Safeguarding and Child Protection Policy

Key external contact details

NB. OHS KS2 (Newton Grove) is situated in the Borough of Ealing whilst KS1 (Priory House) and EYFS (Rupert Road) are situated in the Borough of Hounslow.

Key school contact details

Relevant statutory and non-statutory advice

This policy is written with regard to the advice below and in Appendix 1, section 28 of this policy:

• Keeping Children Safe in Education (KCSIE), DfE, September 2025
• Regulated Activity in Relation to Children (Scope), DfE, September 2025
• KCSIE supplement — safeguarding and remote education
• Disqualification Under the Childcare Act 2008 — updated August 2018
• Working Together to Safeguard Children — updated February 2024
• DfE statutory guidance “Children missing education” (2024)
• The Independent School Standards (England) Regulations, DfE, 2014 (updated 2019)
• The National Minimum Standards for Boarding, DfE (updated 2022)
• EYFS Framework 2025–26 (effective September 2025)
• DfE guidance “What to do if you’re worried a child is being abused” (March 2015)
• Prevent Duty 2015 — updated March 2024
• NSPCC E-Safety Guidance for Schools, January 2024
• Sexual Violence and Sexual Harassment Between Children in Schools and Colleges, DfE, September 2021
• Martyn’s Law — Terrorism (Protection of Premises) Act 2025
• DfE Meeting the Digital Standards 2025
• Teaching Online Safety in Schools guidance 2023

Policy statement

This policy applies to Orchard House School (‘the School’), which includes the EYFS and Nursery settings. This policy is reviewed and updated annually (as a minimum) and is available on the School website, or on request from the school office or in person. This policy can be updated whenever needed, so that it is kept up to date with safeguarding issues as they emerge and evolve, including any lessons learnt. The school has a strong commitment to safeguarding.

Orchard House School works with social care, the police, health services and other services, as and where appropriate, in accordance with our statutory responsibility, to promote the welfare of children and protect them from harm.

Our school staff do not require parental consent to make such a referral to external statutory agencies. If a direct referral is made by a member of staff, the DSL should also be informed as soon as possible or, in their absence, the Head or our safeguarding governor, Rachael Friend (07552 268782).

Aims

The aims of this policy are:

• To ensure that effective safeguarding procedures are in place and are followed by all staff in accordance with national guidance and the locally agreed inter-agency procedures of the ECIRS Safeguarding Children’s Partnership.
• To provide a systematic means of monitoring children known or thought to be at risk of harm, as well as support for those children.
• To identify, monitor and support those children who may be in need of Early Help, including support from other agencies apart from Children’s Services, e.g. Child and Adolescent Mental Health Services (CAMHS).
• For all staff to be fully aware and confident of their role in safeguarding and child protection and of their responsibilities to identify and report possible concerns about the welfare of children, including possible harm or abuse.
• For all staff to be fully aware of the need to report any concerns about the actions of members of staff, volunteers, visitors or contractors.
• To support children’s development in ways that will foster security, confidence and independence.
• To be alert to the risks to young people online and to ensure, through appropriate filtering and monitoring systems, that they are safeguarded in the school from potentially harmful and inappropriate online material (also see Digital Usage Policy).
• To emphasise the need for good levels of communication between all members of staff.
• To promote effective working relationships with other agencies.
• To ensure that all staff are recruited in accordance with the school’s Recruitment Policy and in accordance with guidance in Keeping Children Safe in Education (September 2025) (“KCSIE”) and Disqualification under the Childcare Act 2006 (September 2018).

The school will also create a positive ethos to:

• Establish and maintain an environment where all pupils feel secure, are encouraged to talk and are listened to.
• Ensure staff are confident to report any concerns and to deal with any disclosures.
• Provide early help to children and their families.
• Have methods in place which make it easy for children to report concerns, and ensure all children know they can talk to any adult in the school if they are worried.
• Include opportunities in the curriculum for age-appropriate personal, social, health and citizenship education (PSHCE) and Relationships & Sex Education for pupils to develop the skills they need to recognise and stay safe from abuse, including abuse or exploitation through technology of all kinds.

The Designated Safeguarding Lead

The school has appointed a Designated Safeguarding Lead (DSL) and Deputy Designated Safeguarding Leads (DDSLs). Some are members of the Senior Leadership Team and have the necessary status, training and authority to be responsible for matters relating to the welfare of pupils, including child protection.

In accordance with the Early Years Foundation Stage (“EYFS”) statutory framework, Rosamund Brown and Mercedes Remuinan are DSLs for safeguarding in relation to pupils within the EYFS.

Responsibilities of the DSL

The DSL’s role is to take lead responsibility for safeguarding and child protection matters in the School (including online safety), maintaining an overview of safeguarding within the School, opening channels of communication with local statutory agencies, referring incidents to third parties (including local authority children’s services, the DBS, Channel and the police) where appropriate, supporting staff in carrying out their safeguarding duties, and monitoring the effectiveness of the School’s policies and procedures in practice. The DSL works with the governors to review and update the School’s safeguarding policy.

During term time, the DSL and/or a DDSL will always be available (during school hours) for staff to discuss any safeguarding concerns. If a DSL or DDSL is not available in person, they can be contacted via phone or email, including out of hours or out of term.

The main responsibilities of the DSL are as detailed in KCSIE Annex C, and include:

• Promoting a culture of safeguarding so the welfare and best interests of children are embedded within all the school’s processes and procedures.
• Co-ordinating and monitoring safeguarding, being the first point of contact for parents, pupils, teaching and non-teaching staff, and external agencies.
• Acting immediately upon the receipt of any concerns.
• Liaising with ESCP/HSCP Safeguarding Children’s Partnership and other neighbouring Children’s Services departments.
• Understanding child protection processes, including Section 17 and Section 47 assessments under the Children’s Act 1989 and ‘Early Help’ processes.
• Ensuring the safeguarding governor, Rachael Friend (07552 268782), is informed about safeguarding concerns, including any referrals.
• Attending case conferences or other multi-agency planning meetings and contributing to assessments and reports.
• Keeping detailed, accurate records of procedures and action taken, including cases where no referral to another service is required.
• Providing a systematic means of monitoring and supporting children known or thought to be at risk of harm, or where there are ongoing concerns.
• Promoting the educational achievement and care of any looked after children, taking lead responsibility for them.
• Maintaining a regular training programme for all members of school staff and volunteers.
• Ensuring all new staff receive induction training in safeguarding, including a copy of KCSIE Part 1 and/or Annex A.
• Ensuring all staff and governors confirm they have read and understood the Safeguarding Policy, KCSIE Part 1, Annex A, and Annex B if they lead, manage or work directly with children.
• Ensuring that when children leave the school, child protection information is copied for the new educational provider within 5 days and transferred securely and separately from the main file.
• Ensuring a record of safeguarding information is obtained from any previous school or nursery for a new pupil joining the school.
• Monitoring the confidentiality and storage of records — hard copy records are kept locked in the DSL’s office, separated from routine pupil records, with access restricted to the DSL and Deputy DSLs.
• Ensuring the Safeguarding Policy is reviewed annually, and after any incident or change in legislation, with immediate remediation where necessary.
• Overseeing online safety in the school with the support of the IT manager, including responsibility for filtering and monitoring systems and processes.
• Ensuring the Safeguarding Policy is available to parents/carers and published on the school’s website.
• Ensuring “Safeguarding” is a standing item on staff meeting agendas, with detailed information shared only on a ‘need to know’ basis.
• Ensuring a weekly report is sent to the Safeguarding Governor and that the annual Safeguarding Audit is presented to the Governing Board.
• Being aware of the requirement for an appropriate adult to be present where children are investigated by the police, whether at school or a police station (see www.safeguarding.link/pace; Annex C, KCSIE 2025).

Responsibilities of the Deputy DSLs

The Deputy DSLs are trained to the same level as the DSL and, in the DSL’s absence, carry out the functions necessary to ensure the ongoing safety and protection of children, ensuring the DSL receives copies of all reports and referrals and is fully briefed as soon as possible on their return. The ultimate lead responsibility for safeguarding and child protection rests with the DSL and will not be delegated except in exceptional circumstances, such as the long-term absence of the DSL.

Responsibilities of the staff

• Provide a safe and supportive learning environment.
• Read and understand Part 1 of Keeping Children Safe in Education and Annex A, as well as Annex B if leading, managing or working directly with children.
• Read and understand the School’s Safeguarding Policy and Procedures.
• Adhere to the school’s Staff Code of Conduct.
• Undertake regular safeguarding training, at least annually.
• Be alert to the signs of abuse and neglect, including child-on-child abuse, and report any concerns to the DSL immediately.
• Be aware that even if there are no reports of child-on-child abuse, or any other form of abuse, it does not mean it is not happening — it may just not be being reported.
• Understand the child protection process, including Section 17 and Section 47 assessments and ‘Early Help’ processes.
• Help pupils understand how to keep themselves safe and manage risk.
• Be alert to absenteeism of any children and inform the DSL of any concerns.
• Consider whether wider environmental factors are present in a child’s life that are a threat to their safety and/or welfare (Contextual Safeguarding).
• Report to the Head any concerns about the conduct of adults, including low-level concerns (including behaviour outside school that might indicate an individual is unsuitable to work with children).

Responsibilities of the Head

• Promote an overarching culture of safeguarding embedded within all school processes and procedures, with the best interests of the child at their heart.
• Have read and understood all parts of Keeping Children Safe in Education.
• Ensure KCSIE Part 1 (including Annex A), and the school’s Safeguarding Policy are understood and implemented effectively by all staff.
• Allocate sufficient time, training and resources to enable the DSL and Deputies to carry out their roles effectively.
• Ensure all staff feel able to raise concerns about poor or unsafe practice, handled sensitively in accordance with the Whistleblowing procedures.
• Ensure pupils are taught about keeping safe, including online.
• Ensure systems are in place for pupils to easily report concerns, including abuse.
• Deal with any reports regarding concerns or allegations related to the conduct of adults, including low-level concerns.
• Seek advice and liaise with the Local Authority Designated Officer (LADO) regarding concerns about adults.
• Undertake training on safer recruitment processes at regular intervals.
• Monitor the effectiveness of this policy in liaison with the Safeguarding Governor and SLT, and remedy any deficiencies immediately.

Responsibilities of the Board of Governors and Proprietor

• Ensure safeguarding and child protection underpin all relevant aspects of process and policy development.
• Ensure processes are in place for continuous vigilance, deterring and preventing abuse and challenging inappropriate behaviour.
• Create a culture where staff feel comfortable discussing matters, including online, which may have safeguarding implications.
• Ensure policies, procedures and training are effective and comply with the law at all times.
• Ensure there is a nominated governor for safeguarding with leadership responsibility at Board level.
• Ensure the nominated governor has the required knowledge, skills and expertise.
• Ensure an appropriate senior member of staff from the nursery is appointed as designated safeguarding lead.
• Ensure there is an effective Safeguarding Policy consistent with KCSIE (September 2025), Working Together to Safeguard Children (2025) and ECIRS requirements, available publicly on the school’s website.
• Ensure child protection files show a clear chronology and reasons for decisions taken.
• Ensure other appropriate policies are in place, including a Staff Code of Conduct, Anti-bullying Policy and Relationships & Sex Education Policy.
• Ensure each Dukes organisation has a written behaviour policy available to parents.
• Ensure the school holds at least two emergency contact numbers for each child.
• Ensure safer recruitment procedures follow Part 3 of KCSIE, with all checks recorded on the Single Central Record (SCR).
• Ensure IT systems have appropriate filters without unduly restricting educational access, with regular monitoring and review, and a named governor for IT under the DfE Digital Standards.
• Have policies and procedures in place relating to the use of cameras and technology within the EYFS.
• Review the Safeguarding Policy at least annually (and after any serious incident) as part of the summer term Governors’ Review Meeting, with termly reports to the Safeguarding Governor and an annual Safeguarding Audit to the Governing Board.
• Ensure ALL governors and proprietors receive appropriate safeguarding and child protection (including online) training at induction, regularly updated.
• Ensure all staff undergo safeguarding and child protection training (including online safety and filtering/monitoring responsibilities) at induction, regularly updated.
• Be aware of obligations under the Human Rights Act 1998 and the Equality Act 2010 (see Appendix 2).

Children with special educational needs and disabilities (SEND)

Staff are made aware that children with special educational needs and/or disabilities, as well as other vulnerable groups, may be especially at risk of abuse, including those with physical health issues. Such children are also more prone to peer group isolation or bullying.

Staff will be aware that:

• Assumptions should not be made that indicators of possible abuse (behaviour, mood, injury) relate to the child’s disability without further exploration, as abuse may be taking or have taken place.
• Children with SEN and disabilities can be disproportionately impacted by things like bullying — without outwardly showing any signs.
• Communication barriers may exist and difficulties in overcoming these barriers.

SEND children placed with alternative provision providers will be regularly monitored to ensure their whereabouts and levels of attendance are known. Suitability checks of staff and premises will be undertaken before any placement commences, with half-termly reviews of academic progress, quality of education delivery and attendance.

What to do when there are concerns or if a child makes a disclosure

The School has a duty to consider at all times the best interests of the pupil and take action to enable all pupils to achieve the best outcomes. Safeguarding and promoting the welfare of children is everyone’s responsibility.

It is vital that all staff understand their responsibility to:

• Listen carefully and keep an open mind. Staff should not decide whether or not abuse has taken place. When the pupil has finished talking, ensure they feel secure and, if appropriate, explain what happens next.
• Not downplay abuse that occurs online or outside of school — it should be treated equally seriously. A victim will never be given the impression they are creating a problem by reporting, nor made to feel ashamed.
• Explain that the law protects children rather than criminalises them, without alarming or distressing them (KCSIE 2025, paragraph 474).
• Be aware children may not feel ready or know how to disclose abuse, exploitation or neglect, and may not recognise their experiences as harmful — maintaining professional curiosity and speaking to the DSL regardless.
• Not promise confidentiality — explain that other adults must be told to help keep the pupil safe.
• Not cross-question the pupil or ask leading questions — let the pupil say what they want to, and no more.
• Be prepared to follow up with the pupil only in conjunction with advice from the DSL.
• Be aware that younger pupils may disclose in general conversation rather than as a specific disclosure.
• Not attempt any examination or ask a pupil to remove clothes to look at an injury; never photograph an injury.
• Not attempt to investigate matters further — the staff role is to listen, record and report to the DSL.
• Follow the specific advice in this policy if a concern or disclosure involves technology or online images.

Staff may speak directly to the DSL or Deputy DSL first, or enter their concern straight onto CPOMS for the DSL’s attention. In either case, a concern must be reported no later than the same working day, with a written record made on CPOMS by the member of staff. Any staff member who cannot access CPOMS must contact the DSL directly and without delay.

Contextual safeguarding

Safeguarding incidents and/or behaviours can be associated with factors outside the School and can occur between children outside School. All staff, especially the DSL and deputies, should consider the context within which incidents occur, and the School will share as much information with Children’s Social Care as possible as part of any referral.

What staff should do if a child is in danger or at risk of harm

If staff believe a child is in immediate danger or at risk of harm, they should make an immediate referral to children’s social care and/or the Police. Anyone can make a referral. Referrals must be made immediately and in any event within 24 hours (one working day). Parental consent is not needed for referrals to external statutory agencies. All concerns, discussions and decisions must be recorded in writing.

The School’s Local Safeguarding Children Executive is ESCP/HSCP:

• ESCP: ealingfamiliesdirectory.org.uk
• HSCP: hscb.org.uk

What staff should do if a child is seen as at risk of radicalisation

Staff should follow the School’s normal referral processes, which may include a Prevent referral or referral to children’s social care. If there is an immediate or significant risk of a child being drawn into terrorism, staff must call 999, or 101 for non-urgent police advice. The DfE Prevent helpline is 0207 340 7264. The School carries out risk assessments of the potential local risk, discussed with the Head, DSL, DDSL and safeguarding governors.

What staff should do if they discover an act of Female Genital Mutilation (“FGM”)

Staff must report to the Police cases where they discover that an act of FGM appears to have been carried out. Unless there is good reason not to, this should still be discussed with the DSL, involving children’s social care as appropriate.

What staff should do if they have concerns that children are at risk from serious violent crime

Indicators may include increased absence, changes in friendships with older individuals or groups, decline in performance, signs of self-harm, or unexplained injuries. Staff should speak with the DSL (or DDSL) to agree a course of action, although a direct referral to children’s social care can also be made.

How staff should respond to an incident of nudes and semi-nudes being shared by pupils

All staff have a duty to recognise and refer any incidents involving nudes and semi-nudes shared by children under 18 online, via any platform or device (including offline transfer such as AirDrop). Any direct disclosure will be taken seriously and handled sensitively. If staff become aware of such an incident, they should refer it to the DSL immediately, who will follow “Sharing nudes and semi-nudes: advice for education settings working with children and young people” (March 2024), including:

• Holding an initial review meeting with appropriate staff.
• Carrying out interviews with the children involved, if appropriate.
• Informing parents and carers at an early stage unless there is good reason to believe this would place the child at risk.
• Carrying out a risk assessment to determine whether the child has been harmed or is at risk of immediate harm.
• Where there is no risk of harm, handling the incident in school per the “sharing nudes” guidance and the School’s Child Protection and Behaviour policies.
• Where there is a risk of harm, making an immediate referral to children’s social care and/or the police.

All such incidents must be recorded, whether referred externally or not, with reasons for non-referral signed off by the Head. No copies of imagery will be taken or retained. This guidance does not apply where an adult over 18 shares images of a child under 18 — this constitutes child sexual abuse and must be notified to the DSL, who will always inform the Police as a matter of urgency.

What staff should do if a child goes missing from education

Children missing from education, or persistently absent, can be a vital warning sign of abuse, neglect, or child sexual/criminal exploitation. The School follows up on absences in a timely manner and has an Attendance Policy shared with parents and carers.

The School’s procedures for unauthorised absence and children missing from education are set out in the Missing Pupil Policy. The School will report to ESCP/HSCP a pupil who fails to attend regularly or has been absent without permission for a continuous period of 10 school days or more.

What staff should do if a child needs a social worker

Local authorities should share the fact that a child has a social worker, and the DSL should hold and use this information as a matter of routine to inform decisions about safeguarding and promoting welfare.

What staff should do if a child requires mental health support

Mental health problems can, in some cases, indicate that a child has suffered or is at risk of suffering abuse, neglect or exploitation. Staff can access advice to help identify children needing extra mental health support, including working with external agencies (see DfE ‘Mental Health and Behaviour in Schools’ guidance).

What staff should do if they have safeguarding concerns about another staff member

Concerns about another staff member (including supply staff, agency staff, volunteers and contractors) should be referred to the Head. The school will not investigate any allegation without first referring to the LADO. Concerns about the Head should be referred to the Chair/Safeguarding Governor, Rachael Friend (07552 268782), who will inform the LADO.

What staff should do if they have concerns about safeguarding practices in the School

The School aims to ensure a culture of safety and an attitude of ‘it could happen here’. Concerns about poor or unsafe practice should be raised in accordance with the School’s whistleblowing procedures. There will be no disciplinary action taken against a member of staff for making such a report provided it is done in good faith.

Whistleblowing

All members of the school community have a duty to protect children and, should they have concerns, must make these known to the Head. Staff may also contact the Safeguarding Governor, Rachael Friend (07552 268782), or the NSPCC whistleblowing advice line: 0808 800 5000.

Procedures for pupils to report concerns

The school has a strong pastoral system promoting an ethos where pupils feel safe to share information. The School Council provides a ‘pupil voice’. Pupils are encouraged to use the Thoughts box, checked at least weekly, and can raise concerns half-termly via the pastoral plan. Childline posters are displayed around school and children are reminded regularly in assemblies and PSHCEE lessons.

Support for staff

Staff who become involved with a pupil who has suffered harm may find the situation stressful and upsetting. The school will support such staff through an opportunity to talk through anxieties with the DSL. The NSPCC helpline (0800 028 0285, help@nspcc.org) and the Employee Assistance Programme (healthassuredeap.co.uk, User ID: Dukes / Password: eap) are also available. Contact: Marcelle Stewart, Director of People, Dukes Education Group (marcelle.stewart@dukeseducation.com).

Recording safeguarding concerns

• Abuse and neglect are rarely standalone events and require a culture of vigilance, professional insight, and respectful challenge, alongside effective recording and monitoring systems.
• All safeguarding concerns must be recorded on CPOMS, the school’s safeguarding management system.
• Records of conversations should include date, time, place, who was present, and what was said — using names, not initials, and the pupil’s own words wherever possible.
• Records should be specific, factual, and free from personal opinion.
• If more than one member of staff is present for a disclosure, each must make a separate report on CPOMS.
• All concerns, even those which appear minor, should be recorded, as minor pieces of evidence can build a pattern over time.
• Staff must not investigate further or speak to parents or other staff — they must contact the DSL, who will determine the next course of action.

DSL action on receipt of a concern about a child

On receipt of the safeguarding report, the DSL must record the decisions made and action taken, which may include one or more of the following:

• Monitoring the pupil in school
• A discussion with parents
• Early Help intervention from the school and/or another agency
• Referral to Children’s Services
• Referral to the LADO
• Report to the police

Preserving evidence

• All evidence (pupil’s work, notes, devices) must be preserved.
• Electronic devices should be confiscated and set to flight mode or turned off.
• Staff must not view, look for, copy, print or forward images — particularly important with nudes/semi-nudes, as doing so is a criminal offence.
• Do not delete imagery or ask a pupil to delete it, or ask the pupil(s) to disclose further information about it.
• Do not share information about the incident beyond those who need to know, or say/do anything to blame or shame any pupil involved.
• Report the matter to the DSL immediately.

Child protection records and information sharing

• Safeguarding records are kept securely on CPOMS with a clear, detailed chronology for each pupil.
• Written records are kept of all concerns, whether or not referred to Children’s Services.
• When a pupil moves school, child protection records are transferred securely within 5 days, with a receipt obtained — parental permission is not required.
• Safeguarding records will be requested from previous schools/nurseries for any new pupils joining.

Information will be shared according to the HM Government guidance Information Sharing (July 2018). The Data Protection Act 2018 and UK GDPR do not prevent the sharing of information for the purposes of keeping children safe (KCSIE 2025, paragraph 55). Information shared should be:

• Necessary and proportionate to the need and level of risk
• Relevant to the purpose
• Adequate for its purpose
• Accurate, current, and distinguishing fact from opinion
• Timely, to reduce risk of harm
• Secure, shared appropriately
• Recorded, whether or not the decision is taken to share

Communication with parents/carers

• Parents are made aware of the School’s Safeguarding Policy via the Parents’ Handbook, website, and posters identifying the DSL and Deputy DSL.
• The School will always put the duty of care to the child as its priority and will refer concerns even against parents’ wishes if a pupil is or may be at risk of harm.
• Referrals to Children’s Services or the LADO do not require prior parental consent.
• If notifying parents might exacerbate the problem or increase risk to the pupil, initial advice will be sought from Children’s Services first, which may result in a referral without parents being notified.
• Where an allegation involves a member of staff, parents will only be informed after the school has consulted with, and obtained consent from, the LADO.

Referrals to Children’s Services and Early Help

Referrals about an individual pupil must be made to the borough in which the pupil resides, though advice can be obtained regardless of where the pupil resides. Where a child is suffering, or is likely to suffer, harm, a referral to local authority children’s social care (and if appropriate the police) must be made immediately, following the local referral process.

Staff should be particularly alert to the potential need for Early Help for a child who:

• Is disabled or has certain health conditions and specific additional needs
• Has special educational needs
• Has a mental health need
• Is showing signs of being drawn into anti-social or criminal behaviour, including gangs or county lines
• Is frequently missing/goes missing from care or home
• Is misusing drugs or alcohol
• Is at risk of modern slavery, trafficking, or sexual or criminal exploitation
• Is in a family circumstance presenting challenges such as substance abuse, adult mental health problems or domestic abuse
• Has returned home to their family from care
• Is showing early signs of abuse and/or neglect
• Is at risk of being radicalised or exploited
• Has a family member in prison, or is affected by parental offending
• Is experiencing, or is at risk of, family ostracism
• Is at risk of ‘honour’-based abuse such as FGM or Forced Marriage
• Is a privately fostered child
• Is persistently absent from education, including partial-day absences

Arrangements for dealing with child-on-child allegations (including sexual violence and harassment)

Staff are required to report any concerns regarding child-on-child abuse immediately to the DSL, or in their absence, a DDSL or the Head. Child-on-child abuse can be standalone or part of wider abuse, and can happen inside or outside school, and online. It can include: bullying (including cyberbullying, prejudice-based and discriminatory bullying); abuse within intimate partner relationships between peers; physical abuse; initiation/hazing type violence and rituals; upskirting; sexting; consensual and non-consensual sharing of nudes/semi-nudes; sexual assault; and causing someone to engage in sexual activity without consent.

These arrangements apply to all reports and concerns whether they happened in school, outside it, or online. Abuse should never be dismissed as “banter”, “part of growing up”, or “boys being boys”.

When there has been a report of sexual violence, the DSL will make an immediate risk and needs assessment, considering the victim, other possible victims, the alleged perpetrator(s), and all other children/staff who may need protecting.

A pupil against whom an allegation of abuse has been made may be suspended from the School during investigation, taking advice from ESCP/HSCP. The School will have regard to KCSIE and the SVSH (Sexual Violence and Sexual Harassment guidance) at all times.

Considering confidentiality and anonymity

Staff should never promise confidentiality. If a victim asks the school not to tell anyone, staff must seek advice from the DSL, who will balance the victim’s wishes against the duty to protect them and other children. Parents or carers should normally be informed unless this would put the victim at greater risk. Where a report of rape, assault by penetration or sexual assault is made, this will be referred to the police — this applies even where the alleged perpetrator is under the age of criminal responsibility (10), with police taking a welfare rather than criminal justice approach.

Staff Code of Conduct and allegations against staff

The Staff Code of Conduct gives comprehensive guidance on expected behaviour. Failure to follow it is likely to result in disciplinary action.

The School’s procedures for managing allegations against staff (including supply staff, volunteers and contractors) apply where staff have (or are alleged to have):

• Behaved in a way that has harmed a pupil, or may have harmed a child
• Possibly committed a criminal offence against or related to a child
• Behaved towards a child in a way that indicates they may pose a risk of harm
• Behaved in a way that indicates they may not be suitable to work with children, including outside school

Allegations that do not meet this “harms test” should be dealt with under the Reporting Low Level Concerns Policy. Allegations against a teacher no longer teaching, and historical (non-recent) allegations, should be referred to the Police and the LADO.

Reporting an allegation or concern

• A member of staff receiving an allegation about another staff member should report this immediately to the Head, unless the allegation is against the Head.
• An allegation against the Head should be reported to the Safeguarding Governor, Rachael Friend (07552 268782), without notifying the Head first.
• Where there may be a conflict of interest, the Chairman of Dukes Education, Mr Aatif Hassan, should be contacted directly; if unavailable, Mr Tim Fish, CEO of Dukes Education (UK and ROI).
• Concerns may be reported verbally or by email; verbal reports must also be followed by a written record.

Allegations found to be malicious or false will be removed from personnel records unless the individual consents to retention. Records relating to allegations of sexual abuse must be preserved for the duration of any IICSA inquiry; other records retained until pension age or 10 years from the date of allegation, whichever is longer.

Low-level concerns

A ‘low-level’ concern does not mean it is insignificant — it may be no more than a sense of unease or a ‘nagging doubt’ that an adult’s behaviour is inconsistent with the Staff Code of Conduct, but does not meet the threshold for a LADO referral. Examples include: being over-friendly with children; having favourites; taking photographs of children on a personal device; engaging with a child 1:1 in a secluded area or behind a closed door; using inappropriate sexualised, intimidating or offensive language.

• Staff must report any low-level concern to the Head, DSL and Safeguarding Governor, Rachael Friend (07552 268782).
• The Head is the ultimate decision maker for all low-level concerns, and may consult the DSL.
• Staff are encouraged to self-refer where they believe their own conduct may have been misinterpreted.
• All low-level concerns will be recorded in writing, including details, context, evidence, categorisation, action taken, rationale, and the name of the individual raising the concern (respecting anonymity requests where possible).
• Records will be reviewed for patterns; where a pattern moves from concern to meeting the harms threshold, it will be referred to the LADO.
• Staff who report a low-level concern in good faith will suffer no detriment and benefit from Whistleblowing Policy protections.

Safer recruitment

The School is committed to safer recruitment processes. All members of teaching and non-teaching staff, including part-time, temporary, supply and visiting staff (e.g. musicians and sports coaches), are subject to necessary statutory child protection checks before starting work, including:

• Taking up of references
• Verification of identity and right to work in the UK
• Enhanced DBS check with ‘barred list’ information, for most appointments
• Self-declaration under the Childcare Act 2006 disqualification regulations
• For teachers: verification of Qualified Teacher Status (QTS) and completion of induction/probation
• Check for any prohibition order issued by the Secretary of State (or overseas equivalent)
• Where appropriate: overseas criminal record checks and qualification verification
• Medical fitness questionnaire and/or self-declaration

Full details are set out in the School’s Safer Recruitment Policy. Contractors attending the School site are always accompanied by the site manager.

Staff, DSL and governor training

All staff are required to read, at least annually, the Safeguarding Policy and Staff Code of Conduct, and must sign to confirm they have done so, along with Part 1 and Annex A of KCSIE (Annex A for those who do not directly work with children, if appropriate).

Every member of staff receives comprehensive training in safeguarding, online safety, harmful sexual behaviours, and Prevent awareness. Refresher training is provided annually and on specific issues as required. New staff receive induction training covering the child protection policy, the role of the DSL/DDSL, the behaviour policy, the staff code of conduct, missing education procedures, and anti-bullying/Prevent training.

The DSL receives updated child protection training at least every two years, with knowledge and skills updated at least annually. The DDSL is trained to the same level as the DSL. All governors and proprietors receive appropriate safeguarding training at induction, regularly updated, and the safeguarding governor has received specific safeguarding training.

Filtering, monitoring and online safety

It is the DSL’s responsibility to understand the filtering and monitoring systems in place and to ensure staff receive appropriate training. The Department for Education’s filtering and monitoring standards require schools to:

• Identify and assign roles and responsibilities to manage filtering and monitoring systems
• Review filtering and monitoring provision at least annually
• Block harmful and inappropriate content without unreasonably impacting teaching and learning
• Have effective monitoring strategies in place that meet safeguarding needs

Online safety is considered through the “4Cs” framework:

• Content — exposure to illegal, inappropriate or harmful content (e.g. pornography, self-harm, extremism)
• Contact — harmful online interaction (e.g. grooming, commercial advertising)
• Conduct — online behaviour that increases the likelihood of, or causes, harm (e.g. sharing explicit images, online bullying)
• Commerce — risks such as online gambling, phishing and financial scams

Cyber-bullying is treated as seriously as any other form of bullying and managed through the Anti-bullying Policy. The organisation maintains a clear Mobile and Smart Technology Policy and takes appropriate steps around information security and cyber security, informed by DfE and NCSC guidance.

Relationships Education and/or Relationships and Sex Education (“RSE”)

The School has regard to the DfE’s statutory guidance Relationships Education, Relationships and Sex Education (RSE) and Health Education. Relationships Education and/or RSE forms part of the School’s PSHCEE programme.

Looked after children

The governing body ensures that staff have the skills, knowledge and understanding necessary to keep safe any children on roll who are looked after by a local authority.

Arrangements for visiting speakers

The School undertakes a risk assessment before agreeing to any Visiting Speaker, which may include a DBS check. Speakers are expected to promote British values of democracy, the rule of law, individual liberty and mutual respect at all times. Visiting Speakers are always supervised, must show original photo ID on arrival, and are recorded in a formal visitor register. No visiting speaker will be with a pupil unsupervised.

Keeping children safe outside of our organisation

Where services or activities are provided separately by another body, the governing body will seek assurances that the provider has appropriate safeguarding policies and procedures in place, including written confirmation of safer recruitment checks equivalent to the School’s own, and that the provider will inform the School of any arrangements that may put a child at risk.

Early Years provision safeguarding arrangements

Disqualification from working in childcare

Where staff work in, or manage, the School’s early years or provision of care for pupils under eight, the School checks whether staff are disqualified under the Childcare Act 2006, both pre-appointment and periodically during employment, recorded on the Single Central Register. Where a member of staff is found to be disqualified (or there is doubt), the School will remove them from the relevant work pending resolution, considering redeployment where appropriate.

Use of mobile phones and cameras

Staff must not use personal phones to hold data, photos or personal information about pupils, and must obtain the Head’s approval before photographing or videoing any pupil. Parents are not permitted to use mobile phones or cameras in or around the EYFS setting without prior approval.

DDSLs for the EYFS

The practitioners designated for safeguarding children in the early years settings are Rosamund Brown and Mercedes Remuinan. They report all incidents to the DSL.

Duty to notify Ofsted

The School will inform Ofsted of any significant event likely to affect the suitability of a person in regular contact with children where childcare is provided, within 14 days of becoming aware. The School will notify Ofsted within 14 days of any allegations of serious harm or abuse by any person living, working, or looking after children on the premises.

Other documents informing the policy

• Safer Recruitment Consortium — Guidance for safe working practice (February 2022)
• DfE guidance — Teaching online safety in school (January 2023)
• Mental health and behaviour in schools: departmental advice (June 2021)
• When to call the police — NPCC guidance
• DfE advice — Information Sharing (July 2018)
• DfE Searching, Screening and Confiscation Advice for schools (July 2022)
• UKCIS — Sharing nudes and semi-nudes: advice for education settings (March 2024)
• Designated teacher for looked after children (February 2018)
• Counselling in schools: a blueprint for the future (February 2016)
• UKCIS — Education for a Connected World (updated 2022)
• UKCIS external visitors’ guidance
• National Crime Agency’s CEOP education programme: Thinkuknow
• Public Health England: Every Mind Matters (September 2020)
• Harmful online challenges and online hoaxes (February 2021)
• London Grid for Learning — Undressed guidance
• Forced Marriage Unit resources
• Forced Marriage — The Right to Choose (updated April 2023)
• County Lines — disruption toolkit (19 July 2022)
• Operation Encompass — helpline 0204 513 9990 (8am–1pm, Monday–Friday)

Appendix 1 — Categories of abuse and specific safeguarding issues

Definitions of abuse

All school staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another.

KCSIE 2025 defines abuse as a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Harm can include ill treatment that is not physical, as well as the impact of witnessing ill treatment of others (particularly relevant to domestic abuse). Children may be abused in a family, institutional or community setting by those known to them or, more rarely, by others; abuse can take place wholly online, or technology may be used to facilitate offline abuse; and children may be abused by an adult or adults, or by another child or children.

Categories of abuse

• Physical abuse
• Emotional abuse (including domestic abuse)
• Sexual abuse
• Neglect

Risk factors

In an abusive relationship, the child may appear frightened or wary of a parent or other adult, or act in a way inappropriate to their age and development. The parent or carer may persistently avoid child health promotion services, have unrealistic expectations of the child, frequently complain about/to the child, be absent or misusing substances, persistently refuse home visit access, or be involved in domestic violence. Staff should be alert to changes in behaviour if there is a new carer (e.g. nanny or au pair) in the home.

Recognising signs of physical abuse

Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm, including where a parent or carer fabricates or induces illness. Indicators of concern include: inconsistent or multiple explanations for an injury; unexplained delay in seeking treatment; disinterest from parents/carers; repeated presentation of minor injuries; use of different doctors/A&E departments; bruising patterns (e.g. simultaneous bruised eyes, bruising to the head, ears, face, or object-shaped marks); bite marks; cigarette burns; scald patterns indicating immersion; and delayed presentation of fractures.

Recognising signs of emotional abuse

Emotional abuse involves persistent maltreatment causing severe adverse effects on a child’s emotional development — conveying worthlessness, imposing inappropriate expectations, witnessing domestic violence, or serious bullying. Indicators include developmental delay, abnormal attachment, aggressive behaviour, low self-esteem, withdrawal, reverting to younger behaviour, depression, and fear of academic failure. See also the school’s Anti-bullying Policy.

Recognising signs of sexual abuse

Sexual abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening, and can include contact and non-contact activities, including online abuse and grooming. Sexual abuse is not solely perpetrated by adult males, and can be perpetrated by other children (see KCSIE 2025, Part Five). Behavioural and physical indicators include inappropriate sexualised conduct, self-harm, unexplained pain or injury to the genital or anal area, and pregnancy where paternity is not disclosed.

Harmful sexual behaviour (HSB)

Children’s sexual behaviour exists on a wide continuum, from normal and developmentally expected to inappropriate, problematic, abusive and violent. Problematic, abusive and violent sexual behaviour is developmentally inappropriate and may cause developmental damage — referred to as “harmful sexual behaviour” (HSB), which can occur online, face-to-face, or both, and should be considered in a child protection context.

Signs of neglect

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of health or development, and may occur during pregnancy through maternal substance abuse. Indicators include poor hygiene/clothing, untreated illness, deteriorating schoolwork, significant behavioural change, reluctance to go home, and unexplained physical symptoms.

Affluent neglect

Staff should be aware of the impact of affluent neglect experienced by children in wealthier families — often emotional in nature, arising from parental absence, high pressure to succeed, and reduced parental oversight, which can increase risks such as prolonged online activity or access to means to facilitate drug abuse.

Specific safeguarding issues

Further safeguarding issues of which staff should be aware, with extensive guidance in Annex B of KCSIE, include:

• Child abduction and community safety incidents
• Children missing from education (also see Attendance Policy)
• Children and the court system
• Children with family members in prison
• Child criminal exploitation (CCE, including county lines/gangs) and child sexual exploitation (CSE)
• Domestic abuse
• Fabricated or induced illness
• Homelessness
• So-called ‘honour based’ abuse, FGM and forced marriage
• Mental health
• Child-on-child abuse, including nudes/semi-nudes, sexual violence and harassment, up-skirting, and online behaviour/cybercrime
• Private fostering
• Preventing radicalisation (including Channel)

Child abduction and community safety incidents

Child abduction is the unauthorised removal or retention of a minor from a parent or anyone with legal responsibility for the child, and can be committed by parents, family members, people known to the victim, or strangers.

Children and the court system

Children are sometimes required to give evidence in criminal courts. Two age-appropriate guides (5–11 and 12–17 year olds) are available on gov.uk, explaining the process and special measures available. The Ministry of Justice has also launched an online child arrangements information tool for parents navigating family court disputes.

Children absent from education / missing from education

Prolonged or repeated absence can be a vital warning sign of neglect, sexual exploitation and criminal exploitation, particularly county lines. The local authority is informed of any child added to or removed from the admission register at a non-standard transition point. The school follows up unexplained or unusual patterns of attendance well before the statutory 10-day threshold, typically before a continuous period of 5 days, with immediate first-day calls where a pupil has current involvement with Children’s Services.

Children with family members in prison

Approximately 200,000 children in England and Wales have a parent sent to prison each year, at risk of poor outcomes including poverty, stigma, isolation and poor mental health. The National Information Centre on Children of Offenders (NICCO) provides supporting information.

Child Sexual Exploitation (CSE)

CSE is a form of child sexual abuse occurring when an individual or group takes advantage of a power imbalance to coerce, manipulate or deceive a child into sexual activity in exchange for something the victim needs or wants, or for the exploiter’s benefit. Victims may not recognise the coercive nature of the abuse and rarely self-report. Three main types are recognised: inappropriate relationships; the “boyfriend” model; and organised exploitation and trafficking.

Child Criminal Exploitation (CCE), including gangs and county lines

CCE involves taking advantage of a power imbalance to coerce, manipulate or deceive a child into criminal activity, typically featuring in county lines drug-running. Key indicators include going missing, unexplained gifts, associating with others involved in exploitation, older boyfriends/girlfriends, sexually transmitted infections, mood swings, substance misuse, and inappropriate sexualised behaviour.

Domestic abuse

Domestic abuse includes any incident or pattern of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members, regardless of gender or sexuality. Children can be victims by witnessing/experiencing effects at home, or through teenage relationship abuse in their own intimate relationships, and may blame themselves for the abuse.

Extra-familial harms

All staff, especially the DSL and deputies, will consider whether children are at risk of abuse or exploitation outside their families, including sexual abuse, domestic abuse in intimate relationships, criminal exploitation, serious youth violence, county lines, and radicalisation (KCSIE 2025, paragraph 21).

Operation Encompass

When police are called to a domestic abuse incident involving a child in the household, the police will usually inform the DSL before the child arrives at school the following day, enabling appropriate support. This does not replace statutory safeguarding procedures. The helpline is available 8am–1pm, Monday to Friday, on 0204 513 9990 (charged at local rate).

Homelessness

Being homeless or at risk of becoming homeless presents a real risk to a child’s welfare. The DSL and deputies should be aware of contact details and referral routes into the Local Housing Authority. Indicators include household debt, rent arrears, domestic abuse and anti-social behaviour, and being asked to leave a property.

So-called ‘honour based’ abuse (HBA)

HBA is a collection of practices used to control behaviour and exert power within families to protect perceived cultural and religious honour, including FGM, forced marriage, and practices such as breast ironing, and often involves a wider network of family or community pressure with multiple perpetrators.

There is a statutory duty on teachers to personally report to the Police where they discover (through disclosure or visual evidence) that FGM appears to have been carried out on a girl under 18. Unless there is good reason not to, this should also be discussed with the DSL and children’s social care involved as appropriate. Where a teacher merely suspects risk (without direct discovery), the school’s local safeguarding procedures should be followed instead.

Female Genital Mutilation (FGM)

FGM refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons, and is illegal in the UK. The typical age range is birth to around 15, with most cases between the ages of 5 and 8. Risk factors include low integration into UK society, a mother or sister who has undergone FGM, withdrawal from PSHCE, a visiting female elder from the country of origin, being taken on a long holiday to the country of origin, and talk of a ‘special’ procedure.

Mandatory reporting of FGM

The Serious Crime Act 2015 places a duty on professionals (including teachers) to notify police directly by dialling 101 when they discover FGM appears to have been carried out on a girl under 18. Under no circumstances should school staff physically examine pupils. The report should be made immediately by the individual who becomes aware — this duty cannot be transferred to the DSL, though the DSL must be informed. Where there is risk to life or likelihood of serious immediate harm, staff should call 999.

Forced marriage

A forced marriage is one where one or both parties do not (or, for people with learning disabilities, cannot) consent but are coerced into it — distinct from an arranged marriage. Forcing a person into marriage is a crime in England and Wales. The Forced Marriage Unit can be contacted on 020 7008 0151 or fmu@fcdo.gov.uk. Since February 2023, it is also a crime to carry out any conduct whose purpose is to cause a child to marry before their eighteenth birthday, even without violence, threats or coercion, including non-binding unofficial ‘marriages’.

Mental health

The school’s role in supporting mental health can be summarised as prevention, identification, early support, and access to specialist support. When a pupil is suspected of having mental health difficulties, a graduated response is used: assessment, plan, action, and regular review. Adverse Childhood Experiences (ACEs) that may impact pupils include loss or separation, family conflict or breakdown, life changes, and traumatic experiences. Only appropriately trained professionals can diagnose a mental health problem, but staff are well placed to observe and identify concerns, which should be reported to the DSL immediately.

Child-on-child abuse (formerly known as peer-on-peer abuse)

The school has a zero-tolerance approach; such abuse will never be tolerated or passed off as “banter” or “part of growing up”. Any child can be vulnerable, though individual and situational factors (e.g. SEND, social isolation, being or being perceived as LGBT) can increase vulnerability. Categories include bullying, abuse within intimate peer relationships, physical abuse, sexual violence and harassment, non-consensual sharing of nudes/semi-nudes, up-skirting, and initiation/hazing rituals.

The Cass Review identified that caution is necessary for children questioning their gender, given many unknowns about social transition and potential wider vulnerabilities. Staff will take a cautious approach, working in partnership with parents (other than in exceptionally rare circumstances involving significant risk of harm) and encouraging families to seek advice from a relevant clinical professional.

The DSL will not undertake any enquiry or investigation where a case is referred to Children’s Services or the police. The Head will decide whether to suspend or exclude pupil(s) involved, and the DSL will keep a written record of all conversations and decisions.

Prejudiced behaviour

Pupils may display hurtful behaviour connected with prejudices around belonging, identity and equality — including disability, special educational needs, medical conditions, ethnic, cultural and religious background, gender, home life and sexual identity — which can make it more difficult for a child to report abuse.

Sexual violence and sexual harassment — risk and needs assessment

The DSL will consider the nature of the incident, ages and developmental stages of the children involved, any power imbalance, whether it is a one-off or sustained pattern, whether it occurred within an intimate relationship, and any ongoing risks to the victim, other children or staff (KCSIE 2025, paragraph 487). Risk assessments should be recorded and kept under review (KCSIE 2025, paragraph 485).

E-safety and online behaviour

The school adopts a whole-school approach to online safety, using sophisticated filtering and monitoring systems designed to protect pupils without imposing unreasonable restrictions. Pupils receive guidance through Computing and PSHCEE lessons. Remote education delivered one-to-one is classed as lone working, requiring specific safeguarding arrangements, and staff delivering online learning are appropriately trained.

Youth produced sexual imagery, nudes/semi-nudes, sexting, up-skirting

Sharing of images and videos via text, email, social media or messaging apps involving anyone under 18 is illegal. Up-skirting is a criminal offence involving taking a picture under a person’s clothing without permission, and anyone of any gender can be a victim. Staff who become aware of an incident should confiscate the device, set it to flight mode (or turn it off), not view/delete/copy/forward images, inform parents/carers unless this would put the pupil at risk, and follow the reporting procedures set out in this policy.

Thresholds of sexual behaviour by children

Children’s sexual behaviour is categorised using a ‘traffic light’ approach:

• Green behaviours — reflect safe and healthy sexual development between children of similar age/ability, reflecting natural curiosity and consent.
• Amber behaviours — have the potential to be outside safe and healthy development; unusual, or of potential concern due to age, developmental differences, type, frequency, duration or context. Amber behaviours signal the need to report to the DSL.
• Red behaviours — outside safe and healthy behaviour; excessive, secretive, compulsive, coercive, degrading or threatening, or involving significant age/power differences. Red behaviours indicate a need for referral to Children’s Services.

Preventing radicalisation

Under the Counter Terrorism and Security Act 2015, schools have a duty to ‘prevent people being drawn into terrorism’ — the ‘Prevent Duty’. Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

Early indicators may include showing sympathy for extremist causes, glorifying violence, possessing illegal or extremist literature, secretive behaviour, online sharing of extremist content, intolerance of difference, and advocating violence towards others. Visiting speakers are always vetted, with permission required from the Head.

Channel

Channel is a voluntary, confidential support programme providing early-stage support to people identified as vulnerable to being drawn into terrorism. Prevent referrals may be passed to a multi-agency Channel panel, which a school representative may be asked to attend.

Martyn’s Law

The Terrorism (Protection of Premises) Act 2025 (“Martyn’s Law”) became law on 3 April 2025, named after Martyn Hett, killed in the Manchester Arena bombing on 22 May 2017. The organisation is working towards achieving the Standard Tier recommendations for venues holding 100–799 persons. The Head will ensure steps are taken to prepare for any potential terrorist attack. Please refer to the School’s Lockdown Policy.

Private fostering

A private fostering arrangement occurs when someone other than a parent or close relative cares for a child for 28 days or more, with the parents’ agreement, applying to children under 16 (or under 18 if disabled). Where a member of staff becomes aware that a child may be in such an arrangement, they must notify the DSL immediately.

Fabricated or induced illness

Fabricated or induced illness is where a child has suffered, or is likely to suffer, significant harm through the deliberate action of a parent, attributed by the parent to another cause. This may involve fabrication of signs/symptoms, falsification of records, or induction of illness by various means.

Appendix 2 — Human Rights Act and Equality Act 2010

Human Rights Act

The Human Rights Act 1998 (HRA) sets out the fundamental rights and freedoms in the UK, incorporating the European Convention on Human Rights (ECHR). It is unlawful for schools and colleges to act incompatibly with the Convention. The specific rights applying to schools include:

• Article 3 — the right to freedom from inhuman and degrading treatment (an absolute right)
• Article 8 — the right to respect for private and family life (a qualified right), including protection of physical and psychological integrity
• Article 14 — the right to non-discrimination in the application of these rights, and Protocol 1
• Article 2 (Protocol 1) — the right to education

Being subjected to harassment, violence and/or abuse, including of a sexual nature, may breach any or all of these rights depending on the nature and circumstances.

Equality Act 2010

Schools and colleges must not unlawfully discriminate against pupils because of protected characteristics: sex, race, disability, religion or belief, gender reassignment, pregnancy and maternity, or sexual orientation.

In the context of safeguarding, governing bodies and proprietors should carefully consider how they are supporting pupils with regard to protected characteristics — particularly disability, sex, sexual orientation, gender reassignment and race. The Act allows schools to take proportionate positive action to address disadvantages affecting pupils with a particular protected characteristic, and includes a duty to make reasonable adjustments for disabled children and young people, including those with long-term conditions.