4. St Benedict's School is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment. The School will take all reasonable measures to:It's nice of them to say they are committed. They can hardly say they are not committed, even if that were closer to the truth. But saying it does not by itself translate into effective measures. There seems to be an awful lot of padding on the front end of this document. Also, to say that the school "expects all staff and volunteers" to share the commitment doesn't help a lot. It doesn't describe what they need to do in order to fulfil their roles.
Also, we see here the first of the little caveats that litter the document "The School will take all reasonable measures". Looking at the list of bullets below, there is no justification for the caveat. The first bullet is:
This is something they have to do, not merely take "reasonable measures" about. And the reference to legislation is out of date. The current regulation, which came into force in February 2009 is The Education (Independent School Standards) (England) (Amendment) Regulations 2008. Since that amendment was made on 17th December 2008 and came into force on 9th February 2009, it ought to have been mentioned in the May 2010 version of the school's policies. It is hardly as if the school can be unaware of the applicability of the new regulation.
- ensure that we practise safer recruitment in checking the suitability of staff and volunteers (including staff employed by another organisation) to work with children and young people in accordance with the guidance given in Safeguarding Children and Safer Recruitment in Education and the Education (Independent School Standards) (England) Regulations 2003 as amended;
Again, this is something they have to do, not merely take "reasonable measures" about.
- ensure that we carry out all necessary checks on the suitability of people who serve on the School's governing body and the Board of School Advisors in accordance with the above regulations and guidance given in Safeguarding Children and Safer Recruitment in Education;
There is a big hole here, which remains open even though (or perhaps because) it was exploited by the school in the case of Father David Pearce. Pearce was moved from the post of Junior School Headmaster as a result of an assessment that he was unsuitable to work with children. But the school didn't "cease to use the services" of Pearce, they instead used his services as Bursar, in a role that involved less in the way of supervision of children.
- ensure that where the School ceases to use the services of any person (whether employed, contracted, a volunteer or student) because that person was considered unsuitable to work with children, a detailed report is made to the Independent Safeguarding Authority (ISA) within one month;
This bullet ought to be modified so that the report is also made to the ISA in cases of redeployment of this kind.
In addition, the relevant regulation should be stated, which describes what the "detailed report" must contain. The regulation is The Education (Provision of Information by Independent Schools) (England) Regulations 2003.
UPDATE: Apparently it is now a legal obligation under the Safeguarding Vulnerable Groups Act 2006 to make a notification in the event of a redeployment of staff of this kind. So the school's policy in omitting this aspect is contravening the law.
Mere assurances should not be enough. The requirement should be for evidence that appropriate child protection checks and procedures apply to those staff. Moreover, the form of words seems a bit odd: "staff from another organisation are working with our pupils on another site". So, does this not apply to staff from another organisation working on the school site, such as supply teachers, or a visiting theatre group?
- ensure that where staff from another organisation are working with our pupils on another site, we have received assurances that appropriate child protection checks and procedures apply to those staff;
Meaningless, unless they first describe (at least by reference) what those procedures are, and how they affect the way the staff carry out their duties.
- follow the local inter-agency procedures of the Ealing Safeguarding Children Board;
No point in saying this unless there are procedures to back it. As wel will see later, it is quite dubious as to whether there are any procedures.
- protect each pupil from any form of abuse, whether from an adult or another pupil;
Being alert doesn't commit you to actually doing anything as a result. It's another nice warm and fuzzy statement.
- be alert to signs of abuse both in the School and from outside;
There's another of those little caveats! They deal "appropriately", without specifying what they consider appropriate.
- deal appropriately with every suspicion or complaint of abuse;
This is tautology. The policy is to design and operate procedures which promote the policy...
- design and operate procedures which promote this policy;
No, this really isn't good enough. This policy is to do with child protection. It is not to do with designing policies and procedures.
We'll find later on that the school has something of a fixation about the issue of false allegations. In fact, they seem to say more about how they will protect the staff from false allegations than how they will act on real ones.
- design and operate procedures which, so far as possible, ensure that teachers and others who are innocent are not prejudiced by false allegations;
This is the only mention in the entire document of a "child protection plan". There's nothing on how one is set up, why one might be set up, what they can contain, what the school should do in response. Just this bare mention without any connection to the school's procedures. It sounds terribly impressive and official, but unless backed with descriptions of the duties of staff it is entirely worthless.
- support children who have been abused in accordance with his / her agreed child protection plan;
Certainly the school ought to be alert to this, but it is not a safeguarding issue. It is a health and safety issue and should go in the health and safety policy. Here, it is more padding, designed to look impressive but have no practical effect.
- be alert to the medical needs of children with medical conditions;
Same thing. heath and safety procedures ought to be documented in the health and safety policy, not in the child protection policy.
- operate robust and sensible health & safety procedures;
What a fine upstanding array of qualified statements! "all practicable steps"; "as secure as circumstances permit".
- take all practicable steps to ensure that School premises are as secure as circumstances permit;
So if circumstances happen to be adverse, any failings are acceptable. Sorry, but no. There are minimum standards, and if meeting them is not "practicable", the school must close.
Policies on this are only relevant to child protection in as far as drug, alcohol or substance misuse may be a symptom of neglect or other abuse. Apart from that, this is irrelevant to child protection.
- operate clear and supportive policies on drugs, alcohol and substance misuse;
What a wonderful piece of meaningless and qualified gibberish! again, it sounds wonderful, and commits the school to doing precisely nothing.
- consider and develop procedures to deal with any other safeguarding issues which may be specific to individual children in our School or in our local area; and
If the school hasn't already implemented everything required by those regulations within the body of the procedures, a mention of them here is going to make no difference. Again, this intended to baffle parents with bullshit, in this case by means of spurious reference to external regulations. This bullet adds nothing of substance.
- have regard to guidance issued by the Secretary of State for Children, Schools and Families (DCSF) in accordance with section 157 of the Education Act 2002 and associated regulations.
We we have now reached the end of paragraph 4, and there is still hardly any actual content. About the only thing mentioned is that they will "take all reasonable measures" to check people out before they recruit them as staff, governors or volunteers. The school is required by law to do that anyway, and the requirements of the law are a good deal more specific than have been described here.
So we've completed a page and a quarter of a 12-page document, and we don't have any content yet. How many people would read beyond the first page? Stay with me. We can!