Prevention of harm: by creating and maintaining a positive school atmosphere with excellent pastoral support, stimulating teaching of a varied curriculum including co-curricular activities and vigilance by all staff and particularly within the boarding environment.
We recognise that high self-esteem, self-confidence, supportive friends and a clear line of communication with a trusted adult help all children, especially those who may be worried or anxious. St Mary's, therefore, has a listening culture and promotes an ethos where pupils are valued, feel secure and are encouraged to talk and are listened to.
Self-respect and respect for others are Behaviour Principles embodied in the Pupil Behaviour Policy and the Anti-Bullying Policy and are constantly reinforced during daily school life and in Chapel, House meetings and Tutor time.
The pastoral care of the pupils is of the utmost importance and all staff share in this responsibility. The House structure ensures that every pupil is carefully monitored; the Heads of House are the primary members of staff responsible for the pastoral care and wellbeing of their pupils alongside the Pastoral Deputy Head and the Head of Boarding. Every pupil also has a tutor throughout her time at St Mary's and the Heads of House work closely with the tutors and the boarding staff. Teaching and boarding staff are trained to be vigilant and refer all matters of concern including e-safety to the tutor and/or Head of House either in person or through CPOMS (Child Protection Online Management System) online reporting software, or by using the electronic boarding logs, or the flags on the St Mary’s App (SMAPP) for lower-level and e-safety concerns. The School proactively uses Steer Tracking to help to identify pupils who may be particularly vulnerable to mental health or safeguarding risks in order to put in place preventative measures.
Pupils are also made aware of how to keep themselves as safe as possible and how to regulate their own behaviour, as well as how to recognise and report unacceptable behaviour from other children and adults. This includes educating pupils about online safety, through regular internal and externally provided ICT safety talks, about the safe use of electronic equipment and access to the Internet. The Pastoral Deputy Head works closely with the Director of Network Services to endure that the school’s internet filtering and monitoring systems support safe use of the internet. The School is in frequent contact with parents including about online safety and provides professional training specifically for parents from external providers about how parents can help to keep their children safe online outside of the school environment and at home.
Smartphones with access to the internet and e-mail must be registered on the school network and must be used in accordance with the ICT Acceptable Use Policy. Pupils are not permitted to have a second phone in school whether declared or secretly. Parents are advised that if they provide their daughter with a 3G, 4G or 5G enabled phone, internet access is not subject to the School’s filtering and monitoring systems. All such phones with internet access must have a parental control app such as Qustodio enabled in order to monitor online activity and screen time, to restrict access and limit screen time at night in accordance with the specific age-appropriate guidance issued by the School.
The Relationships and Sex Education programme is a cross-curricular scheme described in the Relationships and Sex Education Policy which is taught throughout the age range. It is part of the PSHE education programme delivered during skills for life and other lessons and activities and is informed by the DfE Statutory Guidance RSE and Health Education July 2019. It covers healthy and respectful relationships and includes helping pupils to understand the meaning of consent and to recognise that widely encountered everyday sexist stereotypes and sexist language are unacceptable and can promote sexual harassment and/or abuse and abusive relationships. The PSHE programme includes body confidence and self-esteem, prejudice, discrimination, equality, and diversity. Pupils are regularly reminded how to report concerns and incidents which occur both in and out of school, including online, and the support that they will be offered if an incident is reported.
Protection from harm: by following agreed procedures as laid down by Windsor and Maidenhead Local Safeguarding Partners, and by ensuring that appropriate staff are properly recruited and trained to respond sensitively and appropriately to safeguarding concerns. This includes the protection of pupils from the risk of radicalisation in accordance with the DfE Statutory Prevent Duty Guidance.
St Mary’s E-Safety Policy and ICT Acceptable Use Policies promote online safety. The ICT Steering Committee, ICT Working Party and Cyber and Technology Council conduct frequent and close reviews of operating procedures and policies and recommend and implement changes as required. Pupils review the ICT AUP with their tutor at the start of each academic year and sign that they agree to comply with it.
Online risks include: harmful content such as pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism; unreliable contacts such as adults posing as children with the intent to groom or exploit; ill-judged conduct such as sharing explicit images and online bullying; and ecommerce such as inappropriate advertising, gambling and scams. It is the responsibility of staff, with the support of the E-safety Committee, to regularly review the security protection of the school network, to implement suitable and proportionate filters, to monitor age appropriate use of technology, to educate pupils in the safe and sensible use of technology, to be vigilant about the opportunity to download harmful content via 3,4 and 5G that will bypass the school’s filtering and monitoring systems, as well as to regulate pupils’ use of technology. This is informed by the DfE Guidance Teaching Online Safety in Schools, June 2019 and Meeting Digital and Technology Standards in Schools and Colleges March 2023.
The boarding areas are clearly signed and only boarding staff are routinely permitted in the boarding areas. Access for non-boarding staff to the boarding areas follows a strict protocol which can be found in the Code of Conduct, on staff notice boards and it also forms part of the induction for new members of staff. Whenever a non-boarding member of staff is in the boarding area, appropriate steps are taken to protect pupils' privacy and safety. Parents and families of pupils are allowed in the boarding areas only when they are dropping off and collecting pupils at the start and end of term and then only up until 8.00 pm.
All visitors to the site are requested to go to reception and register, as detailed in the Safety, Security and Access Policy. Reception staff receive tailored training in safeguarding. All visitors must wear a badge, be accompanied at all times and are given a leaflet with safeguarding information.
Support: by giving appropriate support to pupils and staff if incidents concerning safeguarding issues occur.
It is important to differentiate between safeguarding children who have suffered or are likely to suffer significant harm where cases should be reported to the Windsor and Maidenhead Local Safeguarding Partners immediately and those who are in need of additional support from one or more agencies. The latter could include cases of self-harm or eating disorders and should lead to multi-agency assessment using local processes, including the use of the “Common Assessment Framework (CAF)” and “Team around the Child (TAC)” approaches. St Mary’s will provide as much information as possible to allow any social care assessment to consider all the available evidence in order to enable a contextual approach to addressing the harm.
Early intervention is of paramount importance to prevent a problem from escalating and staff should take any concern, however small, immediately to the DSL, or any other senior member of staff, to ensure that it can be addressed and appropriate action taken and support given as necessary. The best interests of the pupil are at the heart of all safeguarding processes and the pupil’s wishes and feelings are sought and taken into account when determining what action to take. Pupils from groups at greater risk of targeting, such as those who are from different ethnic backgrounds, or identify as lesbian, gay, bisexual or gender-questioning, or are perceived as such have an increased vulnerability to abuse and may be less likely to report incidents or concerns. Staff must be particularly alert to the potential need for early help for a pupil who has any particular vulnerability and also be vigilant to possible peer group isolation or bullying of them. Vulnerabilities also include special educational needs, physical disabilities, special medical or health conditions, mental health concerns or conditions, challenging family or social circumstances, persistent absences from school, repeated suspensions, or personal issues. Staff are trained to be able to respond to pupils about a range of concerns including lesbian, gay, bi-sexual or gender-questioning issues in order to create a safe space for pupils to raise their concerns. The School works closely with its local safeguarding partners to establish what sort of early help may be appropriate.
The DSL is the Mental Health Lead in School and has undertaken relevant training to promote wellbeing and mental health. The Wellbeing Coordinator supports the DSL and Pastoral Deputy Head in the promotion of good mental health and wellbeing of pupils. They deliver pupil workshops on positive mental health and wellbeing, staff training on mental health and wellbeing support for pupils, and actively support good mental health for pupils through planned activities and as a listening ear. Pupils can access the Independent Person or the School Counsellor daily and the Wellbeing Committee with pupil representatives meets twice termly to explore initiatives to promote positive health, wellbeing and resilience. Health and Mental Health Matters Policy has more information including a Suicide Risk Mitigation and Prevention Policy.
Pupils are reminded in assemblies taken by the Headmistress or Deputy Heads or the School Council, in House meetings, tutor groups, the Skills for Life programme, in posters around the School and in their study diaries to whom they are able to talk. That may be their Head of House, their tutor, their residential member of staff, the Head of Boarding, the School Chaplain, their teachers, their house captains, their tutor monitor, the School prefects, the Independent Person, the School Counsellor, the School nurses or the School doctor, the Headmistress or the Deputy Heads. Posters and the pupil handbook encourage pupils to be confident that they can discuss a wide range of issues including gender and sexuality if they need to share their concerns. They are encouraged to find a person they trust with a particular awareness of their specific needs. Pupils are kept aware of the Anti-Bullying Policy which encourages them to speak about issues worrying them.
As part of their induction programme the head girls, and upper sixth and lower sixth prefects also receive safeguarding training including what action to take if they hear any allegations of abuse or bullying from other pupils.
Senior staff, Heads of House and residential staff have undertaken e-learning Channel General Awareness training which focuses on providing early support to people who have been identified as being vulnerable to being drawn into radicalisation and/or terrorism.
The School values and promotes effective relationships with parents and positive working relationships and partnerships with local safeguarding agencies and officials and it also recognises the need for all staff to have a broader contextual understanding of safeguarding risks beyond that of school and familial environments.
Details of the NSPCC helpline are displayed around the School, which aims to provide children and adults who are victims of sexual harassment and abuse in school with the appropriate support and advice, and pupils will be supported in accessing this helpline or other preferred further counselling or support as desired.
COMPLIANCEThis policy was updated in July 2025 and is informed by and complies with:
DfE Statutory Guidance Keeping Children Safe in Education September 2025
Working Together to Safeguard Children December 2023
ISI Handbook for the Inspection of Schools September 2025
National Minimum Standards for Boarding Schools September 2022
DfE Guidance: Use of Reasonable Force and Other Restrictive Interventions February 2025
DfE Advice: Sexual violence & sexual harassment between children in schools and colleges September 2021
DfE Statutory Guidance: Relationships and Sex Education and Health Education 2025
DfE Guidance Teaching Online Safety in Schools June 2019
DfE Statutory Guidance: Prevent (April 2021)
Domestic Abuse Act April 2021
Charity Commission Guidance: Safeguarding and protecting people for charities and trustees June 2022
This policy is published on SMILE and is available to Governors, staff, pupils and parents, and on the St Mary’s School Ascot website, in accordance with the ISI Handbook for the inspection of schools.
In all matters relating to safeguarding the School will follow the procedures set out in the Windsor and Maidenhead Multi-Agency Safeguarding Arrangement Procedures Manual, last revised March 2024. These procedures are updated twice a year and published on a dedicated website at proceduresonline.com/berks/windsor_maidenhead/inde...
Prevent DutyIn accordance with the Department for Education Statutory Guidance 2015: Prevent Duty (with effect from 1 July 2015, updated April 2021), St Mary’s recognises its duty to have due regard to the need to prevent pupils from being radicalised and/or drawn into terrorism and adopts appropriate protocols to minimise the risk. The Designated Safeguarding Lead is the designated Prevent Duty person responsible for co-ordinating action within the School and liaising with other agencies.
Although the School assesses the risk to be low, the School implements prevention measures such as applying appropriate restrictions to internet sites likely to promote terrorist and extremist materials, discussing these dangers with pupils when appropriate in suitable forums, and undertaking Prevent awareness staff training periodically to ensure that staff are aware of their responsibilities with respect to Prevent, able to identify pupils at risk and know how to intervene.
All visiting speakers to the School are checked to ensure their suitability and supervised by a member of staff in line with the Visiting Speakers’ Protocol in Safety, Security and Access policy. Details are recorded.
The School will work in partnership with the Local Safeguarding Partners over such matters; the level of risk will determine the most appropriate referral.
Review of Policy and ProceduresThe Safeguarding Policy and Procedures at St Mary’s are under regular review by the Safeguarding Review Board which meets 2 or 3 times a term. Any safeguarding incidents, decisions and actions taken are reviewed to consider whether the Safeguarding Policy needs to be updated to reflect lessons learned. Policies and procedures are reviewed and revised to comply with changes to statutory and other guidance from DfE, to RBWM procedures and to the ISI Handbook for the Inspection of Schools.
The School will remedy any deficiencies or weaknesses in safeguarding arrangements without delay, should any be necessary, and implement changes to policy or procedures in response to Government or other guidance as soon as they are identified.
The Safeguarding sub-committee of the Board of Governors meets twice per term to provide support and guidance to the Board and to maintain close contact with the Headmistress and DSL on safeguarding policy and operational matters including any serious casework, offering support, scrutiny and guidance as required.
The Board of Governors has safeguarding as a standing agenda item for each meeting and carries out an annual review of Safeguarding Policy and Procedures during its meeting in the summer term.
ROLES AND RESPONSIBILITIESSafeguarding and promoting the welfare of pupils is everyone’s responsibility at St Mary’s. Every member of staff is responsible for providing a safe environment in which pupils can develop and learn and every member of staff who comes into contact with pupils must be able and be prepared to identify safeguarding concerns and know how to deal with them.
Designated Safeguarding LeadMrs Keely Benn is a member of the Senior Pastoral Leadership Team and the Safeguarding Review Board and is the Designated Safeguarding Lead (DSL) who has the ultimate lead responsibility for safeguarding and child protection (including online safety and understanding the filtering and monitoring systems and processes in place) for St Mary’s School Ascot. Ms Cristina Garcia, the Pastoral Deputy Head, and Ms Roisin Toner, the Senior Deputy Head, are the Deputy Designated Safeguarding Leads. All these senior members of staff have status and authority to take responsibility for safeguarding and child protection matters including online safety, have received training in safeguarding and child protection and multi-agency working from Windsor and Maidenhead Multi-Agency Safeguarding Partners and are familiar with ‘Working Together to Safeguard Children December 2023.
The role of the Designated Safeguarding Lead is fully described in KCSIE Annex C. The broad areas of responsibility are:
The Governing Body carries out an annual review of the School’s Safeguarding Policy and procedures to ensure that they are up to date and meet the requirements of current legislation and statutory guidance. The DSL provides a detailed brief at the meeting for questions and discussion to enable the Governors to understand the requirements and satisfy themselves that there are appropriate policies, procedures and training in place to comply with the law and to effectively safeguard and promote pupils’ welfare. Governors also review the efficiency with which the related duties have been discharged. Formal minutes of this review and related discussion are recorded and kept on file. In addition, Safeguarding is the first agenda item at each of the other Board meetings of the Governors.
Mrs Annie Casey is the School Governor with leadership responsibility for safeguarding arrangements within the School. As well as being kept up to date on an ongoing basis with updates to policies and procedures she is involved in discussions pertaining to child protection and safeguarding matters with the DSL and she reviews and checks the Single Central Register on a termly basis.
The Safeguarding Committee is a sub-committee of the Board of Governors which meets once per term. The Committee is chaired by Mrs Annie Casey who is the School Governor with Lead Responsibility for safeguarding. Meetings of the Committee will be attended by the Headmistress, Designated Safeguarding Lead (DSL) and Deputy DSLs and usually one other Governor. The role of the Safeguarding Committee is to oversee safeguarding within the School and to provide support and guidance to the Board and to senior staff involved in safeguarding in ensuring that there is a whole school approach to safeguarding in order that it is at the forefront of and underpins all relevant aspects of process and policy development and that all school systems, processes and policies operate in the best interests of the child.
When the School premises are used by external agencies the Bursar, on behalf of the Board of Governors, ensures as part of the letting process that the external provider has satisfactory safeguarding policies and procedures, with appropriate arrangements in place to keep children safe and to liaise with St Mary’s on safeguarding matters as appropriate. The Bursar, who oversees letting of the school during school holidays, is a trained DSL who will take the lead should there be a safeguarding concern raised during a let and who will ensure all the proper agencies are informed.
Safeguarding Review BoardThe Safeguarding Review Board comprises the Designated Safeguarding Lead, the Bursar, the Senior Deputy Head (deputy DSL), the Pastoral Deputy Head (deputy DSL), the Recruitment Officer and the Compliance Officer. This board meets regularly to review and amend safeguarding policies and procedures in the light of new statutory or non-statutory guidance and in response to child protection incidents.
Pastoral Deputy Head
The Pastoral Deputy Head is responsible for the work of and line manages the Designated Safeguarding Lead. She is herself a Deputy Designated Safeguarding Lead who is trained and has authority to deal with safeguarding issues in the absence of the DSL.
Senior Deputy HeadThe Senior Deputy Head is a Deputy Designated Safeguarding Lead who is trained and has authority to deal with safeguarding issues in the absence of the DSL.
Admission RegisterThe Senior Deputy Head is responsible for the Admission Register which is kept up to date by the School Secretary. The information is stored in iSAMS and an electronic and printed copy of the Admission Register is produced at the start of each school year, once a month, and whenever there are any changes made to it. Copies of the register are kept for 3 years after the end of the school year they refer to.
In accordance with DfE requirements the local authority is notified with relevant details of any pupil who joins or leaves the School at a non-standard transition point, ie at any time other than the beginning of year 7, year 9 or lower 6, or the end of year 11 or upper 6. The school secretary transfers this information to the relevant person at RBWM within 5 days of a pupil being added to the Admission Register and as soon as a pupil is removed from the Admission Register. This information is copied to the Local Authority where the pupil concerned is normally resident.
When a pupil joins the School the information required to be submitted to the Local Authority is all the information held within the Admission Register. When a pupil leaves the School the information required is the full name of the pupil, the full name and address and at least one telephone number of the parent with whom the pupil lives, the name of the destination school and the start date, and the grounds for deleting the pupil from the Admission Register.
SIGNS OF ABUSEOne of the best ways to help children is by being aware of the signs of possible abuse, neglect and exploitation. While these signs can take the form of physical injuries, all children are liable to get scratches, bruises, bumps and cuts from time to time in the normal course of childhood activities. Therefore it is sometimes difficult to tell the difference between injuries suffered as part of a quite normal childhood and those caused by physical abuse. Other wider contextual factors and behavioural indicators such as drug taking and or alcohol misuse, unexplainable and/or persistent absences from education, and consensual and non-consensual sharing of nudes and semi-nudes images and/or videos can be signs that children are at risk. Mental health concerns can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.
Abuse is any form of maltreatment of a child and it may be perpetrated by an adult, or another child, known or unknown to the victim. The main areas of abuse are physical, emotional, neglect, online and sexual mistreatment. Other areas of risk include child sexual or criminal exploitation, child-on-child abuse including sexual harassment and sexual violence, female genital mutilation, youth produced sexual imagery, honour based violence and involvement in serious violent crime. Any child who witnesses or experiences the effects of domestic abuse in their family is also regarded as a victim of abuse. Detailed information about signs of abuse can be found in ANNEX A to this policy.
DfE advice: “What to do if you are worried a child is being abused - Advice for practitioners” provides more information on understanding and identifying abuse and neglect. Examples of potential signs of abuse and neglect are highlighted throughout the advice. The NSPCC website also provides useful additional information on types of abuse and what to look out for. Up-to-date guidance on specific safeguarding issues such as sexual harassment and assault, domestic violence, fabricated or induced illness, gangs and youth violence, serious violent crime and gender-based violence is available from professional organisations such as the NSPCC. Web addresses are given at the end of this policy.
Staff should be aware that abuse, neglect, exploitation and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another.
PROCEDURESAllegations of abuse which meets the harms threshold, or behaviour which indicates a possible transferable risk to children may be made against a member of staff, supply teacher, volunteer, contractor, another pupil or pupils, or against another individual outside of the school environment. The allegation may relate to an incident that happened when an individual or organisation was using the school premises for the purposes of running activities for children. For all safeguarding allegations, these procedures apply, including if appropriate, informing the LADO.
If a member of staff is made aware of an allegation of abuse, or if knowledge of possible abuse comes to their attention it is their duty to report the matter immediately. Such abuse includes: behaved in a way that has, or may have, harmed a child; possibly committed a criminal offence; posed a risk of harm to a child; behaved in a way that indicates they may not be suitable to work with children.
On hearing an allegation of abuse or complaint about abuse directly from a pupil, a member of staff should listen to the pupil, provide re-assurance that their report is being taken seriously, irrespective of whether an actual or online incident is being reported, and record the pupil’s statements. The pupil should be assured that they will be supported and kept safe and that they have been right to report the abuse including child-on-child sexual harassment or violence and that the law is there to protect them. The member of staff should not probe or put words into the pupil’s mouth, should limit questioning to the minimum necessary for clarification and should be non-judgemental. Leading questions should be avoided. No inappropriate guarantees of confidentiality should be given; rather the informant should be told that the matter will be referred in confidence to the appropriate people. Staff should be aware that some pupils may not be able or ready to talk or may not recognise their experience as harmful; in these circumstances staff should still report any concerns to the DSL. Where the disclosure relates to harmful sexual behaviours, if possible, the report should be managed with two members of staff present (preferably one of them being the DSL or their deputy).
Where a member of staff has any concern about a child this should be referred immediately to the DSL or in their absence the deputy DSL or another member of SMET if they are temporarily unavailable and the member of staff should then make and submit a written record in any event. The DSL or their deputy will immediately inform the Headmistress so that the appropriate agencies can be informed within 24 hours and the matter resolved without delay. In the absence of the Headmistress the Chair of Governors should be informed instead. The DSL will contact SPA, (RBWM Single Point of Access), formerly MASH (RBWM multi-agency safeguarding hub), and/or the LADO (local authority designated officer) if there is a concern about a member of staff, for advice and direction.
Where a member of staff has any concern about another member of staff, including the DSL, supply staff or volunteers, then this should be referred immediately and directly to the Headmistress. If there is a conflict of interest in reporting the concern to the Headmistress then it should be reported directly to the local authority designated officer (LADO).
Where a member of staff has any concern about the Headmistress then this should be referred immediately and directly to the Chair of Governors without informing the Headmistress. The Chair of Governors will immediately contact the LADO and no investigation into the concern will be undertaken until advice and guidance has been sought from the LADO.
If, at any point, there is a risk of immediate serious harm to a child a referral should be made directly to the local authority children’s social care and/or the police immediately. Any member of staff can make a referral using the contact details for the RBWM Safeguarding Referral and Assessment Team, the Thames Valley Police and the ‘When to call the police’ guidance given at the end of this policy. They should notify the DSL as soon as possible after doing so. The School does not require parental consent for referrals to statutory agencies.
All concerned should act with the utmost discretion: a complaint swept aside on the pretext that it is frivolous or malicious can damage the child and a mistaken allegation against a member of staff can damage their career.
Response to Allegations of AbuseThe Headmistress/ DSL will refer all allegations or suspicions of abuse to the local authority designated officer (LADO), or SPA (RBWM Single Point of Access), formerly MASH (RBWM Multi Agency Safeguarding Hub) as appropriate. Borderline cases will be discussed without identifying individuals in the first instance and following discussions the LADO will judge whether or not an allegation or concern indicates possible abuse. The School will not investigate before contacting the LADO. The LADO and the Headmistress/ DSL will decide in the circumstances what further steps should be taken. This could involve informing parents. In the case of a supply teacher the agency will be kept fully informed and involved in the case. In the most serious cases if a crime has been committed or if the school suspects a crime has been committed the police will be informed. The School will refer to the National Police Chiefs’ Council guidance ‘When to call the police’ where relevant.
Where the allegation of abuse is made by one or more pupils against another pupil, where there is reasonable cause to suspect that a child is suffering, or likely to suffer, significant harm, such abuse will be referred to RBWM. In the event of disclosures about child-on-child abuse, all children involved, whether perpetrator(s) or victim, would be treated as being ‘at risk’. Guidance and support would be sought from RBWM local safeguarding partners and as a relevant agency the School would be involved in discussions with local safeguarding partners regarding action to be taken. A thorough risk-assessment of the situation and risk-based decision-making (with the benefit of the advice of statutory authorities, where appropriate) would be carried out with a view to ensuring the safety and best interests of all pupils. Both alleged victim(s) and perpetrator(s) would receive appropriate support and it may be that siblings of those involved also need support. Consideration would be given for example to: whether the alleged perpetrator should be removed from school for a period, or from certain classes, whether sleeping arrangements should be changed for boarders, whether contact between certain individuals should be prevented or supervised, the availability of counselling, the adequacy of arrangements for listening to children and further opportunities for challenging unacceptable behaviours and promoting respect for others. In the event of an allegation of serious sexual assault, contact between the alleged perpetrator(s) and victim(s) would be avoided during the investigation. The needs and wishes of the victim should be paramount and wherever possible, the victim, if they wish, should be able to continue in their normal routine. Sexual assault can result in a range of health needs which may require referral to the NHS Sexual Assault Referral Centre or other agencies. The alleged perpetrator(s) will also need support and possibly disciplinary sanctions; links at the end of this policy refer to dealing with harmful sexual behaviours.
Where a member of staff is facing an allegation of a criminal offence involving a pupil registered at the School, the member of staff concerned is legally entitled to anonymity until they are either charged with an offence or the anonymity is waived by them. All members of staff who are involved in an investigation or privy to such information have a legal duty to maintain confidentiality and provide information only to those who need to know.
If the allegation concerns a member of staff, a volunteer or another pupil they would normally be informed as soon as possible after the result of the initial investigation is known. They will be warned that anything said will be recorded. The School will appoint a representative to keep the person informed of the likely course of action and the progress of the case.
If it is established that the allegation is false, either on the basis of medical examination or further statements, a written record will be made of the decision and the justification for it and then the person against whom the complaint has been made would normally be informed that the matter is closed. Allegations that are found to have been malicious or unfounded will be removed from personnel records and those that are unsubstantiated, false, malicious or unfounded will not be referred to in employer references. If a report is determined to be unsubstantiated, unfounded, false or malicious, the DSL will consider what further help the pupil and/or the person who has made the allegation may be in need of; for example they may have been abused by someone else and this is a cry for help. In such circumstances, a referral to children’s social care maybe appropriate. If a report is shown to be deliberately invented or malicious, the School will consider whether any disciplinary action is appropriate against the individual who made it.
If the police decide to take the case further, the person concerned will be suspended only if there is no reasonable alternative. The reasons and justification for suspension will be recorded and the member of staff informed of them. In the case of staff the matter will be dealt with in accordance with the Disciplinary Procedure. Where a member of the residential staff is suspended pending an investigation of a child protection nature, the Headmistress will make suitable arrangements for alternative accommodation away from children. In the case of a pupil the matter will be dealt with under the School Rules, Discipline and Sanctions Policy.
During the course of the investigation the School in consultation with the LADO will decide what information should be given to parents, staff and other pupils and how press enquiries are to be dealt with.
Any pupils who are involved will receive appropriate care.
If an investigation leads to the dismissal or resignation prior to dismissal of the member of staff, the Teaching Regulation Agency (TRA) of the DfE will be informed.
St Mary’s follows Disclosure and Barring Service (DBS) guidance and procedures regarding referrals and barring decisions, the Protection of Children Act (PoCA) and the Protection of Vulnerable Adults Act (PoVA) (see the Recruitment and Selection Policy and the DBS Policy and Procedures). The School has a legal duty to make a referral to the DBS as soon as possible after leaving the School of any person (whether employed, contracted, a volunteer or student) whose services are no longer used because he or she is considered unsuitable to work with children and has been removed from regulated activity, for consideration of whether inclusion on the barred lists is required. This includes dismissal, non-renewal of a fixed term contract, no longer using a supply teacher engaged directly or supplied by an agency, terminating the placement of a trainee or volunteer, removing a person from working in regulated activity, no longer using staff employed by a contractor, resignation when they would have been dismissed if they had not already resigned and voluntary withdrawal from any of the above. Where an allegation relates to a member of supply staff provided by an agency, the agency will be kept fully informed and involved. Where a dismissal does not reach the DBS referral threshold, consideration will be given to making a referral to the Teaching Regulation Agency (TRA). Reasons for making such referrals would include: unacceptable professional conduct with children and/or adults; satisfying the harm test in relation to children and/or vulnerable adults; conduct that may bring the profession into disrepute; or a caution or conviction, at any time, for a relevant offence. When an individual is removed from regulated activity as much relevant information as possible will be provided when the referral is made to the DBS. Any investigation will be led by an identified case manager, normally the Headmistress.
If there has been a substantiated allegation against a member of staff, the School will work with the LADO to identify any changes which could be made to policy or procedures to lessen the risk for the future.
Response to sharing of nudes and semi-nudes, sexual assault or harassmentAny concern about recent or historic sharing of nudes or semi-nudes, or sexual assault or harassment should be reported immediately to the DSL in the normal way who will report and discuss the matter with the Headmistress. If appropriate, subsequent interviews with the pupils involved will take place with or closely supported by a trained member of staff, and parents will be informed at an early stage, involved in the process in order to best support the pupil (unless there is good reason to believe that involving them would put the pupil at risk of harm) and also supported to understand the wider issues and motivations around the event. Any discussion of images will aim to identify the content without viewing wherever possible. Pupils will be helped to access organisations such as CEOP, the Internet Watch Foundation and Childline’s “Report Remove” tool, to endeavour to get images online removed.
A risk assessment will be carried out immediately to determine pupils’ safety in school and appropriate measures adopted swiftly and as necessary, such as separating the victim and the alleged abuser in classes or in the boarding area. A decision to respond to the incident without involving the police or children’s social care would be made in cases when the DSL is confident that they have enough information to assess the risks to pupils involved and the risks can be managed within the school’s pastoral framework. If a pupil has shared imagery consensually, such as when in a romantic relationship, and there is no intended malice, it is usually appropriate for the school to manage the incident directly. In contrast, any incidents with aggravating factors, for example, a young person sharing someone else’s imagery without consent and with malicious intent, should generally be referred to the police and/or children’s social care. In these cases, the School will follow the advice from the National Police Chiefs’ Council “When to call the police” in liaising with the police and making a report on these issues.
An immediate referral to police and/or children’s social care will be made at the initial stage if:
A disclosure may not be a single event, and further information may be shared by the pupil at a later stage, prompting multiple reviews and risk assessments depending on the situation. The School appreciates that a child who discloses that they are the subject of an incident of sharing nudes and/or semi-nudes or sexual assault and/or harassment is likely to be embarrassed and worried about the consequences. When the disclosure is made the member of staff will ensure the child is feeling comfortable, and appropriate and sensitive questions are asked in order to minimise further distress or trauma.
In reviewing the risks and deciding whether a referral is needed, the following will be considered:
Some behaviours are concerning but do not meet the harms threshold. It is important to deal with low-level concerns appropriately and expeditiously to prevent them escalating. A low-level concern is any concern that an adult working in or on behalf of the School may have acted in an unprofessional way that is inconsistent with the staff behaviour policy or code of conduct, including inappropriate conduct outside of work, but does not meet the harms allegations threshold and so does not merit a referral to the LADO. Examples of such behaviour could include, but are not limited to: being over friendly with pupils; having favourites; taking photographs of pupils on their mobile phone; engaging with a pupil on a one-to-one basis in a secluded area or behind a closed door; using unprofessional language.
Low-level concerns about a member of staff should be referred to the DSL or the Headmistress. The DSL will inform the Headmistress of all low-level concerns in a timely manner according to the nature of the concern. Low-level concerns about the Headmistress should be referred to the Chair of Governors. All low-level concerns will be addressed sensitively and proportionately by the Headmistress, possibly after collaborating with the DSL, with the intention that unprofessional behaviour that does not meet the staff behaviour policy or code of conduct can be corrected at an early stage. The Headmistress will collect as much information as possible from the reporter, the member of staff concerned and any witnesses in order to establish what action needs to be taken. This will include looking for wider cultural issues that may have enabled the behaviour to occur and considering if extra staff training is required. Reports about supply staff and contractors will be notified to their employers so any potential patterns of inappropriate behaviour can be identified.
Where a member of staff has engaged in behaviour themselves that they recognise to be a low-level concern they should report this as a ‘self-referral’. A low-level concern does not mean that the incident is insignificant but that it does not meet the harm threshold as recognised by the LADO. Examples of self-referral could include but are not limited to brushing against a pupil in a corridor accidentally or knocking before entering a room and then discovering that a pupil is in a state of undress. We encourage staff at St. Mary’s to self-refer by recording the incident on CPOMS or contacting the DSL. The DSL will follow-up with the member of staff as appropriate. The safeguarding team will ensure staff are trained on how to ‘self-refer’ to continue to foster a safeguarding culture within the School.
Low-level concerns will be recorded including the detail of the concern, the context and the actions taken and the rationale. Records will be kept securely and confidentially until the member of staff leaves the School. In accordance with KCSIE, low-level concerns relating exclusively to safeguarding will not be referred to in references although other low-level concerns relating to such matters as poor performance or misconduct may be. Records should be reviewed so that potential patterns of problematic or inappropriate behaviour can be identified and addressed.
ConfidentialityMembers of staff should never give a guarantee of confidentiality to pupils or adults wishing to make a disclosure. They should guarantee only that they will pass on information to the minimum number of people required in order to ensure that the appropriate action is taken in response to the disclosure; they will not tell anyone who does not have a clear need to know. They will also take whatever steps they can to protect the informing pupil or adult from any retaliation or unnecessary stress that might be feared after a disclosure has been made.
Record KeepingAll concerns, referrals, reports, conversations, discussions, meetings, communications, decisions taken and the reasons for the decisions, actions and outcomes, including instances of child-on-child abuse and harmful sexual behaviours, whether or not they are referred to another agency, are recorded in writing and stored confidentially in a designated child protection file.
Child protection files are shared only with those who need to see them but information is shared with all those who are actively engaged in the case within and outside of the School. The Designated Safeguarding Lead keeps a register of all child protection incidents and a register of all reports of child-on-child sexual abuse and harassment. Records containing information about allegations of sexual abuse will be kept for the term of the Independent Inquiry into Child Sexual Abuse and all other records of allegations will be retained until the accused has reached normal retirement age or for 10 years if longer.
In line with the Data Protection Act 2018, and the UK General Data Protection Regulation (UK GDPR), the School processes personal information fairly and lawfully and keeps the information it holds safe and secure.
Procedure if a Pupil is MissingDuring the working day:
If a pupil is missing at bedtime or in the early hours:
A record is kept by the Pastoral Deputy Headmistress of any instances in which a pupil is missing from school without satisfactory permission and documentation, including the action taken and the pupil’s explanation. Staff should be aware that prolonged or repeated absence from school may indicate a safeguarding risk.
Where a day pupil or boarder is missing from school because they have returned home or refuse to return to school after an authorised absence, the school will liaise with the parents to establish the best way forward for the pupil. If there is any concern for the safety or wellbeing of the pupil, or in the case of a day pupil’s unexplained extended absence, the school will liaise with RBWM and/or the local authority of the pupil’s home address. If the pupil leaves the School, the School will notify the two Local Authorities.
St Mary’s complies with the DfE statutory guidance ‘Working together to improve school attendance’ and recognises that unauthorised absence from school carries heightened risk of harm to a child. The school Attendance Policy upholds the importance of school attendance to facilitate high attainment and well-being, and details the measures taken to manage both authorised and unauthorised absence from school.St Mary’s ensures the implementation of safe recruitment practices in accordance with all statutory guidance (see the Recruitment and Selection Policy and the DBS Policy and Procedures). Statutory procedures for checking the suitability to work with children of all staff whether teachers or non-teachers, including employed teachers and self-employed peripatetic visiting teachers and coaches, volunteers and Governors are always followed including enhanced criminal records checks with the DBS, barred list checks, prohibition order checks, further checks on those who have lived or worked overseas, section 128 prohibition from management checks and compliance with Independent School Standards Regulations. The Recruitment Officer and at least one member of those interviewing at St Mary’s must have received the Department for Education safer recruitment training.
Assurance is obtained that appropriate child protection checks and procedures apply to any staff employed by another organisation and working with the School’s pupils on another site.
Staff TrainingSt Mary’s has a positive safeguarding culture and all staff are reminded regularly that they have a duty of care of pupils under their supervision and a responsibility to speak up about safeguarding and welfare matters. All child protection and safeguarding training is given by one of three members of staff: Pastoral Deputy Head, Senior Deputy Head, and Bursar, all of whom have themselves received training in child protection and safeguarding matters and multi-agency working provided by the Royal Borough of Windsor and Maidenhead and who are familiar with the Guidance ‘Working Together to Safeguard Children’.
All staff including the Headmistress, full-time and part-time staff, self-employed peripatetic staff and voluntary staff including Governors receive initial child protection and safeguarding training including online safety, filtering and monitoring as part of their induction programme. They are made aware of this Safeguarding Policy including its Staff Behaviour Policy, the Pupil Behaviour Policy and the identity and role of the DSL and deputy DSL, and trained in the importance of being alert to the signs of bullying, abuse, including harmful sexual behaviours, and children at risk of radicalisation, and the procedures for recording concerns and reporting them to the DSL or the Headmistress. Staff complete a quiz at the end of the training to check their understanding of crucial points. Support staff and self-employed peripatetic staff complete an induction checklist to be signed off by their Head of Department or returned to the Recruitment Officer.
Part 1 of Keeping Children Safe in Education, including Annex B, is issued to new staff and to all staff at each revision and is discussed during INSET. Staff who work directly with pupils are required to complete an online questionnaire to demonstrate that they have read and understood the document. Other staff complete a paper questionnaire to demonstrate that they have read and understood it. A condensed version of KCSIE (KCSIE Annex A) may be provided to staff who do not work directly with children in lieu of Part 1 if the DSL considers it will provide a better source of information for them to safeguard and promote the welfare of children.
Governors’ training is designed to equip them with the knowledge to provide strategic challenge to test and assure themselves that the safeguarding policies and procedures, and the appropriate filters and monitoring systems to ensure online safety, are effective and support the delivery of a robust whole school approach to safeguarding. Training includes their obligations under the Human Rights Act 1998, the Equality Act 2010, (including the Public Sector Equality Duty), and their local multi-agency safeguarding arrangements. Governors’ safeguarding training consists of 1 hour induction from the DSL; requirement to read and confirm KCSIE whenever it is updated; 10 minutes safeguarding update from the DSL at the start of the Michaelmas and Lent term meetings; 30 minutes safeguarding training from the DSL at the summer term meeting; enhanced safeguarding training for the Safeguarding Governor and the Chair of the Safeguarding committee.
The DSLs undertake accredited training by attending at least 4 out of 6 RBWM DSL Network meetings in any 2 year period. They receive frequent updates from e-bulletins and have discussions with other professionals in order to keep abreast of safeguarding developments. Refresher child protection and safeguarding training including online safety is provided regularly for all staff and Governors and is recorded.
Regular updates about changes to policy or new procedures or requirements and topical matters such as harmful sexual behaviours and online sexual abuse, are given during INSET or issued as a paper or e-bulletin at the beginning of most terms when staff are reminded that it is the responsibility of every member of staff to safeguard pupils, and these resources are available for staff online.
STAFF BEHAVIOUR POLICYStaff are expected to manage pupil behaviour effectively to ensure a good and safe educational environment in school in accordance with the DfE Teachers’ Standards (updated July 2021), and to have a clear understanding of the needs of all pupils including those with SEND or mental health needs. It is staff’s responsibility to behave professionally in all their dealings with children and specifically with pupils for whom staff have a duty of care. This guidance has been produced to help staff establish the safest possible learning and working environments where an atmosphere of trust exists in which colleagues can conduct their professional lives with confidence. The aims are to safeguard young people - all staff have both a duty of care and a responsibility to speak up about safeguarding and welfare matters using the Whistleblowing procedures.
Whilst every attempt has been made to cover a wide range of situations, it is recognised that any such guidance cannot cover all eventualities. There may be times when professional judgements are made in situations not covered by this document, or which directly contravene the guidance given. It is expected that in these circumstances staff will always advise their senior colleagues of the justification for any such action already taken or proposed. The Code of Conduct covers expectations of general behaviour whilst on duty and includes arrangements for staff access to the boarding areas.
Position of TrustA relationship between a member of staff and a pupil cannot be a relationship between equals. As a result of their knowledge, position and/or the authority invested in their role, all adults working with children and young people in educational settings are in positions of trust in relation to the young people in their care. There is potential for exploitation and harm of vulnerable young people and all members of staff have a responsibility to ensure that an unequal balance of power is not used for personal advantage or gratification. Staff should note that it is an offence for a person aged 18 or over, such as a teacher, to have a sexual relationship with a child under 18 when that person is in a position of trust in respect of that child, even if, in the case of those over 16, the relationship is consensual.
Wherever possible, staff should avoid behaviour which might be misinterpreted by pupils or onlookers, and should always report and record any incident with this potential to the DSL.
Physical Contact with PupilsThere are occasions when it is entirely appropriate and proper for staff to have physical contact with pupils, but it is crucial that they only do so in ways appropriate to their professional role. Staff should, therefore, use their professional judgement at all times. Staff should not have unnecessary physical contact with pupils and should be alert to the fact that minor forms of friendly physical contact can be misconstrued by pupils or onlookers.
A member of staff can never take the place of a parent in providing physical comfort and should be cautious of any demonstration of affection.
Physical contact should never be secretive, or for the gratification of the adult, or represent a misuse of authority. If a member of staff believes that an action could be misinterpreted, the incident and circumstances should be recorded as soon as possible and notified to the DSL and, if appropriate, a copy placed on the pupil’s file.
The Use of Force to Control or Restrain PupilsThe Education Act 1996 forbids corporal punishment and St Mary’s complies with the rejection of its use in all circumstances. The DfE Guidance ‘Use of Reasonable Force and Other Restrictive Interventions’ February 2025 allows all teachers to use reasonable force to prevent a pupil from:
This is in addition to the common law power of any citizen to use reasonable force in self-defence, or to prevent another person from being injured or committing a criminal offence. The School’s guidance on use of restraint is designed to ensure the safety of staff and pupils. We believe that it is only ever acceptable to use reasonable force to prevent a pupil harming herself, another pupil, a member of staff or any other person, or destroying property.
Force used to avert an immediate dangerAll staff supervising or in charge of pupils are authorised to use reasonable force in situations which meet the objectives outline above. If immediate action needs to be taken to protect a pupil (for example, to intercept a fall downstairs) and physical intervention proves necessary, it should involve the minimum of force required to prevent injury to persons and damage to property. A sole member of staff is advised not to intervene physically in an argument unless absolutely necessary but to raise the alarm and summon assistance if necessary. Under no circumstances should physical force be used as a form of punishment.
Force is only to be used when:
The kinds of situation in which the use of force might be advisable are:
The refusal of a pupil to remain in a particular place is not enough on its own to justify the use of force. It would, however, be justifiable if the pupil were about to risk her own or someone else’s safety.
The types of force staff are authorised to use are:
Where there is an immediate and high risk of death or serious injury, a member of staff would be justified in taking any necessary action consistent with the principle of seeking to use the minimum amount of force required to achieve the desired result. Staff should make every effort to avoid acting in a way that might reasonably expect to cause injury. If staff need to touch a pupil for any of the reasons above, they should be very careful about how and where they touch pupils. Conduct must always remain appropriate.
Some children and young people with SEND may react to distressing or confusing situations by displaying behaviours which may be harmful to themselves and others. This can lead to pupils with SEND being disproportionately subject to the use of reasonable force and other restrictive interventions. The School will utilise staff who know individual pupils well to help identify trigger points when challenging behaviour is more likely to occur and develop proactive strategies to reduce the likelihood of reasonable force and/or other restrictive interventions being needed.Staff will be reminded of this guidance as part of regular child protection and safeguarding training. In addition, it will be included in the induction programme for all new staff.
Reporting and recording incidents where force has been used to control or restrain pupilsAs soon as is practicable, the use of force should be reported to the Headmistress or one of the Deputy Heads. A full written account should be supplied (as described below). The Headmistress or Senior Deputy Head or DSL should inform the pupil’s parents and give them an opportunity to discuss the incident. It may also be necessary to report the incident to authorities outside School and the Headmistress or Senior Deputy Head in consultation with the DSL will make this decision.
A record should made by the person who used restraint and passed to the Headmistress, Senior Deputy Head or DSL. The record should include the following information:
After any incident, the School should seek to offer continuing support to all staff and pupils involved in the incident.
Monitoring and Review of the use of Physical RestraintThe DSL keeps and monitors a register of all instances where physical restraint is used. This policy is reviewed each time an incident occurs and annually including a consideration by the Headmistress as to whether additional staff training is required to enable staff to de-escalate potentially violent situations without the need for restraint.
Physical Education and Other Activities Requiring Physical ContactWhere exercises or procedures need to be demonstrated, caution should be used if the demonstration involves contact with pupils and, wherever possible, contact should be avoided. It is acknowledged that some staff, for example, those who teach PE and games, or who offer music tuition, will on occasions have to initiate physical contact with pupils in order to support a pupil so they can perform a task safely, to demonstrate the use of a particular piece of equipment/instrument or to assist them with an exercise. This should be done with the pupil's prior agreement.
Contact under these circumstances should be for the minimum time necessary to complete the activity and take place in an open environment. Staff should remain sensitive to any discomfort expressed verbally or non-verbally by the child.
Members of Staff and One-to-One SituationsWhere staff perform a pastoral, disciplinary or tutorial task, or give co-curricular lessons such as music or drama, this may involve them being in one-to-one situations. Staff working in one-to-one situations must plan and conduct these to minimise the risk of harm to all parties. One-to-one meetings should take place in the vicinity of other teachers and pupils, in a room with visual access. If possible, doors should remain open (or have glass panels) and there should be the equivalent of a desk or small table width between pupil and teacher. Residential staff who need to deal with an individual pupil, for example a distressed pupil at night, should avoid any inappropriate one-to-one contact, should remain in a public area and, if necessary, take the pupil to the Health Centre.
Residential staff, including those living outside the main building, eg Heads of House, should ensure that pupils do not enter their accommodation unless invited to do so in an exceptional circumstance.
Residential staff with children hosting visiting pupilsThe National Minimum Standards for Boarding Schools 2022 (NMS 20.10) does not allow pupils into staff accommodation unless in exceptional circumstances. However, footnote 44 clarifies that this standard does not prevent boarders from visiting their friends who live in staff accommodation. The School operates the following policy to ensure such visits are conducted safely.
If the visit is to take place during term time, the hosting member of staff should contact the Head of House who will seek permission from the visiting pupil’s parents. The hosting member of staff should add a note to CPOMS labelled ‘pupil guest in staff accommodation’, tagging their own child and the pupil(s) they are hosting.
If the visit is out of term time, the hosting staff will need to seek written permission from the parents of the visiting pupil(s) directly and add a note to CPOMS as above.
In line with the NMS, staff should avoid being alone with the visiting pupil(s).
Any concern about the welfare of the visiting pupil(s) should be reported to the DSL immediately and any concern about the conduct of the hosting member of staff should be reported to the Headmistress.
Transporting PupilsIt is not advisable for a member of staff to give a lift in a car to a pupil alone. Wherever possible and practicable it is advisable that transport is undertaken other than in private vehicles, with at least one adult additional to the driver acting as a chaperone. If there are exceptional circumstances that make unaccompanied transportation of pupils unavoidable, the journey should be made known to a senior member of staff and appropriate control measures implemented.
Social Contact and CommunicationStaff must not socialise with pupils outside the normal course of their duties. Socialising would include, although is not restricted to, personal, telephone, text messaging and e-mail contact, and contact through social media sites such as Facebook or Instagram. Staff are required to adhere to the ICT Acceptable Use Policy for Staff which includes regulations on e-communications. Given the required professional nature of staff/pupil relationships throughout the pupil’s time in school, the School recommends leaving a period of three years after a pupil has left school before making any social contact with them using social media, personal email or any other form of communication. Staff who have left St Mary’s should not have contact with current pupils nor contact any former pupil until three years after the pupil has left school.
Staff should ensure that their conduct does not give rise to comment or speculation and should bear in mind that comments and behaviour towards pupils may be misconstrued. Staff should ensure that no comments are made towards pupils that contain sexual innuendo or connotations or are of an otherwise sexual nature.
OtherWhilst it is recognised that these guidelines do not cover every situation and that there will be many occasions on which members of staff will have to use their own professional judgement and discretion, the above outlines some potential problem areas and how to minimise risks.
Staff should refer to these guidelines in conjunction with other School policies including the Code of Conduct and the Disciplinary Policy and Procedure.
WhistleblowingIf a member of staff believes that best practice is not being adhered to in the care and protection of a pupil or pupils, or that a practice may put a pupil or pupils at risk, they have a responsibility to speak up and should follow the procedures set out in the Whistleblowing Policy. In the first instance they should raise the matter with the DSL or the Headmistress or any other member of SMET with whom they feel comfortable.
Genuine concerns about policy or procedures will be taken seriously by senior staff and no member of staff will suffer a detriment or be disciplined for raising a genuine and legitimate concern about unsafe practice, providing that they do so in good faith and follow the whistleblowing procedures.
Where all internal procedures have been exhausted, a member of staff shall have a right of access to an external body such as the local Single Point of Access (SPA), formerly known as Multi Agency Safeguarding Hub (MASH). In addition, the NSPCC has a dedicated Whistleblowing helpline. Contact details for both are at the end of this policy.
Under the Public Interest Disclosure Act 1998, there are circumstances where a member of staff may be entitled to make a protected disclosure and raise a concern directly with an external body without penalty where the employee reasonably believes
(Annexes available upon request)