The DfE has produced a draft of KCSIE 2019 which will come into force on 2nd September. There are comparatively few changes from the current version, but there are some significant actions schools will need to undertake to ensure their policy and practice are fully compliant in September.
In this blog, I highlight the significant changes and possible actions for schools in response.
• In Part 1, which must be read and understood by all staff, there is a considerable re-ordering of information in the sections on abuse and neglect. This makes the document flow better and the information easier to follow.
• Information about transitional arrangements to move from Local Safeguarding Boards to Safeguarding Partners has been removed as they must be completed by September 2019. There is an updated section on multi-agency working (para 68-75) to reflect these changes.
• In paragraph 27 on peer on peer abuse the meanings of sexual violence and sexual harassment are clarified. And upskirting is added to this section with a very clear definition.
• This is followed by two new paragraphs (29 &30) on serious violence which helpfully highlight possible signs that children are at risk or involved in serious violent crime.
• There is an update to the link to the NSPCC whistleblowing line.
• There are updated references to the new OFSTED framework and changes in the inspection of Independent Schools (para 91).
• The requirements under the new Relationships Education and RSE frameworks are included, but no details are given.
• There are minor changes in Part 3
o Removing the reference to section 167A of the Education Act under the section on DBS and barred lists
o A wording and reference change about overseas qualified teachers applying for QTS status in England
o Clarification about the need for maintained schools to carry out section 128 checks on their governors and how to do this (para 173)
o Clarification that while DBS is mandatory for maintained school governors, it is not for associate governors appointed to serve on governing body committees (para 174).
• In Annexe A there is
o a change in the title of the section on ‘So called Honour-based Violence’ to highlight that this includes FGM and Forced Marriage
o a new paragraph on upskirting under the section on Sexual Violence and Harassment between Children.
• In Annexe C, there is a link to the new DfE guidance Teaching Online Safety in school.
Possible actions for Schools, particularly for DSLs
• If there have been any changes in DSLs over the summer check that your policy, website and information posters around the school reflect this.
• Ensure all staff re-read and understand the new Part 1 and Annexe A. It might be worth highlighting the changes. On the other hand, we want them to check their understanding of the whole document, not just skim read for the changes. Also, you should be picking up the changes through your safeguarding update at the beginning of term.
• Ensure that you know and understand the new Multi-agency Safeguarding Partners arrangements for your area.
o Check have any of the contact information, phone numbers or emails for social care changed over the summer. If so, update the posters and other information around the school.
o Share the new arrangements with staff so that they are able to make referrals to social care if necessary.
o Check that staff understand the role of social care, health and police as Safeguarding Partners.
o Check the Governors, particularly, but not exclusively the Safeguarding Governor, know about and understand the new Safeguarding Partner arrangements.
o Update your policy to reflect the changes and remove information about the LSCB.
o Check if you need to make changes to the information on your website
o Consider how this information will be shared with parents
• Offer training and explanation of upskirting to staff and ensure that it is included in your safeguarding policy. It is important that staff both know what this is and understand its impact. It is not enough to say we are a ‘no phones school’ as staff may need to respond to disclosures about upskirting. The definition included in KCSIE will be useful for this. There is more information on the new law on upskirting which made this a criminal offence available. Consider the possible impact of upskirting on staff and how you would provide support to them.
• Ensure that all staff are fully aware of the signs that a child is at risk of or involved in serious violent crime and/ or criminal exploitation. It is important to remember that the grooming processes for all forms of child exploitation; criminal, county lines, sexual and indeed radicalisation are very similar. Staff need to be able to identify the signs and indicators of these and share their concerns immediately with the DSL.
• Check you have the right link to the NSPCC whistleblowing line in your policy. Check that all your posters to remind staff about whistleblowing are up to date and still in place after the summer.
• Check that there are clear and up to date links between your safeguarding policy and your SRE policy.
• Check that your policy and staff training fits with the latest OFSTED or Independent Schools Inspectorate framework including the safeguarding guidance See my blog on the changes to the OFSTED guidance for help.
• If you are a maintained school, ensure that all governors have had a section 128 check using the Employer Secure Access Portal on the Teacher Services’ web page.
• Review your policy and practice for teaching online safety in line with the new DfE guidance Teaching online safety in school, including the commitment to a whole school approach to online safety. My blog summarising this guidance may be helpful.