences from the workplace, teaching
sessions or pre-arranged meetings need investigating as they could be an indication of a
safeguarding or welfare issue. Learners should inform their Coach or another appropriate member of
Primary Goal staff if they will be absent from their apprenticeship for any reason for a period of 2
calendar weeks or more. Employers are required to notify Primary Goal of any unexplained learner
absence from work, and that Coaches and Trainers follow up missed sessions with the learner and
employer.
If a member of staff has concerns about a learner’s absence, this should be reported to the
Designated Safeguarding Lead or another appropriate member of the Senior Leadership Team using
the usual reporting procedure so that they can attempt contact with the learner. If contact is made,
the Designated Safeguarding Lead or appropriate member of the Senior Leadership Team will work
with the learner, and employer if needed, to provide support, signpost, or make an external referral
where necessary.
In the event that a learner cannot be contacted by a member of staff at Primary Goal, the employer
will be contacted to provide an update on their attendance and also attempt to contact the learner if
necessary. In the event that the learner cannot be contacted by their employer or Primary Goal, their
next of kin will be contacted to check on their welfare. Should these attempts also be unsuccessful,
the emergency services will be contacted.
16–18-Year-Old Learners
Fortnightly reports are produced by the Head of Learning, Quality and Performance relating to the
attendance and engagement of those learners aged between 16 and 18 years old. Staff are expected
to contact learners within this age group more frequently as it is recognised that they may present
more vulnerabilities. For absences relating to learners aged between 16 and 18 years old, all reports
must be made to the Designated Safeguarding Lead within 24 hours of the missed session should
contact not be made. Following this, the Designated Safeguarding Lead, or another member of the
Senior Leadership Team, will attempt to contact the learner’s employer and next of kin to determine
the learner’s safety and assist in contacting the learner. For those learners working within educational
establishments or other such employers that do not operate throughout the calendar year, contact
with the employer will still be attempted in cases of unexplained absence.
Should the learner still be uncontactable and contact to the employer and/or next of kin has been
unsuccessful during this time period, an internal risk assessment will be undertaken within a
maximum of 72 hours. Should it be deemed necessary, a report will then be made to the emergency
services.
Reporting and Record Keeping
All safeguarding concerns should be documented via the Safeguarding Cause for Concern Form
which can be found on SharePoint and is accessible by all staff. For safeguarding concerns raised by
those without access to Primary Goal’s internal SharePoint system (i.e. by a learner via telephone),
the Designated Safeguarding Lead, or another member of staff, will complete the Safeguarding
Cause for Concern form.
Written accounts of safeguarding concerns shall be factual, non-speculative and include direct
quotes where possible to ensure accuracy.
A confidential record will be kept of all cases referred to the Designated Safeguarding Lead, which will
only be shared with those with safeguarding responsibilities within the organisation, or with external
agencies where referral is necessary. All information will be shared on a ‘need to know’ basis in line
with data protection and confidentiality laws.
Written records will be kept securely for a period of six years via a restricted site on Primary Goal’s
internal SharePoint system.
Safeguarding reports are created as part of the Board Report by the Designated Safeguarding Lead
to be shared with the Senior Leadership Team and Board of Governors. This report is provided to help
identify any trends in safeguarding issues and assess the impact of our provision. Confidentiality is
maintained throughout reporting and details of concerns are only shared on a ‘need to know’ basis.
Recruitment and Training
Primary Goal encourages job applicants with a criminal record to disclose this information as soon as
possible in the recruitment process so that the Company can establish the relevance of the
conviction compared to the role. Primary Goal will not discriminate against job applicants on the
grounds of previous criminal convictions that have no relevant bearing on the post being applied for.
Upon an offer of employment being made to a candidate in possession of a criminal conviction which
does not affect the post they have applied for, or any other area of the business, a risk assessment
will be completed by the HR Manager and the CEO to demonstrate that all risks have been considered
and mitigated.
All employees of Primary Goal are required to have an Enhanced DBS certificate. Certificates will be
updated at least once every 3 years. Should there be a delay in staff members receiving a DBS
certificate before their start date of employment, a risk assessment will be completed by the
employee’s line manager, HR Manager and CEO to detail any risk mitigation that will take place whilst
the employee awaits certification.
Upon commencement of employment, all staff are required to undertake safeguarding training via the
Education and Training Foundation (ETF) to demonstrate understanding and competency within
safeguarding practices and procedures. Staff are required to update their safeguarding training on
an annual basis. The Designated Safeguarding Lead is required to be trained to a Level 4 standard.
All staff are required to undertake Prevent training through the Home Office website upon
commencement of employment, which is updated at least annually.
Quarterly drop-in safeguarding sessions are arranged for staff to attend for topical and current
safeguarding updates, training and sharing of best practice. Additional ad-hoc training will also be
provided to staff based on business need, identified risks or updated legislation.
Primary Goal offers Mental Health First Aid training to those staff with an interest in supporting mental
health across the organisation. Once trained, these staff are available for learners and staff as an
additional signposting resource to support with mental health and wellbeing discussions. Should any
staff trained as Mental Health First Aiders have concerns about the safety or welfare of an individual
they are engaging with, the safeguarding concern reporting procedure will be followed.
A record of all staff, associate, Board member and volunteer safeguarding training and DBS expiry
dates are recorded on the Single Central Record (SCR) which is kept up to date by the HR Manager.
Certificates for all trainings can be found in staff members’ Professional Development folders.
Staff Concerns
Employees understand that they should not allow feelings of loyalty towards colleagues interfere
with their judgement when there are concerns about a colleague’s behaviour or conduct in relation
to safeguarding. If staff have concerns about the behaviour of a member of staff, they should:
• Refer to the Company’s Whistleblowing policy for guidance regarding improper conduct or
unethical behaviour.
• Report concerns to the Designated Safeguarding Lead.
In line with Primary Goal’s Performance Management procedures, concerns will be investigated, and
appropriate action taken during the course of any investigation. Where appropriate and necessary,
the Designated Safeguarding Lead will involve external agencies such as the relevant Local Authority
Designated Officer (LADO), Local Adults Safeguarding Boards or Social Services.
Supporting Policies and Documents
This policy should be read alongside the following Primary Goal documents:
• Prevent Policy
• Safer Recruitment and Selection Policy
• Equality, Diversity and Inclusion Policy
• IT Policy
• Artificial Intelligence (AI) Policy
• Whistleblowing Policy
• Complaints Policy
• Employee Handbook
Review
Primary Goal will continue to review the contents of this policy on an ongoing basis and will review
annually as a minimum.
