Safeguarding Policy

Child Protection and Safeguarding Policy

1. Scope and Aims

    This policy applies to the MFL Mentoring project, which includes but is not limited to Year 8/9 Mentoring, Linking Language Workshops, Multilingual Mentoring in Primary Schools and the Love Reading Mentoring Project.

    The aim of the MFL Mentoring project is to increase the number of pre-GCSE learners opting to choose an International Language for GCSE through one-to-group mentoring or workshops.

    The aim of the Love Reading Mentoring Project is to increase literacy levels and Key Stage 2 interest in reading through one-to-group mentoring.

    The aim of the Multilingual Mentoring in Primary Schools project is to increase the number of learners interested in languages and cultures through one-to-group mentoring or workshops.

    The MFL Mentoring Project team, and all other affiliated project team staff such as the Love Reading Mentoring Project, fully recognise our responsibilities for Safeguarding and Child Protection and this policy sets out how we will work to fulfil our responsibilities.

    This policy outlines how we, as a project team, will work to:

    1.1 Ensure that we actively support the safeguarding of the young people we work with in their schools by working within the individual safeguarding structures of each school we partner with and as outlined in Keeping Learners Safe (Welsh Government, 2022).

    1.2 Ensure that we actively consider and identify the relevant risks that could occur as a result of this project, and as far as possible, prevent them from occurring.

    1.3 Remain vigilant to the possibility of safeguarding and child protection risks within this project.

    1.4 Act swiftly in relation to any safeguarding or child protection issues that occur as a result of this project and work with the school and other relevant statutory authorities to assess and manage them. 

    1.5 Feed any learning about safeguarding from this project into this policy and review it on an annual basis.

    This policy recognises that all of the children and young people supported through our Modern Foreign Languages Mentoring Project (MFL Mentoring) and any programmes affiliated with MFL Mentoring such as the Love Reading Mentoring Project, are located in our partner schools which all have their own child protection policies, and that any safeguarding issues that arise in relation to young people who are mentored as part of our project will be covered by the policy of these individual schools. This policy fully recognises the authority of the policies that exist in all partner schools and only seeks to supplement those policies in relation to the needs of the project and the specific support we give to our volunteer mentors.  All of the procedures described in this policy will tie in with school safeguarding procedures which remain of critical importance.   

    2. Key contacts and emergency contacts

       Lucy Jenkins is the MFL Mentoring Safeguarding Lead and Project Director of MFL Mentoring and any affiliated projects ( In the event of absence or emergency, the project’s Secondary Safeguarding Leads are Glesni Owen ( and Becky Beckley ( In the case of the Love Reading Mentoring Project, the Secondary Safeguarding Officer is Alexandra Nita (

      All schools have a child protection policy which will provide the name and contact details of the school’s Designated Safeguarding Person (DSP) for child protection. The DSP will decide whether a referral needs to be made to relevant services to keep a child or young person safe.

      If the school DSP is not available when an incident occurs, all those engaged with the project are aware that if they are concerned that a child is being abused or might come to immediate harm they must call the police – 999 in an emergency and 101 for all other enquiries. 

      All those engaged with the project are also made aware that they can contact the local authority child protection team to make a referral in the local authority in which they are based.

      3. Definitions

      It is important that those involved in this project – whether as a member of the project team or as a volunteer student mentor – have an understanding of safeguarding and the different forms of child abuse. 

      Safeguarding is defined as:

      • Protecting children from abuse and maltreatment;
      • Preventing impairment of children’s health or development;
      • Ensuring the children are growing up in circumstances consistent with the provision of safe and effective care; and
      • Taking action to enable all children to have the best life chances and outcomes.

      Child Abuse

      Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to actto prevent harm. Children may be abused in a family or in an institutional or community setting; by those known to them or, more rarely, by others (e.g. via the internet).  They may be abused by an adult or adults, or another child or children. 

      There are four types of abuse as defined in all Wales Child Protection Procedures (2008).  There are more detailed definitions and descriptions of the four main types of abuse in Appendix 1. 

      • Emotional: The persistent emotional ill-treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional and behavioural development.
      • Neglect:The persistent or severe neglect of a child, or the failure to protect a child from exposure to any kind of danger, including cold, starvation or extreme failure to carry out important aspects of care, resulting in the significant impairment of the child’s health or development, including nonorganic failure to thrive.
      • Physical: The hitting, shaking, throwing, poisoning or scalding, drowning, suffocating or otherwise causing physical harm to a child.  Physical harm may also be caused when a parent or carer fabricates or induces an illness in a child whom they are looking after.
      • Sexual:Forcing or enticing a child or young person to take part in sexual activities, whether or not the child is aware of what is happening, including:
      • Physical contact, including penetration or non-penetrative acts
      • Non-contact activities, such as involving children in looking at, or in the production of pornographic material or watching sexual activities; or
      • Encouraging children to behave in sexually inappropriate ways.

      As a project team we undertake to uphold the highest standards of safeguarding and to ensure that we are doing everything we can to reduce risks to those we work with. 

      4. Contextual Safeguarding

      In addition to the above, MFL Mentoring and Love Reading Mentoring recognise the importance of ‘contextual safeguarding’ and understand that children and young people (and particularly older young people) may be at risk, not only in their families but also within the context of their communities and peer groups.  Further information about some key specific safeguarding concerns children and young people may experience is appended to this policy at Appendix 2. 

      5. Training, Awareness and Understanding

      As part of our commitment to safeguarding and upholding safeguarding standards we will regularly train our staff and student mentors to ensure that they understand basic safeguarding, what is required of them, and how they can report concerns. This safeguarding training will be delivered to all newly recruited student mentors (and project team members) and will be refreshed before each new cycle of mentoring commences (October of each year).  All mentors will undertake a short test during the training to ensure that the main points of the safeguarding presentation have been understood. Any student mentor that fails this test will not be placed in a school until they have passed this test.  

      6. Vetting

      The student mentors in this project will be required to undertake an Enhanced DBS (Disclosure and Barring Service) check to ensure that there is nothing that is known about them that would suggest they present a risk to children.  However, we also recognise that not all individuals who may present a risk to children will have criminal records and it is important to always remain vigilant. 

      As part of the project’s recruitment process, student mentors must complete two full days of face-to-face mentor training. During this time any concerns about a student mentor’s attitude or approach can be raised, and if, following this, there are any concerns about their suitability to work with children, they will not be taken forward as a student mentor. 

      Behaviours of concern might be an overfamiliarity with children and a failure to understand the boundaries of the role; a failure to conduct themselves in a responsible manner with children; or a failure to take the project or the safeguarding elements of the project seriously.  See the section below on the behaviours we expect in our project.     

      7. Standards of Behaviour

      It is integral to our policy to have clear standards of behaviour that we expect from our staff and student mentors, so that  everyone involved with the project are clear about what is expected of them in relation to safeguarding. 

      Our mentoring programme is based on the principle that children and young people can benefit immeasurably from supportive relationships with adults who can guide and help them. However, we encourage all our student mentors to be thoughtful and reflective about how their behaviour may be open to scrutiny, and we offer them clear guidance about behaviours and actions that are not acceptable. 

      We expect our staff and student mentors to model best practice in relation to working with children and young people and not engage in any of the following behaviours:

      • Bullying, harassment or discrimination against any child (even in subtle ways such as drawing attention to personal or physical differences).
      • Belittling or shaming a child who is struggling or who finds the work difficult. 
      • Hitting, smacking or causing physical harm to a child as an outlet for frustration or as a means of discipline.
      • Interacting with children in an inappropriate way, singling them out for praise or attention or trying to humiliate them or make them feel uncomfortable.
      • Engaging in physical contact with children of any kinds, even where this is intended to be affectionate or comical.
      • Entering an intimate or sexual relationship with a child or using sexual language around them including suggestive comments or conversations.
      • Entering into a relationship with a mentee outside of the project.
      • Engaging with the mentees on social media, such as WhatsApp, Snapchat, Instagram or another social media service, messaging service or game. Accepting friend invitations or sharing personal numbers with any of the children in the project. 
      • Taking pictures of the children or sharing photos of yourself. 
      • Giving gifts, privileges or rewards to a child to build a special relationship with them.
      • Undertaking mentoring duties whilst under the influence of alcohol or drugs.

      8. Online Safeguarding

      Where online mentoring is concerned, MFL Mentoring facilitates one to small group (6-12 children in normal circumstances) mentoring between the student mentors engaging with the project and the children and young people within the schools in which they are working.  The project follows the procedures laid out in the Live-streaming and video-conferencing: Safeguarding principles and practice for online safeguarding (Welsh Government, 2021) guidance, in addition to the Keeping Learners Safe (Welsh Government, 2022) guidance.

      There are considerable educational benefits and equal access opportunities relating to the provision of online mentoring, but we recognise that it also presents an additional layer of safeguarding risk. The additional risk is a consequence of the fact that this mode of mentoring facilitates online communication between the student mentor and the mentee/s that is removed from the direct supervision of other adults within the school which presents some increased degree of opportunity for a bad actor to coerce or harm a child should they be intent on doing so.

      The project uses MS Teams and/or Google Classroom accessed and monitored through Welsh Government’s bespoke digital platform Hwb. Where required, the project/suse  the school/setting’s own implementation of Google/Microsoft 365 for any online or blended mentoring sessions or workshops. Sessions or workshops take place on MS Teams and/or Google Classroom via Hwb or the school/setting’s own implementation of Google/Microsoft 365, and every student mentor is provided with a Hwb account and email address to use for the duration of their time with the project. The Hwb account is then deleted when a student mentor leaves the project. This is to mitigate against any learner that engages with the project being able to contact a student mentor through a personal or university email address, as all student mentors are required to only use their Hwb account when engaging online through MS Teams or Google Classrooms with their mentees.

      That being said, in addition to the above, all messages are recorded and viewable by the project team and nominated staff from the partner school on MS Teams or Google Classroom via Hwb.  All conversations take place in a group setting and are reviewed by the project team, so no conversations take place without oversight from staff.

      Communicating online has also been shown to have a subtle impact on people’s behaviours – in some cases removing their inhibitions and learners feel invisible or immune to the consequences of rule breaking for example. The project recognises the additional layer of potential risk created by this process and will ensure that there are safeguards in place around these online interactions that reduces any risk they may present. 

      This includes the following safeguards:

      8.1 We will clearly communicate to our mentors that the standards of behaviour expected of them that are described above in section 7 apply online as well as offline.

      8.2 We will ensure that the online interactions between mentors and mentees occur via Hwb, the Welsh Government bespoke platform, using MS Teams and/or Google Classroom or the school/setting’s own implementation of Google/Microsoft 365 with no links to wider social media.

      8.3 We will ensure that the platform we use does not share wider details, usernames, passwords or identifying details of either party or link to other internet-based sites or services.   We will reiterate to mentors that they must not share these details or allow the children and young people to share them. 

      8.4 The project will be open that it will record all online chat that takes place between the student mentors and their mentees. The project team will dip sample and review the transcripts of these interactions weekly during the mentoring cycle.

      9. Responding to Safeguarding Risks and Concerns

      As explained above, safeguarding issues within this project will be dealt with within the framework and procedures of the school policy they are reported within and as outlined in Keeping Learners Safe (Welsh Government, 2022).  However, it is important that the project team are made aware if concerns are raised within school and that the project can act on any information that they become aware of independently. 

      9.1 Concerns raised by a student mentor about a mentee

      It is recognised that a student mentor within this project may receive a disclosure from a child they are mentoring, or they may become aware of information relating to a child that they feel they need to act on.  Some children may choose to disclose to a student mentor because they may feel they are more approachable (as they are closer in age) and they may feel a closer connection with the mentor because they have worked with them in small groups.  In some parts of the project, such as during online communication, it is possible that children may feel that a student mentor is more accessible because they have had the opportunity to communicate with them online.   

      When listening to a disclosure from a child, mentors and anyone involved in the project is instructed to: Listen carefully and patiently to what they are saying and make clear that you take the matter seriously.

      • Reassure them they are not to blame.
      • Encourage the child to talk and let them tell their story in their own way. Do not prompt or ask leading questions.
      • Don’t make the child repeat their account.
      • Explain what actions you must take, that they were right to inform you, and that you will inform the school’s DSP.
      • If visiting the school in any face-to-face context, that any concern is raised with the contact teacher or DSP at the school before leaving the school premises.

      Referring to the Designated Safeguarding Person (DSP) within school

      Student mentors must write down the details of any disclosure and pass on the information to the Designated Safeguarding Lead within the school as soon as possible.   

      A student mentor within this project should also ensure that they report any concerns they have about the welfare and safety of a child to the DSP within school. This might not be as a result of a direct disclosure from a child but might be triggered by concerns about the behaviours or actions of a child they are working with.

      Reporting within the project

      The student mentors should also complete a short statement including only relevant details of the safeguarding concern to be passed on to the project team. The project team will use this to ensure that the matter is being dealt with by the teacher and DSP within the school. Sensitive case information about safeguarding should only be shared by those who are able to take action so the content of the referrals should not be shared with the project.  However, the project team needs to be made aware if a mentor makes a referral within a school/s so that they can understand the issues that are arising for mentors and support them accordingly. 

      Reporting urgent concerns out of school hours

      Student mentors should always report their safeguarding concerns through the structures within their schools where possible.

      However, should a student mentor (or member of the project team) become aware of an immediate risk to a child out of school hours or realise there is such a risk, there should be an immediate referral of their concerns to the local police (as in section 2 above).  The DSP at the school should be made aware of any referral to emergency services as soon as possible following this action.   

      9.2 Concerns raised about the actions or behaviours of a student mentor

      Allegations of abuse or criminal activity

      Concerns about student mentors may be raised by the children who are being mentored, teachers linked to the project or by other teachers within the school or by fellow mentors.  Any serious allegations of abuse should be dealt with within school procedures. This would include if there were an allegation that a student mentor has:

      • behaved in a way that has harmed a child, or may have harmed a child;
      • possibly committed a criminal offence against or related to a child; or
      • behaved towards a child or children in a way that indicates  they may pose a risk of harm to children.

      Any instances of the above should be reported to the DSP who will engage with the Local Authority Designated Officer and Local Police.  The project lead should be made aware immediately by school staff and student mentors themselves.  If the student mentor wants to continue to work as a mentor despite the allegation their ongoing participation in the project will be based on a risk assessment commissioned by statutory leads. 

      The project lead will communicate with the student mentor while an allegation is being investigated and ask that the DSP keep them updated on the progress of any investigation. The project lead will also make efforts to identify support available for the student mentor during an investigation. 

      The project lead should also liaise with the DSP to ensure that an investigation about behaviour that indicates an individual is a risk to a child is completed and has an outcome (even in cases where there are no criminal charges) and despite the fact that a student mentor is a volunteer within the school.  The project lead will also ensure that a referral of a relevant finding is made to the DBS if the findings of an investigation suggest that a student mentor could present a risk to children if working with them in future roles.

      Lucy Jenkins, the Project Director, will also alert the Lead Safeguarding Officer of the relevant Higher Education Institute if an allegation is made against a student from their institution. Where appropriate, it will be the responsibility of the student’s official institution (the institution where they are registered as a student) to pursue relevant further action in relation to the student. Further information and details of Safeguarding Leads for each institution can be found below:

      InstitutionSafeguarding RoleTitleNameEmail
      Aberystwyth University Lead Safeguarding OfficerPro-Vice Chancellor: Learning Teaching and Student ExperienceTim
       Designated Reporting OfficerFaculty Manager: Business and Physical SciencesDave
      Bangor University Designated Safeguarding OfficerSenior Safeguarding, Conduct and Complaints OfficerSteve
        Safeguarding, Conduct and Complaints CoordinatorIfan
      Cardiff UniversityLead Safeguarding OfficerAcademic RegistrarSimon
       Principal Safeguarding Officer – StudentsDirector of Student Support and WellbeingBen
      Cardiff Metropolitan University Safeguarding OfficerHead of ComplianceJayne
      Oxford UniversitySafeguarding OfficerDirector of Student Welfare and Support ServicesN/
      Royal Welsh College of Music and Drama (RWCMD)Lead Safeguarding OfficerDirector of Academic Administration and Student ExperienceBrian
       Designated Person for SafeguardingStudent Support ManagerKate
      Swansea University Lead Safeguarding OfficerHead of SafeguardingCheryl
       Designated Person for SafeguardingTraining Officer for Safeguarding and PreventStevie 
      University of South Wales (USW)Lead Safeguarding OfficerUniversity Secretary and Clerk to the GovernorsWilliam
       Principle Safeguarding OfficerDirector of Organisational DevelopmentCatherine
      University of Wales Trinity St. David’s (UWTSD)Lead Designated Officer Catharine
       Operational OfficerLecturer – Institute of Education and HumanitiesSioned
      Wrexham University Designated Safeguarding OfficerDeputy Vice-ChancellorProfessor Claire
       Designated Safeguarding OfficerStudent Advice & Guidance ManagerSally

      Lower-level concerns or transgressions of expected standards of behaviour

      Lower-level concerns about a student mentor which may violate aspects of the standards of behaviour required but which are not serious enough to trigger a statutory investigation or a formal investigation by the school will be dealt with by the project safeguarding lead in conjunction with relevant staff from the school.

      Any transgressions of the code of behaviour would normally lead to dismissal of the individual from the project but this policy recognises there may be circumstances where an individual has acted unwisely but without any ill intent and may have recognised that they have done the wrong thing and have taken steps to remedy their actions and seek advice. 

      In these circumstances such an individual would not be deemed to pose a risk to children.  Where such lower-level concerns are raised about a mentor’s behaviour this is a discretionary judgement for the project safeguarding lead to make in conjunction with the school – any decision should reflect on the safeguarding and welfare of the children in the school and be clearly recorded in writing by the project safeguarding lead.

      10. Keeping Records

        Cardiff University will keep your personal data for no longer than is necessary for the purposes of the investigation.

        11. Revising this Policy

          The Project Director will follow up any safeguarding issues or concerns that are raised as a result of engagement with the MFL Mentoring or any affiliated projects and carry out any necessary actions as soon as possible and without any undue delay.  The Project Director will also ensure that after each cycle of mentoring is completed, the project team have the opportunity to reflect more broadly on the learning from any safeguarding issues that have been raised during the mentoring and consider whether any changes need to be made to this policy or the procedures described in this document.  

          This policy was last updated on 3rd August 2023.  

          Appendix 1 – Extended definitions of the four main types of abuse from the English guidance (Keeping Children Safe in Education 2022)                                   

          Physical Abuse

          Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. This may include an online element which facilitates, threatens, and/or encourages physical abuse.

          Emotional Abuse

          Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

          Sexual Abuse

          Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape or oral sex) or non-penetrative acts such as masturbation, kissing or rubbing and touching outside of clothing. They may include non-contact activities, such as involving children in looking at, or in the production of, sexual online images, watching sexual activities, or encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse as can other children.


          Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.

          Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

          • provide adequate food, clothing, and shelter (including exclusion from home or abandonment)
          • protect a child from physical and emotional harm or danger
          • ensure adequate supervision (including the use of inadequate care-givers)
          • ensure access to appropriate medical care or treatment.

          It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

          Appendix 2 – Specific Safeguarding Issues

          It is important for the project team and student mentors to be aware of a range of critical safeguarding issues in relation to  children and young people, so they can identify these and act on concerns.  Each school should have information about these in their own policies as well as information about how they handle and manage such issues as they arise.  Some key information is included here to enable mentors and those covered by the MFL Mentoring policy to understand these issues.  If a student mentor has any concerns that any of the issues below are impacting on the children they are working with they should report the issues to their DSP immediately. 

          The information below has been taken from a range of sources including Keeping Children Safe in Education (Welsh Government,2022) and NSPCC Learning

          Peer on Peer Abuse

          The project is aware that children are capable of abusing other children. This is generally referred to as peer-on-peer abuse and can take many forms. This can include (but is not limited to): bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals.

          This should always be treated seriously and must not be minimised or seen as banter or part of growing up. In the case of abuse by a learner, or group of learners, the key indicators identifying the problem as abuse (rather than an isolated instance of bullying) are:

          • the nature and severity of the incident(s),
          • whether the victim was coerced by physical force, fear, or by a learner or group of learners significantly older than him or herself, or having power or authority over him or her,
          • whether the incident involved a potentially criminal act, and whether if the same incident (or injury) had occurred to a member of staff or other adult, it would have been regarded as assault or otherwise actionable.

          Sexual Violence and Sexual Harassment

          Sexual Violence and Sexual Harassment is one particular form of peer-on-peer abuse. If mentors observe or identify harmful incidents and problematic behaviour which includes language seen as derogatory, demeaning, inflammatory, homophobic or hate based this should be reported to the DSP immediately for the school to take action.  This should include a risk and needs assessment of the victim, the perpetrator and other children who may be at risk.

          Sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing.  Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Evidence shows girls, children with SEND and LGBTQIA+ children are at greater risk.

          It is useful to be aware of the importance of:

          • making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up;
          • not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”; and
          • challenging behaviours (potentially criminal in nature), such as grabbing bottoms, breasts, and genitalia, flicking bras, and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them.

          Sexual Violence

          It is important that school and college staff are aware of sexual violence and the fact children can, and sometimes do, abuse their peers in this way. When referring to sexual violence we are referring to sexual violence offences under the Sexual Offences Act 2003 as described below:

          Rape: A person (A) commits an offence of rape if: s/he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents.

          Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents.

          Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents.


          Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal, or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.

          Sexual Harassment

          When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of child-on-child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. Whilst not intended to be an exhaustive list, sexual harassment can include:

          • sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names;
          • sexual “jokes” or taunting;
          • physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (schools and colleges should be considering when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim) and displaying pictures, photos, or drawings of a sexual nature; and
          • online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence.  It may include:
            • non-consensual sharing of sexual images and videos;
            • sexualised online bullying;
            • unwanted sexual comments and messages, including, on social media;
            • sexual exploitation; coercion and threats; and
            • up skirting

          Child Sexual Exploitation

          Child Sexual Exploitation is defined in Definition of Child Sexual Exploitation (HM Government, 2016) as:

          “a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.”

          Child exploitation is a form of child abuse which involves children and young people receiving something in exchange for sexual activity. Like all forms of child sex abuse, child sexual exploitation:

          • can affect any child or young person (male or female) under the age of 18 years, including 16- and 17-year-olds who can legally consent to have sex;
          • can still be abuse even if the sexual activity appears consensual;
          • can include both contact (penetrative and non-penetrative acts) and noncontact sexual activity;
          • can take place in person or via technology, or a combination of both;
          • can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence;
          • may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media);
          • can be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse; and
          • is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.

          The key indicators of child sexual exploitation include:

          • Going missing for a period of time or regularly coming home late
          • Regularly missing school or education or not taking part in education
          • Appearing with unexplained gifts or new possessions
          • Associating with other young people involved in exploitation
          • Having older boyfriends or girlfriends
          • Having sexually transmitted infections
          • Suffering from mood swings or changes in emotional wellbeing
          • Drug or alcohol misuse
          • Displaying inappropriately sexualised behaviour

          Many children who are experiencing sexual exploitation do not recognise themselves to be victims.

          Child Criminal Exploitation: County Lines

          Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market, and seaside towns. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked.  Like other forms of abuse and exploitation, county lines exploitation:

          • can affect any child or young person (male or female) under the age of 18 years;
          • can affect any vulnerable adult over the age of 18 years;
          • can still be exploitation even if the activity appears consensual;
          • can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;
          • can be perpetrated by individuals or groups, males or females, and young people or adults; and
          • is typified by some form of power imbalance in favour of those perpetrating the exploitation. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources.

          If a mentor comes to believe that a child is facing criminal exploitation through a drugs gang or group, they should report it immediately. 

          Domestic Abuse

          The cross-government definition of domestic violence and abuse is: Any incident or pattern of incidents 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. The abuse can encompass, but is not limited to:

          • psychological;
          • physical;
          • sexual;
          • financial; and
          • emotional

          Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.  Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.

          ‘Honour-based’ Violence and Female Genital Mutilation (FGM)

          So called ‘honour-based’ violence encompasses crimes which have been committed to protect or defend the honour of a family, including FGM, forced marriage and practices such as breast-ironing, all of which are abuse. Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. All forms of HBV are abuse (regardless of the motivation) and should be handled and escalated as such.

          FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs for non-medical reasons. The age at which girls undergo FGM varies according to the community; however, the majority of cases of FGM are thought to take place between the ages of 5 and 8. FGM is illegal in the UK and is considered a form of child abuse.

          There are a number of factors to be aware of which can indicate that a child is at risk of FGM or that FGM is imminent or has already taken place.  Any girl born to a woman who has been subjected to FGM; any girl who has a sister who has already undergone FGM; any girl withdrawn from Personal, Social and Health Education may be at risk as a result of her parents wishing to keep her uninformed about her body. A girl may have frequent urinary, menstrual or stomach problems; there may be prolonged or repeated absences from school or college, or she may confide that a ‘special procedure’ or a special occasion is going to happen so she can ‘become a woman’.

          If a mentor has reason to suspect that FGM has taken place or is imminent they should seek advice from the DSL immediately.

          Forced Marriage

          Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage.


          Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism, however there is no single way to identify an individual who is likely to be susceptible to extremist ideology.

          Prevent – all schools now have a duty under the counter terrorism and security act 2015 to ‘prevent’ people from being drawn into terrorism. This duty is known as the Prevent duty and summarises the requirements on schools to assess the risk of a child being drawn into terrorism by demonstrating understanding of the risks affecting children and how to identify such children, training staff to be able to identify such children and to protect children from exposure to terrorist and extremist material when accessing the internet. Mentors should be alert to any pupil who espouses extremist views or appears to be consuming extremist material.