Supplementary guidance for inspecting safeguarding in schools and PRUs

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Guidance for inspectors in evaluating the effectiveness of safeguarding

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Pre-inspection evidence

Inspectors will use a wide range of evidence. Before the inspection, in relation to safeguarding and promoting welfare, the Reporting Inspector will consider:

  • the school’s most recent evaluation of its safeguarding and child protection procedures
  • the local authority report on the school
  • the previous inspection report
  • data on aspects of behaviour such as exclusions; serious incidents and the use of physical interventions
  • the school’s policies for safeguarding and promoting welfare, including the child protection policy
  • written information from parents or other partners
  • any complaints we may have received
  • responses to the pupils’ questionnaires, in particular the responses to questions about feeling safe, bullying, having someone to talk to if worried, keeping healthy and taking regular exercise
  • responses to the parents’ questionnaires, especially the questions about encouragement to be healthy and take exercise, being safe and receiving the additional support for any particular needs
  • responses to staff and governor questionnaires, especially the questions referring directly to the school’s safeguarding procedures, managing pupils’ behaviour and dealing with bullying and harassment.

It is important that we do not share individual comments from any questionnaire with the school. The comments from the learner and parent questionnaires are in the inspection documents area and should be kept confidential to the team. Comments from the staff and governor questionnaires are kept securely in the RI area and should remain confidential to the RI.

Inspectors should take particular account of the school’s context, including where available information on:

  • the number of children on the child protection register
  • the number of refugees or asylum seekers
  • the number of looked after children
  • exclusions and transfers of pupils

Where pre-inspection evidence identifies possible safeguarding issues or poor management practice by the provider, inspectors should seek guidance from their sector AD and the safeguarding team. Where an issue is considered reportable, our safeguarding policy must be applied.

Planning the inspection

Responsibility for inspecting safeguarding should be shared by all members of the team, but ultimately rests with the reporting inspector. The RI may allocate specific tasks to any team member, including the peer inspector and lay inspector. It may be that different inspectors are responsible for different aspects of safeguarding and promoting welfare as they occur in more than one quality indicator, for example in 2.1, 4.1 and 4.2 as well as in aspects of leadership and management in Inspection Area 5. As in all inspections, the reporting inspector takes on overall responsibility for the conduct of the inspection and needs to monitor the work of the inspector(s), taking the lead on issues concerned with safeguarding and promoting the welfare of learners, particularly those regarding child protection.

All schools will complete a comprehensive self-evaluation in relation to safeguarding and child protection prior to inspection. This will provide a useful overview of the issues which need to be taken into consideration when evaluating the school’s policy and procedures for safeguarding, including child protection. Providers are at liberty to use any suitable safeguarding and child protection self-evaluation model they wish. A useful self-evaluation template can be found on our website and within the Welsh Government guidance document, Keeping Learners Safe (2020).

Where a safeguarding issue has been raised about the school / PRU prior to an inspection, a safeguarding officer will have flagged the provider using a safeguarding alert. The IC will inform the RI of the flag and will ask them to contact the safeguarding officer for further information and advice. This might include possible questions and further areas to evaluate, linked to the safeguarding issues raised in the alert. RIs should include a brief comment in the safeguarding section of the reporting JF detailing what actions were taken during the inspection relating to the safeguarding alert. 

The reporting inspector will need to consider how effectively the school has evaluated their own procedures for safeguarding and promoting welfare. This will help establish the extent to which safeguarding policies and procedures are properly implemented and monitored. If the school does not upload an evaluation, this should cause concern about how robustly the school evaluates its own procedures, and how well leaders promote the school’s safeguarding culture. In the light of this evaluation, the reporting inspector will need to allocate time to gather enough evidence to support the team’s judgements. This may include asking questions specifically relating to safeguarding and promoting welfare at meetings with:

  • the headteacher or principal / teacher in charge
  • representative(s) of the governing body / management committee
  • staff
  • parents
  • pupils

Inspectors may also arrange to meet with the designated person with responsibility for child protection if this is not the headteacher /principal / teacher in charge.
 

Inspection activity

When inspecting schools in relation to safeguarding, inspectors will evaluate the following:

  • whether the school has an up-to-date self-evaluation which considers the effectiveness of its safeguarding and child protection duties, including online safety activity, and how well it sets out areas of strength and areas for improvement
  • how well the school implements and monitors its policies and procedures to improve how it safeguards and promotes the welfare of children in accordance with Welsh Government’s statutory guidance found in Keeping Learners Safe ((2020). keeping-learners-safe-the-role-of-local-authorities-governing-bodies-and-proprietors-of-independent-schools-under-the-education-act.pdf
  • whether the school reports regularly to senior managers and governors, and how well it uses its data and evaluations of safeguarding about incidents in the school, including online safety aspects and incidents
  • whether all school staff are clear about their responsibilities and what they need to do to protect pupils and that all staff have received relevant child protection and safeguarding training, including ‘Prevent’ duties
  • whether all safeguarding related records are up to date, including incidents of alleged bullying, physical intervention, child protection referrals, safe recruitment and DBS checks, and safeguarding training
  • whether there are consistent approaches to the management and reporting of safeguarding incidents and behaviour management issues within the school, which are supported by clear policies and procedures, and which include the management of internet and social media related incidents
  • whether there are suitable arrangements to take action where any pupil’s pattern of attendance causes concern, and whether the school’s monitors and acts on pupil absences for all or part of the school day 
  • how well the school develops pupils’ knowledge and understanding of emotionally damaging or unsafe behaviours, for example grooming, harassment, discrimination, prejudice-related bullying, and extremism, in line with their stage of development
  • whether there are appropriate arrangements for developing pupils’ awareness and understanding of how to be safe including safety on line, and which are regularly included in the school’s curriculum
Reporting on safeguarding

Inspectors will report on whether the school’s arrangements to keep pupils safe meet requirements and give no cause for concern.

They should consider whether it is appropriate to describe the nature of any strengths or shortcomings in the report, for example to allay parents’ concerns. 

Where arrangements do not meet requirements, inspectors should normally include a recommendation to improve the provision and that the school/PRU address the safeguarding / wellbeing issues identified during the inspection. After the inspection, we will issue a ‘wellbeing’ letter to the school and the local authority to seek assurance that they are addressing the shortcoming(s) suitably. 

Where inspectors judge safeguarding arrangements in maintained schools and PRUs to be incomplete, ineffective, or not compliant with statutory requirements and /or learners are not safe, it is important that these issues, are properly recorded in the reporting JF and brought to the attention of the provider. Where the disclosure of the exact nature of these concerns would create additional risks to the wellbeing of pupils, inspectors should include the following statement in the main evaluation for inspection area 4:

‘The school’s / PRU’s arrangements for safeguarding pupils do not meet requirements and give serious cause for concern.’

Where inspectors judge that drawing attention to the exact nature of a concern would not expose pupils to additional risks, inspectors can refer to the concern in their main evaluation for inspection area 4. For example, where there are concerns over traffic management at a school site inspectors can make reference to this in their report

The RI should issue a wellbeing letter detailing the exact nature of the safeguarding / wellbeing concerns. The Inspection Co-ordinator will guide the RI through the process and manage the drafting of the letter with the appropriate Assistant Director.

Where matters are minor and/or easily remedied, and are not considered significant, there is no need for a comment or a recommendation in the final inspection report. Consequently, the RI should not issue a wellbeing letter to the provider. However, the RI must ensure that the concerns are raised and plans to address them discussed with the provider as soon as possible.

The RI must ensure that details of the concerns are recorded in the Reporting JF, including any action taken by the provider to address them.

In independent schools when safeguarding arrangements are incomplete, not effective, do not comply with statutory requirements and /or learners are not safe you must discuss them at the team’s moderation meeting, and include a comment in the report. In these cases, the school will not meet the requirements of standard 3 of the Independent school standards regulations and depending on the nature of the issues may not comply with regulations in standard 4. Where standards relating to safeguarding are not met, we will issue a wellbeing letter to the proprietor, copied to Welsh Government as the regulator for independent schools. Welsh Government will ask the school to provide an action plan.

Where there are serious concerns over safeguarding arrangements in an independent school the RI should discuss these with the sector lead who will liaise with the safeguarding team, the Assistant Director and Welsh Government.

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