Junior Safeguarding Policy

A – Policy Statement

 A1: Context

Britannia Student Services is a student accommodation agency providing a choice of accommodation options for students throughout London. We offer a range of accommodation types, including Halls of Residence, House / Apartment Shares and Homestays for students of all ages

A2: Statement of commitment & Under-18s’ entitlement

We are committed to fostering a warm, friendly, safe and supportive accommodation environment, safeguarding the welfare of all students in our care, regardless of their age, gender, nationality, ethnic origin, religious belief, disability or sexual orientation. We endeavour to create a company ethos whereby a full commitment to the protection and well-being of children and vulnerable adults is vigorously promoted and respected by all our staff and host families. This policy forms the duty of care to which all adults associated with Britannia should adhere at all times.

A3: Adults’ responsibilities

This policy applies to all adults involved with Britannia Student Services, including directly employed staff, homestay hosts, assessors, accommodation staff (where applicable), transport providers and interns. All adults are expected to read and abide by this policy and procedures set out in this document.

A4: Associated policies

  • Junior Safeguard Declaration
  • Junior Guidelines for hosts
  • Guidelines for Juniors

A5: Policy review

This policy will be reviewed annually or as deemed necessary by the designed Child Protection Officer (CPO) and will be agreed by all senior management. When reviewing the policy we may request feedback from relevant schools, agents, students and suppliers

A6: Roles and responsibilities

The responsibilities for the implementation of this policy are as follows:

  • Under-18s: Under-18s are responsible for reading the Guidelines for Juniors document and ensuring that they fully understand its contents, including asking for further explanation where needed. They should also be aware of the wellbeing of their peers and report any concerns to a responsible adult.
  • Adults: All adults working with under-18s are responsible for reading the policy and ensuring that they fully understand its contents, including asking for further explanation where needed. They are also responsible for proactively engaging with its requirements and ensuring that all procedures laid out in the policy are always followed.


B – Code of Conduct

B1: Overview and principles

As part of our commitment to fostering a safe and supportive accommodation environment, we recognise the need to build trust between adults and under-18s. We achieve this by adhering to the following key principles:

  • Being an excellent role model
  • Ensuring appropriate appearance
  • Recognising appropriate boundaries
  • Fostering an environment of trust
  • Being vigilant to under-18s’ needs

B2: Being an excellent role model

When dealing with under-18s, all adults representing Britannia should conduct themselves in a manner suitable to that of an adult caring for a child, even if they are not directly responsible for them. This would include using appropriate language, acting in a socially acceptable manner and adhering to the appropriate boundaries and appearance as detailed in sections B3 & B4. Adults should endeavour to inspire under-18s with their own behaviour.

B3: Appropriate boundaries

All adults are expected to maintain professional physical and relationship boundaries at all times, and act in a manner appropriate to their duty of care.

  • Verbal interaction: Adults should not make suggestive or inappropriate remarks, even in jest. These include sexual innuendo, swearing, discussing sex or intimate relationships, and inflammatory remarks regarding race, religion, gender or sexual orientation. Adults should also avoid shouting or raising their voice and conduct conversations in a calm and friendly manner.
  • Direct communication: When emailing or texting under-18s, ensure that permission has been granted by the child’s parent or guardian in advance, and only discuss professional matters such as booking details. Under no circumstances should adults contact under-18s privately.
  • Grooming behaviours: Adults should be particularly aware of behaviours that could be misconstrued as “grooming”. These behaviours include giving money or presents to under-18s, doing favours, and showing favouritism or acting differently towards particular under-18s. Physical contact should be avoided and should always fall within the guidelines laid out below. Be aware that some cultures may be more sensitive to certain behaviours that you may be comfortable with (for example personal space and use of language).
  • One to one situations: Adults should avoid situations where they are alone with an under-18. If this is unavoidable, consider how this could be managed effectively, for example: leaving a door open, positioning yourself within sight of a door or window, and maintaining an adequate distance between you and the under-18. Note: Homestay hosts may find themselves in situations where they are alone with an under-18 on a more regular basis. Therefore, it is particularly important that they maintain all of the appropriate boundaries in this section at all times, in order to foster a sense of trust with the under-18 which remains even in one-to-one situations.
  • Physical contact: Physical contact should always be avoided except in exceptional circumstances where the under-18s health, safety or wellbeing is at risk. To avoid any actions being misconstrued, adults must always make their intentions clear before taking action, and if possible obtain the under-18’s consent. In addition, wherever possible, ensure that at least one other adult is present before making any physical contact.
  • Socialising: Adults associated with Britannia (with the exception of homestay hosts) must not socialise with under-18s for reason outside of a professional itinerary. Homestay hosts may invite under-18s to participate in family social events, however one-to-one socialising should be avoided as is it could be misinterpreted by the under-18, especially where there is a language barrier.

B4: Appropriate appearance

All adults are expected to present themselves in a manner which promotes a positive and professional image. This should be appropriate to their role and the surrounding environment. Appearance should not be:

  • Revealing or sexually provocative
  • Offensive or likely to cause embarrassment or give rise to misunderstanding
  • Displaying content which may be perceived as being politically contentious or offensive in any way

Adults should be aware that certain cultures may be more conservative with regards to appearance, and should be sympathetic to this. If staff or hosts have any uncertainty in this regard, they are encouraged to contact Britannia’s head office for advice.

B5: An environment of trust

Adults are encouraged to maintain a warm and supportive attitude towards under-18s as well as each other, in order to build trust. Adults should always aim to foster an environment in which under-18s are comfortable raising issues or concerns with adults and feel that they will be listened to and taken seriously.

B6: Being vigilant

An essential part of an adult’s duty of care to under-18s is to be aware of any signs of abuse, as detailed in section D4. It is important to understand that these signs may be extremely subtle, but no matter how insignificant they may seem, adults are advised to report them to the CPO as soon as possible. It is not acceptable to do nothing.

B7: Alcohol, drugs and smoking

It is not acceptable to provide an under-18 with alcohol, cigarettes, illegal drugs or other intoxicating substances under any circumstances. Over-the-counter medication such as Paracetamol may be given if needed, as long as consent has been provided by the parents or guardian, and within the guidelines of the medication. Adults should never consume illegal substances, and should avoid consumption of alcohol and cigarettes in the presence of under-18s wherever possible. Adults directly in care of under-18s (eg. hosts or group leaders) must not be intoxicated at any time.

B8: IT and social networks

Adults working with under-18s must not give them their personal email addresses or social media details, and may not add or follow them on Facebook, Twitter, Instagram or any other social media platform. Adults may email or contact under-18s on their personal email addresses or phone numbers using company addresses or phones, but only in relation to business matters. Correspondence by text message should be avoided unless it is the only suitable contact option. Language in any correspondence should always remain professional and should never include any emotive statements or icons.
If under-18s will be accessing the internet on devices owned by hosts / staff, we would advise that this is supervised wherever possible. We would also recommend a guest log-in is created for the under-18’s use, with restricted permissions for adult content.
Adults may not take photographs or videos of under-18s on personal recording equipment (including smartphones), nor may they request copies of photographs or videos taken by under-18s on their own recording devices.

B9: Transport

Transport companies are expected to provide written confirmation that all drivers have been DBS checked at least once annually. Under-18s travelling in groups should be organised so that there is at least one adult group leader or representative present in each vehicle, in addition to the driver. For under-18s travelling alone, the transport company must provide Britannia with the driver’s full name and telephone number in advance, along with confirmation of their last DBS check.
When collecting under-18s in the absence of an appointed representative, the driver will be issued with a confirmation, which includes the under-18’s unique Britannia ID number. Before releasing an under-18 into the driver’s care, the responsible adult is expected to match the ID number from the driver’s confirmation with the student’s confirmation. The driver’s ID details should also be taken as a precaution. After reaching the destination, the driver is expected to accompany the under-18(s) until they can be handed over to the responsible adult who will be taking care of them from this point. This could include:

  • A homestay host: In this case the driver should ask to see the host’s booking confirmation, and match the unique Britannia ID with the one on their transfer confirmation. They should also ask the host to produce their ID.
  • A member of check-in staff at an airport terminal: In this case the driver would be expected to wait until the under-18 has been checked-in by the appropriate airline.

C – Accommodation

C1: Overview

As an accommodation agency, ensuring the safety of under-18s in and around our accommodation forms a key part of our Junior Safeguard Policy. Our responsibility is to ensure the safety and wellbeing of under-18s at all times whilst within the accommodation or when accompanied by the homestay host / Britannia appointed representative.

C2: Types of accommodation for under-18s

Individual under-18s will only be accommodated in specially selected homestays, however certain groups of under-18s may be accommodated in trusted hostels / halls of residence, provided that they are under the supervision of the appropriate number of group leaders (as detailed in section F2).

C3: Requirements for under-18 accommodation

In addition to our normal criteria, accommodation for under-18s must meet the following additional criteria:

  • Homestays:
    • The main caregiver will be DBS checked by Britannia, or hold an existing DBS disclosure dated within the last 2 years.
    • The main caregiver will sign a Junior Safeguard Declaration on behalf of all adult members of the household, declaring they have no prior criminal background.
    • Accommodation will always include at least breakfast and an evening meal. If lunch is not provided by the host, it should be arranged by the school or agent handling the booking.
    • Britannia will provide hosts with curfew times in advance, and hosts will be responsible for implementing them. Curfews will be provided by the organisation responsible for the under-18, and should be age-appropriate. Curfews may be amended by Britannia’s CPO if they feel that it is in the best interest of the child in question.
    • The main caregiver will always be present overnight, and children under 16 years of age will be accompanied by a responsible adult at all times while at home.
    • All under-18s should be provided with a 24-hour contact person outside of the accommodation, who should be acquainted with the under-18 and establish themselves as person of trust.
    • In addition to the above, Britannia will provide their own 24-hour contact number to the under-18 (and their parents where possible).
    • Homestay hosts will not accommodate adult guests at the same time as under-18s.


  • Hostels / Halls of Residence:
    • Under-18s would only be placed in a hostel or hall of residence when travelling in groups.
    • Under-18s will be arranged in the accommodation so that the ratio of responsible adults to children (as per section F2) is maintained.
    • Under-18s will always be kept separate from adult guests, with the exception of those directly responsible for the group.
    • The group organisers are responsible for ensuring that meals are arranged for under-18s staying in these types of accommodation. Britannia can arrange meal packs if requested.
    • The group organisers are responsible implementing age-appropriate curfews.
    • All under-18s should be provided with a 24-hour contact person outside of the accommodation, who should be acquainted with the under-18 and establish themselves as person of trust.
    • In addition to the above, Britannia will provide their own 24-hour contact number to the under-18, their group organisers, and their parents where possible.

C4: Accommodation staff / Homestay hosts

All accommodation staff and homestay hosts involved with the care of under-18s are expected to know and follow the guidelines set out in this Safeguarding Policy document, with particular attention to the Code of Conduct (Section B) and Child Protection guidelines (Section D). Staff and hosts should be prepared to undergo appropriate suitability checks, such as the Disclosure and Barring Service (DBS) check. In the interests of child safety, Britannia operates a zero-tolerance policy with regard to junior safeguarding and any failure to uphold these principles will result in the immediate removal of responsibility for under-18s.

C5: Safer recruitment & training for homestay hosts

In addition to our normal recruitment criteria, homestay hosts applying to accommodate under-18s must undergo the following additional processing:

  • DBS and declaration: The main caregiver will be required to sign the Junior Safeguard Declaration (as discussed in Section C3), as well as undertaking an enhanced DBS check, prior to accepting under-18s.
  • Proof of Identity: Hosts will be required to provide suitable proof of their identity.
  • Junior host selection: Hosts requesting to accommodate under-18s must have previously hosted adult students booked through Britannia for at least 6 weeks with good feedback. These hosts will be assessed for suitability by the CPO before being approved for under-18 guests. This assessment will look for levels of care above and beyond those normally required for adult students.
  • Area risk assessment: Under-18s are only accommodated in specifically approved areas in London, which meet our requirements for safety and suitability. In addition, the location surrounding each host within an area will be risk-assessed prior to placing any under-18s there. The main focus of area risk assessment is as follows:
  • Is the walk to and from the local station safe?
  • Is there adequate street lighting?
  • Are the surrounding buildings residential, occupied and of a suitable standard of repair?
  • Are there any specific areas of concern (eg., industrial estates, cemeteries, drinking establishments, etc.), and how will these risks be managed?
  • Character reference: Hosts will be expected to provide at least one character reference, preferably from a professional with good personal knowledge of the host. If possible, hosts should also provide any records of feedback from previous guests.
  • Training: Hosts will be provided with the Junior Guidelines document, as well as this Junior Safeguarding Policy. Q&A sessions will be conducted at every assessment to ensure that hosts fully understand their responsibilities, and will be encouraged to call head office with any further questions.
  • Assessments: Hosts accommodating juniors will be reassessed annually as opposed to the normal bi-annual assessment of regular homestay hosts.

D – Child Protection

D1: Overview

Child protection is at the heart of Britannia’s Junior Safeguard Policy, and is upheld in the following ways:

  • Creation: Policies are created in accordance with guidelines from official bodies such as ChildSafe and the British Council, alongside our own experience. Policies are created by the CPO and agreed by all senior management.
  • Review: Policies are reviewed annually, as stated in Section A5.
  • Training: All staff involved with under-18s will be given a minimum of Basic Awareness Training (Level 1 Safeguarding), and will be expected to read and understand the Junior Safeguard Policy in full. Designated CPOs will be trained to Level 3 Safeguarding and at least one of these CPOs will be available to offer guidance to other staff at any time.

D2: Nominated / Designated person

Britannia will appoint two Designated Safeguarding Leads, called Child Protection Officers (CPOs). CPOs will be trained to Level 3 Safeguarding standard, and at least one of these will be available at all times.
Britannia’s current CPOs are:

  • Rita Fedon (Deputy Operations Manager) Email: rita@britanniastudents.com;
  • Rob Grant (Project Manager) Email: rob@britanniastudents.com;

During office hours the CPO can be contacted on +44 (0)20 7436 7738, and out of office hours on +44 (0)7866 723 789.

D3: Learning of a concern, and how to respond

The common methods by which concerns can be raised include the following:

  • An under-18 discloses that they are concerned about another under-18
  • An under-18 discloses an issue which concerns themselves
  • A person outside the company reports a potential issue regarding an under-18
  • An under-18 or adult witness behaviour by another adult which raises concern
  • An adult recognises non-verbal indications of safeguarding concerns from an under-18 (as referred to in Section D4)

In the event of any concerns being raised:

  • If applicable, follow the guidelines outlined in Section D5 (a child telling an adult).
  • Contact the CPO as soon as possible and explain the concerns in detail
  • The CPO will then advise of the next steps

It is important to follow-up on any situation, even after handing it over to the CPO, and adults should be satisfied that progress is being made in the matter. Should there be any concerns over the manner in which the CPO is handling the case, the following actions can be taken to escalate the matter:

  • Report concerns to the second CPO
  • Report concerns to the company directors (in accordance with the company’s whistle-blowing policy outlined in the Employee Handbook)
  • Report concerns to the Local Authority Designated Officer (LADO): Jane Foster (Safeguarding in Employment Manager), Westminster City Council.

Tel:  +44 (0)20 7641 6108,
Email: jfoster1@westminster.gov.uk.
In Jane’s absence contact: Hillary Shaw (Tri-Borough Safeguarding in Schools and Education Officer) Tel: +44 (0)7817 365 519.

D4: Recognising symptoms of abuse

Abuse is defined as: “any action that intentionally harms or injures another person”. Legally, abuse falls into four main categories: Physical, Emotional, Neglect and Sexual (PENS).
Some of the signs of abuse are included in the following table, however this information is by no means exhaustive and adults should be vigilant for any behaviour which raises concern.

Physical Abuse
Hitting; shaking; throwing; poisoning; burning / scalding; drowning; suffocation or otherwise causing physical harm.
Unexplained injuries / burns; refusal to discuss injuries; improbable explanations for injuries; untreated injuries or lingering illness; shrinking from physical contact; fear of returning home, undressing or medical help; aggression / bullying; over-compliant behaviour or “watchful” attitude; running away; changes in behaviour without explanation.
Emotional Abuse
Persistent emotional ill-treatment so as to cause severe and adverse effects on a child’s emotional development.
Lack of confidence; child complaining of feeling worthless, inadequate or unloved; suicidal statements; difficulty controlling emotions or outbursts; anxiousness; depression; problems sleeping or eating or changes in regular behaviour; nightmares; self-harm, drugs or alcohol.
Persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of the child’s health or wellbeing. Failure to provide adequate food, clothing or shelter or protect the child from harm.
Constant hunger; poor personal hygiene; inappropriate clothing; low self-esteem; poor social relationships; compulsive stealing or scrounging; frequent lateness or non-attendance of classes; untreated medical problems; constant tiredness.
Sexual Abuse
Involves forcing or enticing a child to take part in sexual activities, including prostitution, whether or not the child is aware or complicit in what is happening. This may involve: physical contact (including penetrative acts); non-penetrative acts such as looking at / producing pornographic material; watching sexual activity; encouraging children to behave in sexually inappropriate ways.
Bruises, scratches, burns or bite marks on the body; sexual awareness inappropriate to the child’s age; frequent public masturbation; attempts to teach other children about sexual activity; refusal to stay with a certain person or go to certain places; aggressiveness, anger, anxiety, tearfulness and withdrawal from friends; promiscuity or provocative sexual behaviour; self-injury or self-destructive behaviour or suicide attempts; unexplained gifts or money.


D5: Sources of abuse

Abuse commonly occurs within a relationship of trust or responsibility. This could include friends, neighbours, family or household members, teachers, group leaders or other people in a position of trust and/or access. Abusers can be male or female and can include other young people.

D6: (FGM) Female genital mutilation

FGM is a form of harmful child abuse and is not a question of individual preference; it is an illegal practice and therefore should be taken extremely seriously. In the case of alleged or known FGM on a child (u-18 student), the following actions should be taken to escalate the matter:

  • Report concerns to the police via the 101 non-emergency number
  • Report concerns to the LADO to seek further guidance, as well as the Britannia CPO

D7: An under-18 telling an adult (handling disclosures)

A child who is aware of abuse or is being abused will find it extremely difficult to come forward to an adult, and may fear that no one will believe them. Therefore, it is important to ensure that their concern is taken seriously and made a priority. If an under-18 asks to talk, this should be prioritised over any other matter. If a child is not given the chance to come forward with a disclosure, they may not have another opportunity or may lose the courage to do so.
When handling a disclosure, the following guidelines should be observed:

  • Just listen: A disclosure is not an investigation. The adult should simply listen and take note of what is being said. It is important to remain calm and to accept what is being said without judgement. It is not up to the adult receiving the disclosure to determine the truth.
  • Reassure: The child should be reassured that it was right to come forward, and that what they have said has been taken seriously. Acknowledge how difficult it must have been for them to come forward.
  • No Leading Questions: These must be avoided at all costs. (For example: “So what you’re saying is…”; “Does that mean that….?” Or “Did they do/say xxx…?”) It is however acceptable to repeat the child’s own words back to them for clarification, or to ask open questions (for example: “Is there anything else you would like to tell me?”). Do not assume anything, speculate or jump to conclusions.
  • No Secrets: The adult should never promise to keep secrets during a disclosure, and should make it clear to the child that they will need to inform the CPO in order to help. However the child can be reassured that the matter will only be shared with people whose job it is to protect children, and will not be made public knowledge.
  • Taking notes: The adult should not take notes whilst the child is making the disclosure, however they should write an account immediately afterwards. This should be as close to verbatim as possible, making use of the child’s exact words. As this could form part of a legal process, paraphrasing or editing should be avoided. Do not destroy original notes as may be needed in court.
  • Date and circumstances: In addition to the account, the adult should make a note of the date and time of the disclosure, along with a description of the circumstances of how it came about, including how the child appeared.
  • Use body map if appropriate: If recording physical abuse, the adult should use a body map to indicate the location of marks, including the colour and nature.
  • Escalate to CPO: The adult must report all of the above to the CPO as soon as possible. The CPO may request further details in writing.
  • Confidentiality: It is important to keep details of disclosures confidential and share them only with the CPO. If notes are taken, ensure they are kept securely as outlined in Section D6.

D8: Keeping records

Britannia will ensure that all concerns communicated to the CPO will be acknowledged within the same working day. Further action will be taken as necessary within one working day, however urgent matters will be handled immediately.
Records kept will include details of disclosures, all subsequent action taken and decisions made. They will also include details and correspondence of any parties informed. Any allegations which are later found to be false will be clearly marked as such.
Any records regarding child safety will be held securely on the head office server, in a password-protected folder accessible only by the CPOs. Access may be granted to outside agencies where appropriate. Records are kept indefinitely, but will be updated as appropriate to show the most recent information.

D9: If an adult is accused

In the event of an adult being accused of abuse or inappropriate behaviour, the CPO is responsible for the following procedure:

  • Establish the identity of the accused beyond reasonable doubt, and their relationship to both the accuser and Britannia.
  • Make contact with the LADO to seek further guidance, as well as contacting any other external organisations as appropriate.
  • If the accused is directly involved with Britannia (eg. a homestay host or member of staff), suspend them from current duties and ban them from all contact with the accuser, pending an investigation. This may include relocating the under-18 if the accused shares the same accommodation.
  • If the accused is not directly involved with Britannia (eg. a group leader or teacher), inform their CPO, or contact an external organisation (eg. social services, police etc.). Wherever possible, contact should be minimised between the accused and accuser.
  • Support the LADO and any external organisations involved in conducting a thorough investigation.
  • Clearly inform all relevant parties of the outcome of the investigation, and of any consequential actions taken as a result.
  • Ensure that all records of the investigation are up-to-date and held securely in accordance with procedures in Section D6 (keeping records).

D10: If a child is accused

In the event of a child (u-18 student) being accused of abuse or inappropriate behaviour, the CPO is responsible for the following procedure:

  • Establish the identity of the accused beyond reasonable doubt, and their relationship to both the accuser and Britannia.
  • Make contact with the LADO to seek further guidance, as well as contacting any other external organisations as appropriate.
  • If the accused is directly involved with Britannia (eg. a student placed in a homestay or residence), ban them from all contact with the accuser and relocate the child if the accuser shares the same accommodation.
  • If the accused is not directly involved with Britannia (eg. a friend of a student), inform their CPO, or contact an external organisation (eg. social services, police etc.). Wherever possible, contact should be minimised between the accused and the accuser.
  • Support the LADO and any external organisations involved in conducting a thorough investigation.
  • Clearly inform all relevant parties of the outcome of the investigation, and of any consequential actions taken as a result.
  • Ensure that all records of the investigation are up-to-date and held securely in accordance with procedures in Section D6 (keeping records).

E – Safer Recruitment & Training

E1:  Overview

As part of Britannia’s commitment to the protection and wellbeing of under-18s, all adults involved with Britannia undergo a thorough process of suitability checking as appropriate to their role and involvement with under-18s. This includes office and residence staff, homestay hosts and external service suppliers (eg. transfer companies and cleaners). This is achieved through documentation-checking, and the interview and referencing process.

E2: Recruitment materials

All job descriptions contain a statement notifying applicants that they may be required to undergo an enhanced DBS check, depending on their level of contact and responsibility. Applicants may also be required to attend Basic Awareness Safeguarding (Level 1) training or higher, as appropriate. They will also be required to know and uphold the company Junior Safeguarding Policy, which is available on the company website and will be provided to successful applicants along with their offer of employment.

E3: Recruitment stages

During the interview process, applicants are informed about the company’s junior safeguarding policy, as well as their responsibility to the safety and wellbeing of under-18s. They will be asked about their attitude to working with under-18s and for any previous examples of their involvement with child safety.  The recruitment process will include thorough checking of references, and any gaps in CVs will need to be explained satisfactorily by the applicant.
Homestay hosts electing to accommodate under-18s will be subjected to additional checks as detailed in Section C5, over and above Britannia’s normal host recruitment application process. During the assessment process, the additional responsibility for hosting under-18s will be discussed in detail with the host and their attitude to child safeguarding forms an important part of the final decision of whether or not to accept them as a junior host.

E4: Information for Applicants

Any applicants for roles involving responsibility for or substantial access to under 18s will be informed of the following either prior to, or at interview stage:

  • All references will be followed up, and Britannia reserves the right to ask for further references if required. Referees will be asked specifically whether there is any reason why the applicant should not be placed in situations where they have responsibility for or access to under-18s.
  • Any gaps in CVs will need to be explained adequately by the applicant
  • The applicant will be required to provide proof of identity as well as proof of qualifications where applicable
  • Appropriate suitability checks (including DBS checking) will be required prior to appointment.

E5: Applicants awaiting DBS

Britannia operates a no-exceptions policy with regards to suitability checking, applicants will not be allowed access to under-18s until DBS checks have been completed and returned. This would mainly concern homestay hosts but would also apply to office or residence staff if working directly with bookings relating to under-18s.

E6: Applicants with a criminal record

Although an applicant with a criminal record is not automatically considered to be unsuitable for work with under-18s, the safety and wellbeing of children is always the overriding concern when assessing their suitability. The CPO(s) and company directors will be responsible for the joint suitability assessment of applicants with a criminal record, and may seek guidance from the LADO as appropriate. Assessments will focus on the following categories, although these are guidelines only and each applicant would be assessed on an individual basis:

  • Nature and seriousness of offence(s): Serious convictions for sexual, violent or drug offences would be examples of strong indicators of unsuitability for work with under-18s.
  • Nature of appointment: The convictions should be compared to the role applied for, and assessed on this basis. For example, driving or drinking offences would be relevant for roles involving the transportation of under-18s.
  • Age of offence(s): Convictions which occurred many years previously would not hold as much relevance as those that occurred recently, although this would apply less for serious convictions, especially those of a sexual or violent nature. An example could be an isolated dishonesty or traffic offence which occurred when the applicant was young.
  • Frequency of offence(s): A series of offences over time would be a much stronger indicator of unsuitability than a single isolated incident.

The disclosure will also be discussed with the applicant in order to obtain a full picture of the circumstances surrounding the conviction(s), and judgement will be withheld until all possible information regarding the offence(s) has been gathered.

E7: Training – Responsibility

Britannia will ensure that all CPOs are trained to Level 3 Safeguarding standard. The CPOs are responsible for ensuring that all adults with responsibility for or access to under-18s are trained appropriately.

E8: How training is delivered

Office and residence staff will receive appropriate Level 1 Safeguarding training from the CPO, as well as being expected to read and understand the Junior Safeguarding Policy. Refresher training will be carried out annually or as needed. Homestay hosts will be given copies of the Junior Safeguarding policy as well as the Junior Guidelines document for homestay hosts. Q&A sessions will be held at each assessment to ensure that hosts completely understand their responsibilities. Refresher Q&A sessions will be held at each assessment (conducted annually) and hosts will be given an up-to-date copy of the Junior Safeguarding Policy.

F – Welfare / Implementing Safeguarding

F1: Use of risk assessments

Risk assessments are used in the following areas in order to minimise the risk of harm to under-18s:

  • Host area risk assessment: As detailed in section C5, all homestay hosts applying to accommodate under-18s must undergo an area risk assessment, which is carried out by a trained accommodation assessor. The risk assessment follows a standard questionnaire form and is reviewed by the CPO prior to accepting the host for under-18 bookings. Specific risks will be identified and strategies for their management devised as appropriate. The relevant information will then be passed to the host and added to the host profile. (For example: under-18s must not use the short cut through the park after dark)
  • Criminal record risk assessment: As detailed in section E6, any applicants with disclosures from their DBS check will undergo a risk assessment process to determine whether they will be suitable for roles with access to or responsibility for under-18s. The risk assessment will be carried out by the CPOs and company directors, in consultation with the LADO where appropriate. As each assessment will be unique, there is no standard assessment form, however detailed records of the assessment process and final decisions will be kept on the applicant’s personnel file, if they are subsequently accepted. Homestay hosts with disclosures from their DBS check will not be allowed to accommodate under-18s.

F2: Supervision ratios

When accepting groups of under-18s into our accommodation, Britannia requires minimum supervision ratios as follows:

  • Homestay accommodation: 1 responsible adult per 15 children over 12 years of age; 1 responsible adult per 8 children aged 12 or under.
  • Residential accommodation: 1 responsible adult per 20 children over 12 years of age; 1 responsible adult per 15 children aged 12 or under.

The organisation of these groups will be the responsibility of the agent or school who makes the booking, however we require confirmation of the supervision ratio before confirming the booking, and full details of the group leaders (including their contact details) before the booking commences. Bookings with insufficient supervision ratios will be cancelled unless this is rectified prior to the arrival date.

F3: Missing students

Homestay hosts accepting under-18’s are expected to actively enforce the curfews given to them for each booking. Should an under-18 fail to return to the host by the agreed curfew time, the following procedure must be initiated:

  • If the under-18 is part of a group, the host should contact the group leader to find out if the group has been delayed. If the group leader is not contactable, they should call Britannia’s emergency number. In the case of an individual booking, the host should contact Britannia’s emergency number to report the under-18 as missing.
  • The emergency phone operator will attempt to contact:
    1. The under-18 directly (where possible)
    2. The group leader (if applicable)
    3. The school or organisation responsible for the under-18
    4. The appointed guardian for the under-18 (if separate to c).

The operator will attempt to establish where the under-18 is, why they have been delayed and what time they will be expected to return home. The operator will then relay this information back to the homestay host.

  • If the under-18’s whereabouts are still unknown after following the steps above, the CPO should be contacted for further guidance. Normally the CPO will advise moving to stage 4 below:
  • The police should be contacted and the under-18 reported as missing. They must be given full details about the child, information about their expected route home, and any other details as requested. If this step has been reached, it is important that the school or organisation responsible for the under-18, as well as their guardian, be made aware of the situation as soon as possible. The parents of the under-18 should also be contacted.
  • All parties involved should coordinate fully with the police as directed to ensure the location of the under-18 as quickly as possible.

In the case of an under-18 being reported as missing during the course of their daily activities with the school or organisation responsible for them, Britannia will provide full co-operation with the organisation as necessary to ensure the location of the child as soon as possible.

F4: Preventing radicalisation and extremism

Extremism promotes actions of violence, separation and intolerance of others, by integrating fact with subjective opinion to evoke fear from lack of understanding of others ideas, views and beliefs. Forms of extremism can include extreme views on subjects such as homosexuality and animal welfare, and far right and religious extremism. People of any age, gender or cultural background can be exposed to radicalisation or extremism, and signs can include (but are not limited to):

  • Changing attitude or behaviour e.g. isolating themselves or sudden narrow-mindedness toward others
  • Failing standard of studies and work
  • Forcefully imposing beliefs/opinions onto others
  • Justifying opinions that mirror ideological extremist views and/or talking about extremist material
  • Evidence of access to online extremist material

Any student hosted by a host family that displays the above or relatable signs, should contact the Britannia CPO immediately, who will then contact the students’ place of study, LADO and any other relevant parties.
The following steps can be taken to help prevent radicalisation and extremism:

  • Promote a safe and supportive home environment, tolerant of different cultures and backgrounds
  • Show sensitivity to international affairs
  • Ensure a concise code of conduct for acceptable/non-acceptable in a fair and friendly manner
  • Impose suitable access filters for the internet

F5: Welfare provision

Britannia implements a wide range of provisions to ensure the safety and welfare of under-18s in the company’s care. These are defined as follows:

  • CPOs: Britannia appoints at least two CPOs in order to ensure that at least one is contactable at any time. CPOs are trained to Level 3 Safeguarding standard and are responsible for the creation and review of the company’s Junior Safeguarding Policy. CPOs are also responsible for the training of other staff.
  • 24-Hour Emergency Contact Number: Britannia operates a 24-hour emergency contact number which is given to all under-18s, schools, agents and any other relevant parties. The CPOs are also contactable at all times.
  • Junior Homestay Hosts: Homestay hosts undergo additional processing before being allowed to accommodate under-18s. They are selected particularly for their care and attention to children.
  • Junior Safeguarding Policy: Britannia has a detailed Junior Safeguard Policy which is reviewed regularly by the CPOs. All staff and homestay hosts are expected to read, fully understand and adhere to its contents.
  • Junior Safeguarding Training: All staff are trained to Level 1 Safeguarding standard, with refresher training annually or as required. CPOs are trained to Level 3 Safeguarding standard.
  • Safe Recruitment Procedures: All staff and homestay hosts are recruited specifically with child welfare in mind, as detailed in Section E. Recruitment includes reference and DBS checking prior to appointment.
  • Junior Guidelines: Specific guidelines documents are given to homestay hosts accommodating under-18s, as well as under-18s themselves, which detail measures which enhance the safety and wellbeing of under-18s.
  • Risk assessment: Risk assessments are carried out in the areas covered under Section F1.
  • Transport: Additional safeguards are put in place for transporting under-18s, as detailed in Section B9.

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