- Policy Statement
- Safer Working Practices for LAL Representatives
- Named Trained Safeguarding Officers
- Physical Contact
- Alcohol and Drugs
- Safer Working Practices for LAL employees
- Setting Standards
- Social Media
- Other Safer Working Practices
- General and fire safety risk assessments checks will be carried out during Host Family visits by LAL staff or contractors.
- Welfare/Implementing Safeguarding
- Risk Assessments
- Behaviour and Discipline
- What If Scenarios?
- Who’s Who for Children
- Supervision Ratios
- Emergency Procedures
- Age Appropriate Activities
- Arrival and Departure Arrangements
- Unaccompanied minors procedure
- Recognising Child Abuse
- Physical Abuse
- Emotional Abuse
- Sexual Abuse
- Handling Allegations
- Safer Recruitment
- Background check
- What to do if the Background Check results have not arrived before employees start work
- What to do if the disclosure comes back with a criminal record
- The Recruitment Process
- All staff to undertake training
Safeguarding is about:
- building and not compromising relationships of trust between under 18s and adults
- ensuring appropriately safe systems are in place for the well-being of under 18s
- having clear procedures in place if things do go wrong
LAL carries out activities which bring our employees and people working on behalf of our organisation into regular unsupervised contact with children. LAL acknowledges its duty of care to safeguard and promote the welfare of children and is committed to ensuring our safeguarding practices reflect statutory responsibilities, government guidance and complies with best practice.
This policy applies to all employees, other individuals associated by formal arrangement with LAL, 3rd parties, host families and volunteers whose duties bring them into contact with children for which LAL is or could be held responsible. For the purpose of this safeguarding policy the aforementioned will be referred to as LAL Representatives and a child is defined as a person who is under 18 years of age.
This policy recognises that the welfare and interests of children are paramount in all circumstances. It aims to ensure that regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation or socio-economic background, all children have a positive and enjoyable experience at LAL in a safe and child-centred environment.
As part of our safeguarding policy LAL will:
- promote and prioritise the safety and wellbeing of children.
- ensure everyone is aware of their roles and responsibilities in respect of safeguarding and is provided with the resources and appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children
- ensure appropriate action is taken in the event of incidents/concerns of abuse and that support is provided to the individual/s who raise or disclose the concern
- ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
- prevent the employment/placement of unsuitable individuals
- ensure robust safeguarding arrangements and procedures are in operation.
Safer Working Practices for LAL Representatives
Named Trained Safeguarding Officers
LAL’s Designated Persons for Safeguarding Children in the Organisation are:
Laura Holton LAL Summer Schools US & LAL Fort Lauderdale
Cintia Leone LAL Boston
They have both been awarded the Level 3 Safeguarding Children Practice qualification.
LAL Representatives should:
- Never physically chastise a child.
- Never touch a child in any way that could be considered indecent.
- Encourage children to undertake self-care tasks independently.
- Make themselves aware of cultural or religious sensitivities about physical contact.
- Understand that physical contact in any circumstances can be easily misinterpreted.
- Treat children with respect.
- Avoid all contact with intimate parts of their body.
It is understood that an LAL Representative may have physical contact with a child in order to prevent accident or injury to themselves or anyone else (e.g. to prevent a fall), or in the case of medical assistance being needed (e.g. to administer first aid). If a child is hurt or distressed, the LAL Representative will do his/her best to comfort or reassure the child without compromising his/her dignity or doing anything to discredit the person’s own behaviour.
LAL Representatives will use clear and simple lexis and always refrain from using foul, blasphemous and offensive terminology.
LAL Representatives should not behave in such a way that would leave any reasonable person to question their suitability to work with children or act as a role model.
LAL Representatives should be aware that behaviour in their personal lives may impact upon their work with children.
LAL Representatives should never bring to the child’s attention any material that could be construed as pornographic.
Other than for the purposes of safeguarding the child, LAL Representatives must not seek or agree to meet them anywhere outside of the normal workplace without the full prior knowledge and agreement of the parent, guardian or carer.
LAL Representatives should wear clothing that is appropriate to their role and is not likely to be viewed as offensive, revealing or sexually provocative. This clothing should not distract, cause embarrassment or give rise to misunderstanding. Clothing should be absent of any political or otherwise contentious slogans.
LAL Representatives are required not to in any way induce children for which LAL is or could be held responsible to undertake any actions against their wishes as a result of fear or favour. Gifts should only be given as part of an agreed reward system and should be of insignificant value.
Alcohol and Drugs
LAL Representatives must not distribute, purchase or sell alcohol to any children for which LAL is or could be held responsible.
LAL strictly prohibits:
- Even if consensual, any sexual, intimate, dating or other romantic relationship between any LAL Representative and any current or former student under the age of 18; or
- Any form of communication with a child which could be interpreted as sexually suggestive or provocative i.e. verbal comments, letters, notes, electronic mail, phone calls, texts
- LAL Representatives discussing their own sexual relationships with or in the presence of children.
Safer Working Practices for LAL employees
All new employees within LAL that have direct, unsupervised access to children are issued with a role specific handbook as part of the induction process which outlines the key elements of their role. Handbooks include references to tasks the employee is expected to undertake, a summary of the staff dress code, safeguarding, fraternisation and social media policies as well as outlining LAL’s overall standards and expectations.
As part of the induction process all new staff are required to read and confirm in writing that they have read the Employee Handbook and associated policies.
Host Families are also issued with a Host Home Manual that provides rules, help and advice for hosts.
In order to protect children and staff from adverse effects that could result from the improper use of Social Media, staff use of Social Media must comply with LAL’s Fraternisation policy.
In addition staff should not:
- initiate or accept ‘friend’ or similar requests from any current or former LAL student under the age of 18 and for as long as they are under 18.
- use internet or web-based communication channels to send personal message to children.
- give their personal contact details to children including their mobile phone number.
Other Safer Working Practices
General and fire safety risk assessments checks will be carried out during Host Family visits by LAL staff or contractors.
Risk assessments will be carried out for all on site and off site activities to remove and eliminate risk where possible. This will include first aid cover and accident reporting. Staff are required to read these risk assessments and will be advised of any subsequent changes to these risk assessments.
Behaviour and Discipline
The children will have their behavior monitored and controlled in order to minimise any danger that they present to themselves or others.
What If Scenarios?
All staff that answer the emergency phone outside of standard hours are fully briefed and trained to advise the caller on a wide range of ‘what if’ scenarios.
Irrespective of the type of accommodation, unless specifically by the written request of the parent/guardian of the children concerned under no circumstances will a child be placed in the same room as an adult. Children sharing a room will be of the same gender. This applies to our Host Families and Residential Accommodation. LAL will ensure that students under 16 lodged by them in homestay or residential accommodation will not be lodged with students of 19 years or older unless specifically advised in advance.
Who’s Who for Children
During first day inductions children will be introduced to all individuals whom they can contact for help and advice. This information is also provided in the LAL Young Learner Student Handbook.
Children are provided by a variety of means including verbal instruction and the student handbook easy-to-understand information regarding US laws, personal safety, road safety, fire safety, beach and sea safety as well as being provided with instructions should they become lost.
Regular fire alarm checks take place within our learning centres. As part of the student induction process, children are shown where the fire exits are located and where to meet if the fire alarm is activated.
LAL has a number of staff who are trained to provide emergency first aid.
When transporting children, the transport will be checked to ensure it is roadworthy and adequate for the purpose. Appropriate insurance will be kept up to date and adequate to cover such assignments.
Children are also issued with an LAL Student ID card on arrival which has phone numbers to call in an emergency.
Lessons have a maximum size of fifteen students, with some courses having a lower maximum number. One responsible adult will be assigned to each class.
On activities and excursions the supervision ratio is one responsible adult to maximum of twenty students. Students under 12 years old have a supervision ratio of one responsible adult to twelve students.
In residential accommodation LAL will ensure that the ratio of residential adults to students will be at least 1:20 for students aged 13-18 and 1:15 for students under 13, to include LAL staff and accompanying Group Leaders. First aid facilities and an appropriately trained member of staff will be available at all times.
A responsible adult is required to be present overnight at host homes and will normally be present but always contactable when children under 18 are at home.
The Host Home manual clearly outlines to the host the procedure to be followed in the event of emergencies. Information includes office opening hours, contact numbers, out of hours contact numbers, what the family should do if a child becomes ill, requires first aid, requires a doctor or dentist appointment and is late home or missing. For children staying at our summer schools, all staff are trained to deal with emergency situations as part of their induction. This information is reiterated during host family visits and during the host family open event.
LAL provides parents and/or agents, group leaders, host families and students with 24 hour emergency contact numbers.
Children are made aware of emergency procedures in all circumstances including when in the residence, in school or on activities.
The Young Learner Student Handbook details emergency contact information and procedures.
Age Appropriate Activities
Host families are made aware via the ‘host home manual’ of the rules regarding activities children may undertake outside of scheduled activity times, the level of supervision required by the host family and what time they are expected home at a specific location including curfew times.
Arrival and Departure Arrangements
All under 18s are fully supervised from their point of arrival to their accommodation/learning center and from the learning center to the security zones and their points of departure.
At any port of arrival under 18s will be supervised by a LAL Representative until they are handed to an LAL Representative who will escort them to their destination.
For more local airports the transfer will deliver under 18s directly to the host family.
On departure for all airports either the host family or an LAL Representative will take under 18s to the specified meeting point where a member of LAL Representative will be waiting for them and will escort them to the airport. On arrival at the airport the LAL Representative will take the student to the check-in desk and assist them with checking in and dropping off bags. They will then be taken to the security point where they will be given instructions.
All children will be equipped with our pre-arrival information that contains our emergency number. They are instructed to call this number if they have any issues at the airport before they meet up with an LAL Representative for example in baggage reclaim.
Unaccompanied minors procedure
At the port of arrival airline staff will pass the child to an LAL Representative who will accompany the child to their destination.
Where applicable host families will be required to bring the child to evening activities. A representative from the learning centre will then either accompany the child back to their host family or a private transport company will be used.
Recognising Child Abuse
LAL Representatives are trained to monitor children for evidence of abuse. Child abuse falls into one or more of four categories: physical abuse, emotional abuse, sexual abuse and neglect.
Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child.
Emotional abuse is the persistent emotional ill treatment of a child such as to cause severe and persistent effects on the child’s emotional development, and may involve:
- Conveying to a child that s/he is worthless, unloved, inadequate, or valued only insofar as s/he meets the needs of another person
- Imposing developmentally inappropriate expectations e.g. interactions beyond the child’s developmental capability, overprotection, limitation of exploration and learning, preventing the child from participation in normal social interaction
- Causing a child to feel frightened or in danger e.g. witnessing domestic violence, seeing or hearing the ill treatment of another
- Exploitation or corruption of a child
Some level of emotional abuse is involved in most types of ill treatment of children, though emotional abuse may occur alone.
Sexual abuse involves forcing or enticing a child to take part in sexual activities, including prostitution, whether or not s/he is aware of what is happening. Activities may involve physical contact, including penetrative and non-penetrative acts.
Sexual activities may also include non-contact activities, e.g. involving a child in looking at / production of abusive images, watching sexual activities or encouraging her/him to behave in sexually inappropriate ways. It may include use of photos, pictures, cartoons, literature or sound recordings via internet, books, magazines, audio cassettes, tapes or CDs.
Neglect involves the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health and development. This could involve failing to:
- Provide adequate food, clothing or shelter (including exclusion from home or abandonment)
- Protect from physical and emotional harm or danger
- Meet or respond to basic emotional needs
- Ensure adequate supervision including the use of adequate care-takers
- Ensure access to appropriate medical care or treatment
- Ensure that her/his educational needs are met
- Ensure her / his opportunities for intellectual stimulation are met
If a child discloses any information to a LAL Representative suggesting that they have been abused in any way, LAL Representatives should follow the process outlined below. If this information is reported by a child to their host family, the host family should inform LAL as soon as possible using the emergency contact numbers.
Listen to what is being said without displaying shock or disbelief. A common reaction to news as unpleasant and shocking as child abuse is denial. However, if you display denial to a child, or show shock or disgust at what they are saying, the child may be afraid to continue and will shut down. Accept what is being said without judgement. Take it seriously.
Reassure the child, but only so far as is honest and reliable. Don’t make promises that you can’t be sure to keep, e.g. “everything will be all right now”. Reassure the child that they did nothing wrong and that you take what is said seriously.
Don’t promise confidentiality – never agree to keep secrets. You have a duty to report your concerns. Tell the child that you will need to tell some people, but only those whose job it is to protect children. Acknowledge how difficult it must have been to talk. It takes a lot for a child to come forward about abuse.
Listen quietly, carefully and patiently. Do not assume anything – don’t speculate or jump to conclusions. Do not investigate, interrogate or decide if the child is telling the truth. Remember that an allegation of child abuse may lead to a criminal investigation, so don’t do anything that may jeopardise a police investigation. Let the child explain to you in his or her own words what happened, but don’t ask leading questions. Do ask open questions like “Is there anything else that you want to tell me?” Communicate with the child in a way that is appropriate to their age, understanding and preference. This is especially important for children with disabilities and for children whose preferred language is not English. Do not ask the child to repeat what they have told you to another member of staff. Explain what you have to do next and whom you have to talk to.
Make some very brief notes at the time and write them up in detail as soon as possible. Do not destroy your original notes in case they are required by Court.
Record the date, time, place, words used by the child and how the child appeared to you – be specific. Record the actual words used; including any swear words or slang. Record statements and observable things, not your interpretations or assumptions – keep it factual.
It is not for LAL Representatives to decide if the allegations are true or not. Their role is only to listen and report as accurately as possible. Staff should inform their line manager immediately, who in turn should report to the school General Manager and LAL’s Designated Person for Safeguarding Children.
The appropriate state body will be informed by LAL’s Designated Person for Safeguarding Children within one working day of all allegations that come to LAL’s attention and appear to meet the criteria below:
- behaved in a way that has harmed a child, or may have harmed a child;
- possibly committed a criminal offence against or related to a child; or
- behaved towards a child or children in a way that indicates they may pose a risk of harm to children.
The state has a responsibility to consult LAL, Police and Child Services about whether the criteria above is met and if so to determine which of the three strands listed below should be used to conduct enquiries:
- a police investigation of a possible criminal offence
- enquiries and assessment by children’s social care about whether a child is in need of protection or in need of services
- consideration by LAL of disciplinary action in respect of the individual.
If there is immediate danger to the student immediate action to safeguard the child will be a taken by LAL.
When families apply to be a host home, they are required to complete an application form and sign a host home contract. The application form includes a child protection questionnaire and declaration which has to be signed by all adult residents and regular visitors (over the age of 18) to the household. The main contact will also be required to provide a copy of a valid current enhanced Background Check which is less than 3 years old.
Employees and persons on work experience whose role involves unsupervised contact with children will be required to have an up to date enhanced Background Check every three years. Any persons who cannot be background checked in the US will be required to provide a police check from their country of origin or residence, translated and notarised.
What to do if the Background Check results have not arrived before employees start work
It is LAL’s policy that no one should be allowed to start work before the Background Check is received. This policy is to try to ensure maximum protection by minimising any known risks. The practice of awaiting a Background Check is sometimes difficult to implement fully due to the practicalities on the ground of having to ensure minimum staffing levels at all times. Therefore, General Managers have the discretion to allow school-based staff to commence work under specific measures before receiving a Background Check. These specific measures are to be used only in exceptional circumstances when the delivery of services will be affected and all other alternatives have been considered and exhausted.
What to do if the disclosure comes back with a criminal record
Where the Background Check discloses a criminal record, an assessment to decide the relevance of the criminal record and the suitability of the individual to carry out the duties of the post will be made. To reach a fair and balanced decision this assessment will involve an evaluation of the associated risks. Protection of the applicant’s rights and interests must be weighed against the rights and interests of young learners, including LAL’s duties and responsibilities towards the same. The same process also applies to host families who have a criminal record.
Full assessment details are outlined in LAL’s Recruitment of Ex-Offenders policy.
The Recruitment Process
Within LAL all roles that are based within schools will require applicants to complete an application form. For those positions where an enhanced Background Check is required, the application form and recruitment documentation (including the job description) will state this. LAL’s application forms asks applicants to declare spent and unspent convictions where relevant in addition to asking the applicant to declare and allegations and disciplinary action in relation to working with children. The form also asks applicants to provide details of any gaps in their employment history.
LAL’s job application form states that applicants must give the name and address of two referees from which LAL can seek information regarding the suitability for employment. References must cover the past 3 years of employment and one must be from the applicant’s current employer if applicable. If candidates are not currently working with children, but have done so in the past, the second referee must be from their most recent employer where they worked with children. If the position involves working with children referees will be asked if they believe the applicant is suitable to work with children and whether there has ever been any allegations/disciplinary action regarding behaviour towards children.
References are followed up. Successful applicants are asked to bring in details of their qualifications and ID to prove their identity. All staff are required to complete LAL’s Child Protection disclaimer when commencing employment.
All staff to undertake training
All LAL Representatives whether paid or unpaid will be required to read LAL’s Safeguarding policy as part of their induction process. The importance of safeguarding children is also included in each role specific handbook. All staff that are recruited on a seasonal basis that will have unsupervised contact with children will receive direct Safeguarding training. This training will include the use of a presentation, an explanation of this policy and a multiple choice test to check their understanding.
It is the responsibility of the HR Manager to review this policy annually and more frequently if necessary as per government guidance, legislation change or as a result of any other significant change or event.
LAL Language Centre’s Designated Person for Safeguarding Children in the Organisation is: Laura Holton
- The following outlines the process that the Designated Person should follow after a disclosure:
- Any person should contact the Florida Abuse Hotline when they know or have reasonable cause to suspect that a child or vulnerable adult has been abused, abandoned, neglected, or exploited. The Hotline has counselors available 24 hours a day, 7 days a week.
- The Hotline counselor will determine if the information provided meets legal requirements to accept a report for investigation.
- There are four ways to make a report:
- By Telephone 1-800-96ABUSE (800) 962-2873
- By Fax (800) 914-0004
- By TDD (800) 453-5145
- Web Reporting https://reportabuse.dcf.state.fl.us