Paragraphs 18-21 describe what a teacher hearing an allegation is supposed to do. I'll quote the whole of these four paragraphs together.
18. Initial complaintParagraph 18 isn't at all bad. The steps to be taken are broadly the ones required by good safeguarding practice. I would quibble a bit about the phrase "sufficient written record" - sufficient for what? Basically the record should contain everything the teacher can reasonably remember about what the child has said and about the child's behaviour at the time.
A member of staff suspecting or hearing a complaint of abuse:
19. Preserving Evidence: All evidence (for example scribbled notes, mobile phones containing text messages, clothing, computers), must be safeguarded and preserved.
- must listen carefully to the child and keep an open mind. Staff should not take a decision as to whether or not the abuse has taken place;
- must not ask leading questions, that is, a question which suggests its own answer (“was it your father?” or “did this take place on Tuesday when you were away?”);
- must reassure the child but not give a guarantee of absolute confidentiality. The member of staff should explain that they need to pass the information to the Designated Teacher who will ensure that the correct action is taken;
- must keep a sufficient written record of the conversation. The record should include the date, time and place of the conversation and the essence of what was said and done by whom and in whose presence. The record should be signed by the person making it and should use names, not initials. The record must be kept securely and handed to the Designated Teacher.
21. Reporting: All suspicion or complaints of abuse must be reported to the Designated Teacher, or if the complaint involves the Designated Teacher, to the Headmaster or other Deputy.
- Make brief notes as soon as possible after the meeting. This may be possible in the meeting itself.
- Write up your notes in full and include time, date, place and signature.
- Describe observable behaviour e.g. was shaking, continued to cry, constantly moved around the room. (Do not interpret these features)
- Record the actual words spoken by the child wherever possible.
Paragraph 19 is a bit more of a problem in the way it is written. Mobile phones and computers not already the property of the school cannot be taken from their owners without consent, even if they contain evidence of possible abuse. To do so is theft. In the event that evidence is contained within such items, the safeguarding of evidence must consist of copying the information and promptly returning the device to its owner. Furthermore, in the event of an allegation or suspicion of a crime, it is not the task of the school to investigate, but instead to immediately refer the matter to the police and/or Social Services, who have both the duty and authority to obtain and safeguard evidence in the way described.
Paragraph 20 is a more extended version of the record-keeping part of the last bullet of paragraph 18.
Similarly, paragraph 21 is an extended version of the reporting requirements of the last bullet of paragraph 18. There is some contradiction here. Paragraph 18 requires that the report is provided to the Designated Teacher, while paragraph 21 qualifies this, in the case where the Designated Teacher is the subject of the complaint, in which case the report is provided to the Headmaster or other deputy.
In fact, good safeguarding practice should have a slightly more formal reporting chain than this, unambiguously covering all possible cases. The report should be made to the Designated Teacher if the concern involves the conduct of a volunteer, visitor, governor, trainee or another young person or child, or somebody from outside the school. If the concern involves the conduct of a member of staff, the report should be made to the Headteacher. If the concern involves the conduct of the Headteacher, the report should be made to the governor or trustee who has been designated as having responsibility for child protection. In the absence of such a designated governor, the chairman of trustees (i.e. the Abbot) automatically assumes that role.
For all that these paragraphs are about the best-written of the document so far (not all that much of a commendation admittedly), they still give the impression of not really having been read and edited for consistency and organisation. Something this sloppily put together doesn't inspire confidence in the care with which it has been written or will be implemented.