Date: January 2026
Review Date: October 2026 (or sooner if statutory guidance changes)
Policy Owner: Designated Safeguarding Lead (DSL)
Nominated Governor: Safeguarding Governor
Version: v01.26
Refreshed for KCSIE 2025 — signed off April 2026
This policy was refreshed on 2026-04-29 to align with current statutory guidance: KCSIE 2025, Online Safety Act 2023 (phased duties on user-to-user services), DfE Filtering and Monitoring Standards 2024, Worker Protection (Amendment of Equality Act 2010) Act 2023 (preventive duty re sexual harassment, including third-party harassment), and emerging AI safeguarding considerations (DfE Generative AI in Education 2025, ICO Children’s Code).
Status: live — signed off 29 April 2026 by Proprietor and Governing Body.
1. Policy Statement and Purpose
The Haven is committed to ensuring that all allegations of abuse or inappropriate conduct involving adults working with children are managed promptly, proportionately, and fairly.
This policy:
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prioritises the safety and welfare of children and young people;
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ensures fair and respectful treatment of staff and volunteers;
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complies with Keeping Children Safe in Education (KCSIE) 2025 – Part Four, Working Together to Safeguard Children (2023), and Local Authority Designated Officer (LADO) procedures;
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applies to online, hybrid, and in-person contexts.
2. Scope
This policy applies to:
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all employees, contractors, volunteers, governors, and trustees of The Haven;
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allegations that meet the harm threshold and low-level concerns;
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conduct occurring in person, online, or outside working hours where it may impact suitability to work with children.
3. Core Principles
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Child first: The welfare of children is the paramount consideration.
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Fairness and dignity: All parties are treated respectfully and without presumption.
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No automatic outcomes: Suspension is not automatic and decisions are risk-based.
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Transparency and oversight: All allegations are recorded and managed with appropriate LADO involvement.
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Trauma-informed practice: Processes seek to avoid re-traumatisation.
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Confidentiality: Information is shared strictly on a need-to-know basis.
4. Definitions
4.1 Harm-Threshold Allegation
An allegation that an adult has:
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harmed or may have harmed a child;
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committed or may have committed a criminal offence against or related to a child;
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behaved in a way that indicates they may pose a risk of harm to children;
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behaved in a way that may call into question their suitability to work with children.
4.2 Low-Level Concern
A concern about behaviour that:
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is inconsistent with the Staff Conduct Policy v10.25;
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does not meet the harm threshold;
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may indicate boundary issues or emerging risk if repeated.
Examples include boundary blurring, unprofessional digital communication, or inappropriate language.
5. Key Roles and Contact Details
5.1 Named Roles
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5.2 Contact Details (to be kept updated)
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**Head: Kirsten Roy
**Email: head@autisticgirlsnetwork.org
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**Designated Safeguarding Lead: Kirsten Roy
**Email: dsl@autisticgirlsnetwork.org
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**Proprietor / Safeguarding Governor: Cathy Wassell
**Email: cathy@autisticgirlsnetwork.org
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**LADO Contacts:
**The Haven works with multiple Local Authorities.
Current LADO contact details for each commissioning LA are held in the Safeguarding Contacts Register and on our Safeguarding Policy and are accessible to the DSL, Principal, and Proprietor at all times.
6. Reporting Allegations
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All allegations or concerns must be reported immediately to the DSL or Principal.
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No investigation or questioning should take place before LADO consultation.
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Records must be factual, dated, and objective.
7. Allegations Concerning the DSL or Principal
Where an allegation concerns:
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the DSL → the concern is reported directly to the Principal.
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the Head → the concern is reported directly to the Proprietor / Safeguarding Governor.
In these cases:
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the DSL or Principal must not manage or influence the process;
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the Proprietor/Safeguarding Governor becomes the case manager;
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the LADO is contacted within one working day.
8. Managing the Allegation Process
Stage 1 – Initial Response
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Immediate safeguarding action taken if required.
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LADO contacted within one working day if the harm threshold may be met.
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Advice from LADO determines next steps.
Stage 2 – Interim Safeguarding Arrangements
During investigation:
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The staff member does not automatically continue working with children.
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A risk assessment determines whether:
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duties can continue with safeguards;
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alternative duties are required; or
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suspension is necessary.
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Suspension is a neutral act and used only where there is no reasonable alternative.
Stage 3 – Investigation
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Managed in line with LADO advice.
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May involve police, children’s social care, or internal investigation.
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The staff member is:
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informed as soon as appropriate;
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kept updated;
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advised to seek union or legal support.
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9. Outcomes and Next Steps
Each allegation concludes with one of the following determinations:
9.1 Substantiated
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The allegation is proven.
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Disciplinary action taken in line with employment procedures.
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Referral made to:
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DBS, and
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Teaching Regulation Agency (TRA) where applicable.
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Commissioning schools and LAs informed.
9.2 Unsubstantiated
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Insufficient evidence to prove or disprove.
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No disciplinary action.
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Support offered to all parties.
9.3 Unfounded
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Evidence shows the incident did not occur.
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Records retained appropriately but not treated as disciplinary.
9.4 Malicious or False
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Deliberate intent to deceive or cause harm (malicious), or
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Allegation made in good faith but proven false.
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Allegation removed from personnel records.
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Restorative and protective support offered.
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Behaviour and Regulation Policy v10.25 may apply if a pupil acted maliciously.
10. Fair Treatment and Support
The Haven is committed to treating both:
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the child or young person raising a concern, and
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the adult who is the subject of an allegation
with fairness, dignity, and care, regardless of outcome.
Support includes:
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named support person (not involved in investigation);
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access to wellbeing support;
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clear communication and reassurance.
11. Low-Level Concerns (Farrer & Co Guidance)
Low-level concerns are managed in line with Farrer & Co (2023) guidance, which emphasises:
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early reporting;
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transparency;
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pattern-spotting;
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a culture of professional curiosity rather than punishment.
All low-level concerns are:
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recorded in a central log;
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reviewed termly by the DSL and Head;
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escalated if patterns indicate risk.
(See Appendix A for summary of Farrer & Co guidance.)
12. Record Keeping and Confidentiality
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All records stored securely within The Haven’s protected systems.
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Access restricted to DSL, Head, and Proprietor.
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Records retained for 10 years or until normal retirement age, whichever is longer.
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Information shared strictly on a need-to-know basis.
13. Learning, Review and Audit
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Each case concludes with a lessons-learned review.
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Findings inform:
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staff training;
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policy updates;
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safeguarding culture review.
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Termly anonymised audits are conducted by the DSL and Safeguarding Governor.
Appendix A – Farrer & Co Guidance on Low-Level Concerns (Summary)
Low-level concerns:
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sit below the harm threshold;
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are recorded, not ignored;
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may indicate future risk if unaddressed;
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are addressed through reflection, supervision, and proportionate action.
This approach supports:
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safer cultures;
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earlier intervention;
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reduced escalation into serious harm.
14. Related Policies and Guidance
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KCSIE 2025 (Part Four)
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Working Together to Safeguard Children (2023)
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Farrer & Co: Developing and Implementing a Low-Level Concerns Policy (2023)