Safeguarding and Prevent Policy

Table of Contents:

flow chart

The purpose of this policy is to support the actions and priorities as set out in the Safeguarding Strategy which outlines Eden Training Solutions’ desire and commitment in promoting positive practices throughout the organisation.




The purpose of this policy is to protect all its employees and learners from harm and to ensure that they feel safe. It also has the intent of providing everyone connected with Eden Training Solutions the necessary information about the Safeguarding and Prevent Policy and procedures adopted by the organisation. Anyone enrolled with Eden-ts or currently going through the enrolment process is considered a learner.

The purpose of this policy is to:

  • Protect learners who may be at risk of harm, abuse, or radicalisation.
  • Protect learners with wellbeing support needs.
  • Provide ongoing advice and guidance to all individuals associated with Eden-ts on procedures to follow if they suspect a learner might be at risk of harm, abuse, or radicalisation.
  • Ensure that all employees adhere to the required legal framework relating to Safeguarding and Prevent.
  • Ensure employees receive ongoing training and guidance.
  • Ensure that all Safeguarding processes are positively promoted throughout the organisation.


Legal Framework

The formulation of this policy considers legislation, policy, and guidance in order to provide a safe environment for everyone at Eden-ts. Below is a summary of the key legislation, policy, and guidance:



Eden-ts believes that every employee and learner has the right to work and complete their training in an environment where they feel safe and protected from the risk of harm, abuse, and radicalisation.

Eden-ts believes:

  • That the safety and welfare of its employees and learners should always be of paramount importance.
  • It is the right of every learner and employee, regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex or sexual orientation, to be protected equally from harm, abuse, and radicalisation.
  • All individuals working with learners have a moral and legal duty to protect and promote their welfare, especially regarding the prevention of abuse.
  • Partnerships with learners and other agencies are vital for promoting a safe environment and the Prevent Duty.
  • Some learners are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs, or other issues. Extra safeguards may be needed to keep learners who are additionally vulnerable safe from abuse.
  • Eden-ts seeks to safeguard all learners, employees, and visitors by following the six principles of safeguarding:


Empowerment – giving individuals as much freedom and power over decisions made about themselves as is reasonably possible.

Prevention – preventing neglect, harm, and abuse is the core function of safeguarding. It is better to act before harm occurs.

Protection – often the people that need protection in safeguarding are the ones that are unable to protect themselves or seek out appropriate protection so professionals need to be prepared to intervene.

Proportionality – it’s important that every case is dealt with individually and with all the facts taken into account without excessive intrusion.

Partnerships – use a multi-agency approach when dealing with a safeguarding concern or complaint.

Accountability – while named employees are most responsible for safeguarding, it’s up to everyone to do their part.


Eden-ts ensures learners, employees, and visitors are safe by:

  • Implementing the safeguarding and prevent policy and ensuring that effective procedures and guidelines are in place.
  • Ensuring there are robust safer recruitment processes in place.
  • Listening to, respecting, and valuing the information that may be shared.
  • Having a Designated Safeguarding Lead and team of deputies who are appropriately trained and skilled.
  • Having a Safeguarding and Welfare officer who is appropriately trained and skilled to support learners and employees.
  • Sharing information with relevant employees, partners, and agencies whilst considering confidentiality and keeping learners, parents, and carers appropriately informed.
  • Implementing effective employee training throughout induction with ongoing CPD opportunities. All Eden-ts employees are responsible for ensuring that their training is up to date.
  • Monitoring all concerns, including low-level concerns, and responding appropriately.
  • Building a safeguarding culture where employees and learners know how they are expected to behave and feel comfortable sharing concerns.
  • Recording, storing, and using information professionally and securely in line with data protection legislation and guidance.
  • Reviewing our policies, procedures, and practice on an annual basis or as and when required.


Key Contacts

As part of our duty of care, we have appropriately trained designated safeguarding leads and designated safeguarding officers to manage and support the safeguarding process.


Designated Safeguarding Lead
Lisa Whittick
Head of Quality
Mob: 07834807352 Tel: 08007563985
Email: or


Designated Safeguarding Lead
Lorna Newbould
Chief Executive Officer
Mob: 07595756162 Tel: 08007563985
Email: or


Designated Safeguarding Lead
Sarah Baker
Safeguarding & Welfare Officer
Mob: 07355677062 Tel: 08007563985
Email: or


Designated Safeguarding Officer
Sam Law
Operations Manager
Mob: 07764966295 Tel: 08007563985


Designated Safeguarding Officer
Elizabeth Harvey
Operations Manager
Mob: 07764966226 Tel: 08007563985


Designated Safeguarding Officer
Jessica Barton
Operations Manager
Mob: 07764966281 Tel: 08007563985


Designated Safeguarding Officer
Nicola Dutton
Operations Manager
Mob: 07764966260 Tel: 08007563985


External Contact Details
NSPCC Helpline
Tel: 0808 800 5000

Tel: 0800 1111



Eden-ts’ priority is the safety and protection of all its learners and employees, especially those more vulnerable than others. Employees have a duty to act where there is a safeguarding concern/incident or when abuse is reported. This policy outlines how Eden-ts will meet this commitment.

This policy applies to anyone working on behalf of Eden-ts, including senior managers and board members, paid staff, volunteers, sessional workers, agency staff, and learners.


Definition of Terms


Safeguarding is the action that is taken to promote the welfare of children and vulnerable adults and protect them from harm. Safeguarding means:

  • Protecting children and vulnerable adults from abuse and maltreatment
  • Preventing harm to children and vulnerable adults’ health or development
  • Ensuring children and vulnerable adults grow up with the provision of safe and effective care
  • Taking action to enable all children, young people, and vulnerable adults to have the best outcomes


Wellbeing Support Needs
Supporting learners to gain access to the help that they require to enable them to reach their potential


Children and Young People
Anyone under the age of 18 years


Vulnerable Adults
Anyone over the age of 18 who:

  • Is in need of community care services
  • Is unable to care for themselves
  • Is unable to protect themselves against significant harm or exploitation
  • Has a physical or sensory disability
  • Is physically frail or has a chronic illness
  • Has a mental illness or dementia
  • Has a learning difficulty
  • Misuses drugs and/or alcohol or lives in a drug-misusing family
  • Has social and/or emotional issues
  • Exhibits challenging behaviours
  • Lives in areas of high crime
  • Is a victim of domestic abuse


Anyone of any age who is currently enrolled with Eden-ts or currently going through the enrolment process.


Anyone working for or on behalf of Eden-ts, whether on a paid or voluntary basis.


What We Are Safeguarding From

The list below is not exhaustive but lists the primary areas of concern:

  • Neglect
  • Physical abuse
  • Sexual abuse
  • Emotional abuse
  • Domestic abuse
  • Child sexual exploitation
  • Harmful sexual behaviour (HSB)
  • Bullying & cyberbullying
  • Online abuse
  • Female genital mutilation (FGM)
  • Child trafficking, forced marriage, and modern slavery
  • County lines
  • Radicalisation and/or extremist behaviour
  • Child-on-child abuse such as sexual violence and sexual harassment
  • Self-harm, suicide, and mental health matters


Additional information about the signs and symptoms of abuse and neglect and how to help prevent and respond to abuse can be found on the NSPCC website. Further guidance can also be found within the Keeping Children Safe in Education (KCSE) 2023 statutory guidance.

KCSE provides guidance on children who are missing from education. At Eden-ts we ensure that all 16–18-year-olds that do not attend a planned teaching session are contacted either in the workplace or at home. Regular non-attendance or concerns are reported to the Safeguarding and Welfare officer.

All Eden-ts employees are made aware of the requirements of the KCSE legislation as part of the Job Ladder induction process. Ongoing CPD supports the process with promotion of the policy with learners and employers being via social media, newsletter, and the review process.

It is not the responsibility of anyone from Eden-ts to decide whether someone has been abused. It is however everyone’s responsibility to report concerns.


The Prevent Duty

“The aim of The Prevent Duty is to stop people from becoming terrorists or supporting terrorism. Prevent also extends to supporting the rehabilitation and disengagement of those already involved in terrorism.” Prevent Duty Guidance 2023.


The main aim of the strategy is to:

  • Respond to the ideological challenge we face from terrorism and aspects of extremism and the threat we face from those who promote these views;
  • Provide practical help to prevent people from being drawn into terrorism and ensure they are given appropriate advice and support;
  • Work with a wide range of sectors (including education, criminal justice, faith, charities, online, and health) where there are risks of radicalisation that we need to deal with.

Nominate the Designated Safeguarding Lead (DSL) as the company Prevent Officer.

Ensure the DSL has the authority in making all decisions regarding referrals to Local Authority Channel Panels.

Eden-ts recognises its responsibility to help prevent the risk of people becoming terrorists or supporting terrorism. The duty helps to ensure that people who are susceptible to radicalisation are supported as they would under safeguarding processes. Eden-ts is committed to supporting vulnerable learners through its safeguarding agenda in order to prevent potential radicalisation.


As part of Eden Training Solutions’ approach to Safeguarding, Equality, and Diversity, and the promotion of fundamental British values, we will:

  • Promote fundamental British values and Citizenship by ensuring that there is a culture of openness within our delivery team and the opportunity for learners to explore what this means to them.
  • Challenge segregation, promoting cohesion and building learner resilience with the aim of our learners and employees contributing actively to wider society.
  • Operate a clear and consistent anti-bullying approach which challenges harassment and discrimination and enables learners and employees to feel safe and supported.
  • Provide support, advice, and guidance for learners and employees who may be at risk of radicalisation. This may include referral to Channel, the process by which multi-agency support is provided to individuals who are at risk of being drawn into terrorism.
  • Ensure that employees, learners, and employers are aware of their roles and responsibilities in preventing radicalisation and extremism.
  • Have a leadership team which actively promotes the core values of shared responsibility and well-being for learners and employees, ensuring that these are at the heart of everything that we do.
  • Produce and monitor a Prevent risk assessment of which the findings will be shared with all Eden-ts colleagues.
  • Through online safety measures, limit exposure to radicalising narratives both online and offline to create an environment where radicalising ideologies are appropriately challenged.
  • Promote a culture of vigilance and operate a whistleblowing procedure which includes reference to the Prevent agenda.

Spotting the signs of Radicalisation

Radicalisation can be difficult to spot. Signs that may indicate a learner is being radicalised include:

  • Isolating themselves from family and friends.
  • Talking as if from a scripted speech.
  • Unwillingness or inability to discuss their views.
  • A sudden disrespectful attitude towards others.
  • Increased levels of anger.
  • Increased secretiveness, especially around internet use.

Learners who are at risk of radicalisation may have low self-esteem or be victims of bullying or discrimination. Extremists might target them and tell them they can be part of something special, later brainwashing them into cutting themselves off from their friends and family.

However, these signs don’t necessarily mean a learner is being radicalised – it may be a sign that something else is wrong.

Prevent Duty Risk Assessment

In line with Eden-ts’ footprint across England, Eden-ts safeguarding team have built relationships with Department for Education Regional Prevent Coordinators to ensure that both national and localised risks are identified. Meaning that Eden-ts receive regular updates relating to radicalisation and extremism. This information is used to raise awareness for staff, learners, and employers through Hot Topics and Newsletters. Affiliations are also established with other advisory agencies such as Educate Against Hate and NSPCC.

The Prevent Duty Risk Assessment will be reviewed yearly and updated as required based on Government guidelines.

Making a Channel Referral

Where an allegation of radicalisation or extremism is reported, Eden-ts DSL will report to the Prevent Coordinator for that region. The Prevent Coordinator will advise on the next steps to take. This may involve reporting any concerns to the local authority, police, and/or Channel Programme to ensure a multi-agency approach is taken. Anyone that is found to be guilty after investigation by the relevant authority will be removed from their programme/employment.

A system of threat level has been created which represents the likelihood of an attack in the near future. The five levels are:

  • Low – an attack is highly unlikely
  • Moderate – an attack is possible but not likely
  • Substantial – an attack is likely
  • Severe – an attack is highly likely
  • Critical – an attack is highly likely in the near future

The current threat level as well as additional information can be found on the Terrorism and National Emergencies website.

Lockdown Procedure

Lockdown procedures should be seen as a sensible and proportionate response to any external or internal incident which has the potential to pose a threat to the safety of employee and/or learners. Procedures should aim to minimise disruption to the learning environment whilst ensuring the safety of all.

Lockdown procedures may be activated in response to any number of situations but some of the more typical might be:

  • An emergency situation outside a building or premises which prevents the safe evacuation of people to a designated rally point.
  • An intruder within a building or premises.
  • A local warning such as air pollution (gas or smoke from a major fire).
  • An internal threat from a known entity.
  • Removing people from a threat.
  • Isolating a dangerous situation away from individuals.
  • Allowing for an accurate accounting of people within each room.
  • Facilitating an organised evacuation away from a dangerous area.

Run Hide and Tell

Released in 2017 by Counter Terrorism Policing, the RUN HIDE TELL campaign was designed to teach people how to keep safe in a gun or knife terror attack.

  • Run – to a place of safety. This is a far better option than to surrender or negotiate. If there’s nowhere to go then
  • Hide – It’s better to hide than to confront. Remember to turn your phone to silent and turn off vibrate. Barricade yourself in if you can. Then finally and only when it’s safe to do so
  • Tell – the police by calling 999.


  • If you can see the attacker they may be able to see you.
  • Cover from view does not mean you are safe. Bullets go through glass, brick, wood, and metal.
  • You must still hide even if you are behind a locked door.
  • Be aware of your exits.
  • Try not to get trapped.
  • Be quiet, silence your phone, and turn off vibrate.
  • If there is an armed police response, follow the officers’ instructions, remain calm, avoid sudden movements, and keep your hands in view.

Implementing Lockdown Procedures

Clear all rooms and corridors.

Ensure all windows and doors are locked.

Close all shutters/blinds and block remaining internal windows with paper.

If appropriate, block doors with furniture.

Turn lights and monitors off.

Prepare a plan of action should an intruder gain entry.

Follow any instructions if an evacuation is initiated by the police or other emergency services.

Stay away from all doors and windows.

Remain quiet, ensuring that all phones are on silent and vibrate is turned off.

Awareness Raising and Promotion to Employees, Learners, and Employers

To safeguard and educate our employees, learners, and employers (and other stakeholders), the following activities are employed as part of the Steps to Success process throughout our programmes:

  • A clear and effective Safeguarding and Prevent Policy is available;
  • A clear induction process for staff – Job Ladder;
  • Promotion of the Safeguarding and Prevent Policy through the Apprenticeship and Employer Onboarding process;
  • Promotion of the Safeguarding and Prevent Policy through the website;
  • Monthly Hot Topics promoted to learners and employers via RoundUp and Social Media;
  • Learning resources attached to learners’ Personal Learning Plan;
  • Promoted via the Learner Review process;
  • Discussed as part of KIT days, OTLA periods, and via standardisation activities;
  • Review, monitor, and update all IT systems and technologies against illegal access and use;
  • Record and track instances of learner and employee absences;
  • Mandatory training for all staff.

Teaching and Learning

We will provide a curriculum that promotes fundamental British values and Citizenship with the view to encourage learners to participate in their local communities and use their voice to make positive changes.

We will take every available opportunity to match curriculum to local priorities whilst offering learners the opportunity to develop critical thinking skills.

We will use topical and relevant examples to stimulate thinking and actively tackle discrimination.

Learners will be encouraged to explore fundamental British values and Citizenship in a safe and supportive environment without fear of discrimination.

Learners are responsible for joining online sessions and should inform their Skills Coach if they are unable to attend.

All learners should dress appropriately for the session.

Use of offensive behaviour, language, or gestures will not be permitted in any instance in either verbal or written form.

All learners on Skills Teacher sessions should treat each other with respect.

Permission to be recorded will be obtained for all recorded sessions. If permission is not obtained by all parties then the session will not be recorded.

Should a learner not feel safe at any point, they will be encouraged to make the Skills Teacher aware or contact

Use and Monitoring of ICT

ICT equipment provided to both employees and learners is subject to monitoring. In addition to monitoring, filters are applied to Eden-ts systems which will restrict access to harmful content. This will be overseen by the Director of Systems.

Staff identifying inappropriate use will report this to the DSO to enable this to be investigated for safeguarding purposes.

We will ensure that there is a shared understanding amongst employees and learners as to the risks posed within the training environment by extremist behaviour by raising awareness through training and information sharing.

Steps will be taken to mitigate the risk posed to employees and learners by individuals vulnerable to radicalisation on a case-by-case basis.

Referrals to Channel will be made on a case-by-case basis and with consideration being made to the need for a multi-agency approach in advance of any referrals.

We will operate a critical incident management plan in dealing with terrorist-related incidents. This will form part of our Disaster Recovery Plan.

We will ensure that there are plans in place which respond to any direct threats within our buildings.

All display materials, including externally produced leaflets and posters, will promote Fundamental British Values and have due consideration to the Equality Act 2020. We will seek to promote this ethos within employer premises.

Eden-ts will only promote its services within organisations that share its values for the need to safeguard, promote equality, and prevent extremist behaviour. Where required, risk assessments will be undertaken to consider the appropriateness of venues before agreements are made to provide information and advice to individuals within that organisation.

The culture of vigilance extends to our external relationships. Where an employer is found to be either in breach of the Equality Act 2020 or advocating extremist views or behaviour, this will be addressed as a Safeguarding issue by the DSO.

Safer Recruitment

Eden-ts is committed to safer recruitment practices. This includes:


  • All adverts include information on Eden-ts’ commitment towards safeguarding and promoting the welfare of children, including an overview of the checks that will be made if successful.
  • Job descriptions include information on safeguarding responsibilities.

Pre-appointment vetting checks and DBS

  • Confirmation in a screener/interview of employment history, noting any breaks, where appropriate.
  • Questions included in all interviews regarding Safeguarding responsibilities and DBS disclosures.
  • Two suitable reference checks.
  • Appropriate level DBS check required for all employees.
  • Right to work in the UK.
  • All employees involved in the recruitment process are required to undertake mandatory Safer Recruitment training.


Mental Health

Mental health is a priority for Eden-ts for all its employees and learners. Support will include speaking to staff and checking on wellbeing in 1-2-1s, reviewing the wellbeing referrals, and raising awareness of mental health issues and reporting processes by providing adequate training and resources.

Resources will be available to signpost staff, learners, and employers to appropriate mental health organisations and referral agencies.


Mental Health Links:


Wellness Recovery Action Plan

Learners and employees are given the opportunity to complete a wellness recovery action plan. This plan can help to develop approaches to supporting mental wellbeing, reducing the likelihood of problems such as work-related stress and sickness. Wellbeing referrals and wellness recovery plans are supported by the Safeguarding and Welfare Officer.


Reporting, Recording and Monitoring a Referral

If a disclosure is made it is important to follow best practice:


Show you care, help them open up

  • Give them your full attention and keep your body language open and encouraging.
  • Be compassionate, be understanding and reassure them their feelings are important.
  • Phrases like “you’ve shown such courage today” help.


Take your time, slow down

  • Respect pauses and don’t interrupt them – let them go at their own pace.
  • Recognise and respond to their body language.
  • And remember that it may take several conversations for them to share what’s happened to them.


Show you understand, reflect back

  • Make it clear you’re interested in what they’re telling you.
  • Reflect back what they’ve said to check your understanding – and use their language to show it’s their experience.

Source: NSPCC: Recognising and Responding to Abuse


Reporting a concern or incident

When reporting a concern, internal employees should report to Eden-ts Designated Safeguarding Lead (DSL), using the safeguarding referral form.

Should a learner be accused of abuse, this should be raised with Eden-ts DSL by the learner’s Skills Coach, where advice and guidance will be provided to support the learner until the outcome of any investigations by the appropriate authorities is known. All reports, internal and external, will be treated in the same way, following Eden-ts safeguarding processes.


Allegations against an employee

Where there is an allegation against an Eden-ts colleague, an investigation may need to be conducted by the DSL, supported by the Head of People Development and Eden-ts Chief Executive Officer. The findings of which, may need to be given to the relevant authorities, such as the police or Safeguarding Children and Adults Partnerships. In certain cases, the Disclosure and Barring Service (DBS) may need to be informed if an employee is found by the relevant authority to have committed a criminal offence. The DBS would be responsible for making any decisions as to whether the employee should be barred from working with children or adults at risk.


Low-level concerns

Eden-ts is committed to promoting an open and transparent culture where safeguarding concerns are taken seriously and addressed quickly. By working together to identify concerning or inappropriate behaviour early, we aim to minimise the risk of abuse. When a member of staff behavior falls short of these standards, it is important that this is addressed in a proportionate and appropriate way. Low-level concerns cover a broad spectrum of actions and can include both intentional and unintentional behavior. By highlighting low-level concerns processes, Eden-ts can support staff in expectations and better safeguard learners, thus reducing risk.

Low-level concerns are any concerns that an adult has acted in a way that:

  • Is inconsistent with Eden-ts code of conduct, including outside of work.
  • Does not meet the threshold of harm that needs to be referred externally.

Low-level concerns include:

  • Behaviors that are considered inappropriate.
  • Inadvertent or thoughtless behavior.

Low-level risk examples include:

  • Being overly friendly.
  • Using inappropriate language.
  • Intimidating or degrading treatment.

To support low-level concern understanding, Eden-ts will:

  • Be clear on what is meant by inappropriate behavior.
  • Identify professional boundaries.
  • Empower the reporting of low-level concerns.
  • Take any reports seriously.

On receiving low-level concerns, Eden-ts will:

  • Ensure that all concerns are managed sensitively and proportionately.
  • Address unprofessional behaviors and support individuals to correct it at an early stage.
  • Identify any training or development that meets both staff and safeguarding needs.

On receipt of a concern, the DSL will assess the situation to establish next steps. All concerns will be logged regardless of whether it is deemed necessary to take action. If action is deemed necessary, the DSL will:

  • Speak to the person who raised the concern.
  • Speak to potential witnesses.
  • Speak to the person whom the low-level concern has been made.

If action is deemed necessary, the DSL will make judgements on the detail to be recorded, which will include:

  • Name and role of whom the concern is being raised.
  • Name and role of the person who is sharing the concern.
  • Brief context of the concern.
  • Detail of the concern, including dates and ensuring detail is accurate.
  • Sign, date and record time of concern being reported.
  • Record outcomes of concerns.



Consent is the capacity for one person to give permission to another and can, at first, feel like an uncomfortable conversation but it is important that all parties are able to talk freely and agree on any decisions without being coerced.

There are many kinds of consent but by being verbally open and able to discuss your feelings and thoughts, any pressure that you might be feeling may be relieved. Laws are in place to protect vulnerable persons regarding the capacity and freedom of consent. It is necessary for a person to always obtain consent and obtain support if needed when it comes to consenting, be this verbally or not. This can help with the reduction of abuse and keeps everyone safe from harm.


Peer on peer abuse (child on child)

All staff are aware that children can abuse other children (often referred to as peer on peer abuse). And that it can happen both inside and outside of work or an education setting and online. It is important that all staff recognise the indicators and signs of peer on peer abuse and know how to identify it and respond to reports.

All staff understand that even if there are no reports in their workplaces or settings, it does not mean it is not happening; it may be the case that it is just not being reported. As such, it is important if staff have any concerns regarding peer on peer abuse they should speak to their designated safeguarding lead (or deputy).

It is essential that all staff understand the importance of challenging inappropriate behaviors between peers, many of which are listed below, that are actually abusive in nature. Downplaying certain behaviors, for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of growing up” or “boys being boys” can lead to a culture of unacceptable behaviors, an unsafe environment for children, and in worst-case scenarios a culture that normalises abuse leading to children accepting it as normal and not coming forward to report it.


Peer on peer abuse is most likely to include, but may not be limited to:

  • Bullying (including cyberbullying, prejudice-based and discriminatory bullying);
  • Abuse in intimate personal relationships between peers;
  • Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse);
  • Sexual violence, such as rape, assault by penetration and sexual assault; (this may include an online element which facilitates, threatens and/or encourages sexual violence);
  • Sexual harassment, such as sexual comments, remarks, jokes, and online sexual harassment, which may be standalone or part of a broader pattern of abuse;
  • Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party;
  • Consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth-produced sexual imagery);
  • Upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress, or alarm; and
  • Initiation/hazing type violence and rituals (this could include activities involving harassment, abuse, or humiliation used as a way of initiating a person into a group and may also include an online element).


Child Criminal Exploitation (CCE)

Child criminal exploitation is complex and takes a variety of forms. In general, child exploitation occurs where an individual or group takes advantage of a power imbalance to coerce, control, manipulate, or deceive a child or young person under the age of 18 into criminal or sexual activity or modern slavery. This can be in exchange for something the victim needs or wants; this is most likely to be the result of grooming, where a criminal has identified what a young person may want or need.

The power imbalance can be through a range of factors, including age, gender, cognitive ability, status, and access to economic or other resources. A young person may also experience poor mental health, have experienced bereavement, or are being bullied which may make them more likely to be vulnerable to exploitation.

The victim may have been exploited even if the activity appears consensual, and exploitation does not always involve physical contact; it can also occur through technology.

CCE activity can include children being coerced into moving drugs or money across the country, forced to shoplift or pickpocket, or to threaten other young people. One of the most common types of CCE activity is called county lines. This involves organised drug dealing networks that exploit children and vulnerable adults to move, hold, and sell drugs across the UK using dedicated phone lines to take orders. Exploitation is a key component of the business model and gangs use children because they are cheaper, more easily controlled, and less likely to get picked up by the police. CCE can result in gang cultures being formed and increased risk of serious violence.

Children can be exploited as ‘runners’ (transporting drugs) but they may also undertake other roles such as cutting and bagging drugs, collecting debts, or experience the ‘cuckooing’ of properties. Cuckooing involves taking over the home of a vulnerable person in a supply area to use it as a base for drug dealing.


Exploitation can affect any child but there are some children who may be at greater risk than others:

  • Children in care – these children may be particularly vulnerable because of the situations and experiences that led them to being brought into care.
  • Children who have been excluded from school or are in alternative provision – young people may feel disenfranchised which can make them an easy target for perpetrators.
  • Children living in poverty – who may be groomed through offers of material possessions or for money for themselves or their family due to financial concerns.
  • Children with educational needs – this may be due to increased vulnerabilities but also due to not recognising exploitation, or not being able to access support.
  • Children who are not UK citizens or do not have immigration status – the precariousness of their immigration status is an additional vulnerability that enables gangs to target them.
  • Family connection – some children have family members who are involved in criminal activity and therefore fall into exploitation through running errands to support their family.
  • Young people not already known to authorities – who may be from affluent backgrounds and not deemed as ‘vulnerable’. These groups often fall under the radar and are less likely to attract attention from authorities.
  • Children with poor mental health and wellbeing – children and young people with poor emotional wellbeing, low esteem, have experienced bereavement, or are being bullied are also more likely to be vulnerable.
  • Children in proximity to an exploiter – children and young people who have none of the above factors but are in proximity to someone who is seeking to exploit children.


Working Safely On-line



Cyberbullying involves the use of electronic communication devices to bully people. These include: mobile phones, tablets, iPods, laptops, and PCs. Social media platforms such as Facebook, Instagram, Twitter, and WhatsApp are used by cyberbullies to put out their communications.

Filters are applied to Eden Training Solutions systems which will restrict access to harmful content. This will be overseen by the Director of Systems.


Who is most at risk?

Children using social media unsupervised and vulnerable adults are particularly at risk if they are using social media, as they may be more emotionally and mentally susceptible to the abuse.


Examples of Cyberbullying

  • Flaming – Online fights usually through emails, instant messaging, or chat rooms where angry and rude comments are exchanged.
  • Denigration – Putting mean online messages through email, instant messaging, chat rooms, or websites set up to make fun of someone.
  • Exclusion – Intentionally leaving someone out of a group such as instant messaging, friend sites, or other online group activities.
  • Outing – Sharing secrets about someone online including private information, pictures, and videos.
  • Impersonation – Tricking someone into revealing personal information then sharing it with others.
  • Harassment – Repeatedly sending malicious messages to someone online.
  • Cyberstalking – Continuously harassing and denigrating including threats of physical harm.



Grooming is a word used to describe people befriending children and vulnerable adults to take advantage of them for sexual preferences. Grooming is also used by extremist groups to radicalise individuals into supporting and potentially committing terrorist attacks.


What is sexual online grooming? Sexual online grooming is when people form relationships with children pretending to be their friend, using social media platforms to do so. The person carrying out the online grooming will try to establish the likelihood of the child telling someone. They will also find out as much as they can about the child’s family and social networks.

Online groomers will tend to use chatrooms, which are focused on young people. There are countless teen chat rooms on the internet. Those carrying out the grooming will pretend to be a child themselves, similar in age to the person they are grooming. They will even change their gender to make it easier to befriend the person they are grooming.

Grooming online is anonymous and children find it easier to trust an online ‘friend’ than someone they have met ‘face to face’.


Online Grooming

How do you know if a child/vulnerable adult is being groomed online?

  • Wanting to spend more and more time on the internet
  • Being secretive about who they are talking to online and what sites they visit
  • Switching screens when you come near the computer
  • Possessing items – electronic devices or phones – you haven’t given them
  • Using sexual language, you wouldn’t expect them to know
  • Becoming emotionally volatile


Roles & Responsibilities

Eden-ts is committed to protecting our learners against all forms of abuse. All employees of the organisation have a responsibility toward our service users to ensure that they are protected from abuse. The Designated Safeguarding Lead has overall responsibility for safeguarding. It is their role to:

  • Act as a source of support, advice, and expertise for all staff on the protection of learners to Eden-ts employees.
  • Receive concerns and referrals on behalf of Eden-ts.
  • Act as a point of contact with safeguarding partners.
  • Help to promote successful outcomes for learners who have social workers by sharing information to help learners to achieve.
  • Report to the Channel programme where there is a radicalisation concern.
  • Identify any training needs within the organisation.
  • Ensure that all employees receive appropriate training and support.
  • Raise awareness by ensuring that all staff have access to and understand Eden-ts policies and procedures.
  • Undergo regular refresher training to ensure up-to-date knowledge as possible with any new guidance.
  • Should a learner (under 18) working in childcare be accused of/involved in a safeguarding incident, Eden-ts DSL will report to/work with Local Authority Designated Officer (LADO).
  • Ensure that Eden-ts has sufficient safer recruitment processes.
  • Report where a person is dismissed or left due to the risk of harm to a child to the Disclosure and Barring Service.
  • Contribute to the ongoing review of this policy and safeguarding procedures.
  • Ensure risk assessments are in place.
  • Retain a central record of all incidents and allegations, including low-level concerns.

The Designated Safeguarding Lead is supported by Eden-ts Chief Executive Officer as well as the Safeguarding and Welfare Officer and a trained team of Designated Safeguarding Officers.


Where it is suspected that a learner is experiencing abuse, experiencing mental health concerns, being drawn into radicalisation, or has any other wellbeing issue, this should be immediately reported via Eden-ts Designated Safeguarding Lead, who will respond by following company processes for recognising, responding, reporting, recording, and referring, where needed. Eden-ts is committed to protecting its learners from abuse and continuously improves its systems, processes, and policies to reflect this.


Eden-ts employees are also responsible for maintaining a culture of concern regarding safeguarding, including:

  • Protecting learners.
  • Being aware of Eden-ts policies, processes, and procedures.
  • Completing appropriate safeguarding training every 12 months.
  • Providing appropriate information and documentation to support the DBS process – staff will not be permitted to have any unsupervised activity with learners prior to the satisfactory return of a DBS check.
  • Being aware of who the DSL and DSOs are as well as the process for reporting any concerns.
  • Having a responsibility to inform the DSO or DSL of any concerns, signs, or allegations of abuse, incidents, or well-being concerns using the Eden-ts referral process.


Involving External Agencies

The Designated Safeguarding Leads are responsible for referring incidents or allegations of abuse to Safeguarding Children and Adults Partnerships, the Care Quality Commission, Ofsted, the Disclosure and Barring Service, and sometimes the police or in cases of radicalisation to the Channel Programme as appropriate. Thus, ensuring a multi-agency approach to the safeguarding.


Employee Training

All Eden-ts employees are required to complete appropriate Safeguarding and Prevent training regardless of their role and responsibilities. New employees take part in a robust induction process which includes the following:


Online Courses:

  • Safeguarding Children Level 2
  • Safeguarding Adults
  • Online Safety
  • The Prevent Duty & British Values
  • Child Protection
  • Child Criminal Exploitation, Gangs & County Lines
  • ACT
  • Prevent Awareness Course


Meeting with the Safeguarding and Welfare Officer to discuss their role and responsibilities as well as reporting processes


Mandatory reading:

  • Policies and procedures
  • Working together to Safeguard Children 2023
  • Keeping children safe in education 2023
  • Home office Prevent Duty guidance
  • TQUK Safeguarding Level 2 Qualification

It is expected that employees will undertake refresher training every 12 months to ensure that they remain up to date regarding safeguarding and the Prevent Duty. In addition to this, the Designated Safeguarding Leads are available to provide advice, support, and guidance as required.

Monthly ‘Hot Topics’ are communicated in the organisation’s newsletter RoundUp which is sent to all employers, learners, and employees. The information included in ‘Hot Topics’ is discussed by Skills Coaches with their learners during their reviews.



The policy will be monitored and reviewed at least annually by the Chief Executive Officer and the Designated Safeguarding Lead, in accordance with changes in legislation and guidance, following any issues or concerns raised regarding safeguarding and or Prevent matters and in all other circumstances.

Eden-ts Chief Executive Officer has overall and final responsibility for this policy, supported by the Designated Safeguarding Lead who will control the implementation and monitoring of the policy throughout the organisation.