Slovak Learning CIC’s Data Protection Policy

Slovak Learning CIC’s Safeguarding Policy

(Reviewed: August 2024)

(Person Responsible for the Policy: Patrik Čuchta)

Contents

The Scope of the Policy

Safeguarding Statement

Important Contacts

Definitions

1. Introduction 


2. Safeguarding Children and vulnerable adults Policy 


3. What to do if Children and vulnerable adults Talk to you About Abuse or Neglect 


4. Consult About your Concern 


5. Make a Referral 


6. Allegations Against Adults who work with Children 


7. Training

8. Responsibilities

9. E-Safety

10. Mobile Phones and Cameras

11. Confidentiality 


12. Notifying parents

13. Useful Telephone Numbers 


14. Further Slovak Learning CIC policy references

15. Policy Review

Safeguarding Statement

Slovak Learning CIC recognises the moral and statutory responsibility to safeguard and promote the welfare of all pupils. We endeavour to provide a safe and welcoming environment where children are respected and valued. We are alert to the signs of abuse and neglect and follow our procedures to ensure that children receive effective support, protection and justice. Child protection forms part of oursafeguarding responsibilities.

Important Contacts

1.Headteacher/Designated Safeguarding Lead

Name: Patrik Čuchta Tel: 07960753005 Email: patrik.cuchta@slovaklearning.co.uk

2.Deputy Designated Safeguarding Lead (London Branch)

Name: Martina Bačinská

Email: martina.bacinska@slovaklearning.co.uk

3.Deputy Designated Safeguarding Lead (Cambridge Branch)

Name: Zuzana Franková

Email: zuzana.frankova@slovaklearning.co.uk

The Scope of this policy

The purpose of this document is to set out Slovak Learning CIC Safeguarding Policy.

To fulfil Slovak Learning CIC’s commitment to safeguard and promote the welfare of children, all organisations that provide services for, or work with, children must have:

• Clear priorities for safeguarding and promoting the welfare of children and vulnerable adults, explicitly stated in strategic policy documents 
 • A clear commitment by senior management to the importance of safeguarding and promoting welfare 


• A clear line of accountability and defined roles and responsibilities within the organisation for safeguarding and promoting the welfare of children and vulnerable adults. 


• Recruitment and human resources management procedures that take account of the need to safeguard and promote the welfare of children, vulnerable adults and young people, including arrangements for appropriate checks on new staff and volunteers. eg DBS (Disclosure and Barring Service), Registration via LSCB and the use of the Vetting and Barring Scheme (VBS) (when operational) 
 • Safe working practice guidance which staff/volunteers have read and understood 


• Procedures for dealing with allegations of abuse against members of staff and volunteers, 
including a Named Senior Officer to whom allegations and concerns are reported 


• Arrangements to ensure that all staff undertake appropriate training to equip them to carry out 
their responsibilities effectively, and keep this up-to-date by refresher training at regular intervals; and that all staff, including temporary staff and volunteers who work with children and vulnerable adults, are made aware of the establishment's arrangements for safeguarding and promoting the welfare of children and vulnerable adults and their responsibilities for that 


• Policies for safeguarding and promoting the welfare of children and vulnerable adults including a child protection policy, and procedures that comply with LLC Safeguarding Children and vulnerable adults policies and procedures for safeguarding. 


• Arrangements to work effectively with other organisations to safeguard and promote the welfare of children and vulnerable adults, including arrangements for sharing information. 


• A culture of listening to, and engaging in dialogue, with children and vulnerable adults- seeking children's views in ways that are appropriate to their age and understanding, and taking account of those views in individual decisions and in the establishment or development of services • Appropriate whistle-blowing procedures, and a culture that enables issues about safeguarding and promoting the welfare of children and vulnerable adults to be addressed. 


• Safeguarding of on-line, social media and generic ICT activities by and for learners and staff and stakeholders.

Definitions


Safeguarding and promoting the welfare of children means:

• Protecting children from maltreatment 


• Preventing impairment of children’s health or development 


• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care 


• Taking action to enable all children to have the best outcomes.


Child protection is part of this definition and refers to activities undertaken to 
prevent children suffering, or being likely to suffer, significant harm. 


Abuse is a form of maltreatment of a child and may involve inflicting harm or failing to act to prevent harm. Appendix 1 explains the different types of abuse. 


Neglect is a form of abuse and is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Appendix 1 defines neglect in more detail. 


Children includes everyone under the age of 18. 


1. Introduction

1.1 The purpose of this document is to set out Slovak Learning CIC’s Safeguarding Policy. This document is the Safeguarding Children and Vulnerable Adults Policy for Slovak Learning CIC which will be followed by all members of the organisation and followed and promoted by those in the position of leadership within the organisation. 


1.2 Individual agencies are responsible for ensuring that their employees are competent and confident in carrying out their responsibilities for safeguarding and promoting children's welfare. 


1.3 The purpose of the organisation is the delivery and management of learning and skills services. 


1.4 We know that being a young person makes them vulnerable to abuse by adults. The purpose of this policy is to make sure that the actions of any adult in the context of the work carried out by the organisation are transparent and safeguard and promote the welfare of all young people. 


1.5 This document is written in accordance with Working Together to Safeguard Children (2013). 


1.6 Principles upon which the Safeguarding Children is based:

• The welfare of a child, young person will always be paramount 


• The welfare of families will be promoted 


• The rights, wishes and feelings of children, young people and their families will be respected and listened to, keeping safe from harm requires people who work with children and vulnerable adults to share information. 


• Those people in positions of responsibility within the organisation will work in accordance with the interests of children, vulnerable adults and young people and follow the policy outlined below;

1.7 This policy is also based on the following legislation:

• Section 175 of the Education Act 2002, which places a duty on schools and local authorities to safeguard and promote the welfare of pupils. 


• The School Staffing (England) Regulations 2009, which set out what must be recorded on the single central record and the requirement for at least one person on a school interview/appointment panel to be trained in safer recruitment techniques. 


• Part 3 of the schedule to the Education (Independent School Standards) Regulations 2014, which places a duty on academies and independent schools to safeguard and promote the welfare of pupils at the school. 


• The Children Act 1989 (and 2004 amendment), which provides a 1 https://www.gov.uk/government/publications/working-together-to-safeguard-children--2

• Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015, which places a statutory duty on teachers to report to the police where they discover that female genital mutilation (FGM) appears to have been carried out on a girl under 18. 


• Statutory guidance on FGM, which sets out responsibilities with regards to safeguarding and supporting girls affected by FGM. 


• The Rehabilitation of Offenders Act 1974, which outlines when people with criminal convictions can work with children.

• Schedule 4 of the Safeguarding Vulnerable Groups Act 2006, which defines what ‘regulated activity’ is in relation to children. 


• Statutory guidance on the Prevent duty, which explains schools’ duties under the Counter-Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism. 


2. Safeguarding Children and Vulnerable Adults Policy

2.1 Immediate Action to ensure Safety 


Immediate action may be necessary at any stage in involvement with children and vulnerable adults and families. 
IN ALL CASES IT IS VITAL TO TAKE WHATEVER ACTION IS NEEDED TO SAFEGUARD THE CHILD OR CHILDREN AND/OR VULNERABLE ADULTS CONCERNED i.e.:

• If emergency medical attention is required this can be secured by calling an ambulance (dial 999) or taking a child to the nearest Accident and Emergency Department. 


• If a child is in immediate danger the police should be contacted (dial 999) as they alone have the power to remove a child immediately if protection is necessary, via their powers to use Police Protection. 


2.2 Recognition of Abuse or Neglect 


Abuse and neglect are forms of maltreatment of a child and/or vulnerable adults. Somebody may abuse or Neglect a child and/or vulnerable adult by inflicting harm, or by failing to act to prevent harm. Children and vulnerable adults may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger. They may be abused by an adult or adults, or another child or children. 


2.3 Physical Abuse 


Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a child. 


2.4 Emotional Abuse 


Emotional abuse is the persistent emotional ill treatment of a child such as to cause severe and persistent adverse effects on the child's emotional development. It may involve conveying to children and vulnerable adults that they are worthless or unloved, inadequate, or valued only in so far as they meet the needs of another person. 
 It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child's developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying, causing children and vulnerable adults frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of Emotional Abuse is involved in all types of ill treatment of a child and/or vulnerable adult though it may occur alone. 


2.5 Sexual Abuse 


Sexual abuse involves forcing or enticing a child, young person and/or vulnerable adult to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape or buggery or oral sex) or non-penetrative acts. They may include non-contact activities, such as involving children and vulnerable adults in looking at, or in the production of, sexual online images, watching sexual activities, or encouraging children and vulnerable adults to behave in sexually inappropriate ways.

2.6 Neglect

Neglect is the failure to meet a child's and/or vulnerable adult basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

• provide adequate food, clothing and shelter (including exclusion from home or abandonment) 


• protect a child from physical and emotional harm or danger 


• ensure adequate supervision(including the use of inadequate care-givers) 


• ensure access to appropriate medical care or treatment 
It may also include Neglect of, or unresponsiveness to, a child's and/or vulnerable adult basic emotional needs. 


2.7 Individuals within the organisation need to be alert to the potential abuse of children and vulnerable adults both within their families and also from other sources including abuse by members of that organisation. 


2.8 The organisation should know how to recognise and act upon indicators of abuse or potential abuse involving children and vulnerable adults and where there are concerns about a child's
welfare. There is an expected responsibility for all members of the organisation to respond to any suspected or actual abuse of a child in accordance with these procedures. 


2.9 It is good practice to be as open and honest as possible with parents/carers about any concerns. However, you MUST NOT discuss your concerns with parents/carers in the following circumstances:

• where Sexual Abuse or sexual exploitation is suspected 


• where organised or multiple abuse is suspected 


• where there are concerns a child may be at risk of Female Genital Mutilation 


• where fabricated or induced illness (previously known as Munchausen Syndrome by proxy) 
is suspected 


• where contacting parents/carers would place a child, yourself or others at immediate risk 


2.10 These decisions should not be taken in isolation. Consult with your senior manager/line manager/designated teacher. 


3. What to do if Children and Vulnerable Adults talk to you about abuse or neglect

3.1 It is recognised that a child and/or vulnerable adult may seek you out to share information about abuse or Neglect, or talk spontaneously individually or in groups when you are present. In these situations YOU MUST:

-Listen carefully to the child and/or vulnerable adult. DO NOT directly question the child 


• Give the child and/or vulnerable adult time and attention.

• Allow the child and/or vulnerable adult to give a spontaneous account; do not stop a child 
who is freely recalling significant events. 


• Make an accurate record of the information you have been given taking care to record the 
timing, setting and people present, the child's and/or vulnerable adult’s presentation as well 
as what was said. Do not throw this away as it may later be needed as evidence. 


• Use the child's and/or vulnerable adult’s own words where possible. 


• Explain that you cannot promise not to speak to others about the information they have 
shared - do not offer false confidentiality. 


• Reassure the child and/or vulnerable adult that: o they have done the right thing in telling you; o they have not done anything wrong;

• Tell the child and/or vulnerable adult what you are going to do next and explain that you will 
need to get help to keep him/her safe. 


• DO NOT ask the child and/or vulnerable adult to repeat his or her account of events to 
anyone


If you have a Child and/or vulnerable adult protection concern you should:

4. Consult about your concern 


4.1 Because of your observations of, or information received you may become concerned about a child and/or vulnerable adult who has not spoken to you. 


4.2 It is good practice to ask a child and/or vulnerable adult why they are upset or how a cut or bruise was caused, or respond to a child and/or vulnerable adult wanting to talk to you. This practice can help clarify vague concerns and result in appropriate action. 


4.3 If you are concerned about a child and/or vulnerable adult you must share your concerns. Initially you should talk to one of the people designated as responsible for child and/or vulnerable adult protection within your organisation. In this organisation this person is Patrik Cuchta (Tel: .07960753005); if not present then consult Martina Bačinská (for London branch) or Zuzana Franková (for Cambridge branch).

4.4 You should consult with your local Social Care Duty & Investigation Team in the area where the child and/or vulnerable adult resides, in the following circumstances:

• when you remain unsure after internal consultation as to whether child and/or vulnerable adult protection concerns exist 


• when there is disagreement as to whether child and/or vulnerable adult protection concerns exist

• when you are unable to consult promptly or at all with your designated internal contact for child and/or vulnerable adult protection 


• when the concerns relate to any member of the organising committee 


4.5 Consultation is not the same as making a referral but should enable a decision to be made as to whether a referral to Social Care or the Police should progress.

5. Make a Referral

5.1 A referral involves giving Social Care or the Police information about concerns relating to an individual or family in order that enquiries can be undertaken by the appropriate agency followed by any necessary action. 


5.2 Parents/carers should be informed if a referral is being made except in the circumstances outlined in section 2.9. 


5.3 However, inability to inform parents for any reason should not prevent a referral being made. It would then become a joint decision with Social Care about how and when the parents should be approached and by whom. 


5.4

• if your concern is about harm or risk of harm from a family member or someone known to the children and/or vulnerable adults, you should make a telephone referral to the Social Care Duty & Investigation Team in the area where the child and/or vulnerable adult resides (see Section 8: Useful Slovak Learning Telephone Numbers).

• If your concern is about harm or risk of harm from someone not known to the child and/or vulnerable adult family, you should make a telephone referral directly to the Police. 


• If your concern is about harm or risk of harm from an adult in a position of trust see Section 6: Allegations Against Adults Who Work With Children. 


• If your concern is that a child and/or vulnerable adult or their family need additional help or support, you should contact the appropriate Locality Team (see Section 8: Useful Slovak Learning Telephone Numbers). 


5.5 Information required when making a referral Be prepared to give as much of the following information as possible (in emergency situations all of this information may not be available). Unavailability of some information should not stop you making a referral.

• Your name, telephone number, position and request the same of the person to whom you are speaking. 


• Full name and address, telephone number of family, date of birth of child and/or vulnerable adult and siblings. 


• Gender, ethnicity, first language, any special needs. 


• Names, dates of birth and relationship of household members and any significant others. 


• The names of professionals known to be involved with the child/family and/or vulnerable 
adult e.g.: GP, Health Visitor, School.


• The nature of the concern; and foundation for the concern. 


• An opinion on whether the child may need urgent action to make them safe. 


• Your view of what appears to be the needs of the child and/or vulnerable adult and their 
family. 
 •

Whether the consent of a parent with Parental Responsibility has been given to the referral 
being made. 


5.6 Action to be taken following the referral

• Ensure that you keep an accurate record of your concern(s) made at the time. 


• Put your concerns in writing to the Social Care Duty & Investigation Team following the 
referral (within 48 hours) 


• Accurately record the action agreed or that no further action is to be taken and the reasons 
for this decision. 


6. Allegations against Adults who work with Children. 


If you have information which suggests an adult who works with children and vulnerable adults (in a paid or unpaid capacity) has: 


6.1 • behaved in a way that has harmed or may have harmed a child and/or vulnerable adult.

• possibly committed a criminal offence against, or related to, a child and/or vulnerable adult. 


• behaved towards a child/children and/or vulnerable adult/s in a way that indicated s/he is 
unsuitable to work with children and/or vulnerable adults. 


6.2 You should speak immediately with your - line manager or senior manager/governor who has responsibility for managing allegations.

- The senior manager will consult with/make a referral to the LADO (Local Authority Designated Officer) via the LSCB 


6.3 If one of those people is implicated in the concerns you should discuss your concerns directly with the LADO (Local Authority Designated Officer) via the LSCB

7.
Training

All stuff

7.1. All staff members will undertake safeguarding and child protection training at induction, including on whistle-blowing procedures, to ensure they understand the academy’s safeguarding systems and their responsibilities, and can identify signs of possible abuse or neglect. This training will be annually updated and will be in line with advice from our Local Safeguarding Partners.

7.2. All staff are responsible for ensuring that their individual understanding of safeguarding is up to date at all times. Staff must be aware who they should approach with concerns or questions. 


7.3. All staff will have training on the government’s anti-radicalisation strategy, Prevent, to enable them to identify children at risk of being drawn into terrorism andto challenge extremist ideas. 


7.4. Staff will also receive regular safeguarding and child protection updates (for example, through emails, e-bulletins and staff meetings) as required, but at least annually.

The Designated Safeguarding Lead and Deputy/Deputies

7.5. The DSL and Deputy/Deputies will undertake child protection and safeguarding training at least every two years. 


7.6. In addition, they will update their knowledge and skills at regular intervals and at least annually (for example, through e-bulletins, meeting other DSLs, or taking time to read and digest safeguarding policy documents and national updates). 


7.7. They will also undertake Prevent awareness training. 


8. Responsibilities

All staff

8.1. All staff will read and sign to confirm their understanding of Part 1 and Annex A of the Department for Education’s (DfE 2019) statutory safeguarding guidance, Keeping Children Safe in Education, and review this guidance at least annually.

8.2. All staff will be aware of:

• Our systems which support safeguarding, including the staff code of conduct policy, the role of the Designated Safeguarding Lead (DSL), the behaviour policy, and the safeguarding response to children who go missing from education; 


• The early help process (sometimes known as the common assessment framework) and their role in it, including identifying emerging problems, liaising with the DSL, and sharing information with other professionals to support early identification and assessment; the process for making referrals to local authority children’s social care and for statutory assessments that may follow a referral, including the role they might be expected to play; 


• What to do if they identify a safeguarding issue or a child tells them they are being abused or neglected, including statutory duties such as reporting FGM, and how to maintain an appropriate level of confidentiality while liaising with relevant professionals; 


• The signs of different types of abuse and neglect, as well as specific safeguarding issues, such as child sexual exploitation (CSE), FGM and radicalisation. 


The Designated Safeguarding Lead (DSL) 


8.3. The DSL takes lead responsibility for child protection and wider safeguarding. 


8.4. During term time, the DSL will be available during school hours for staff to discuss any safeguarding concerns. 


8.5. The contact details of the DSL and Deputy DSL and Regional Safeguarding System Leader, can be found at the front of this policy. 


8.6. When the DSL is absent, the deputy/deputies will act as cover. 


8.7. If the DSL and deputy/deputies are not available, the headteacher must arrange for appropriate cover (for example, during out-of-hours/out-of-term activities). 


8.8. The DSL will be given the time, funding, training, resources and support to provide advice and support to other staff on child welfare and child protection matters:

• Take part in strategy discussions and inter-agency meetings and/or support other staff to do so; 


• Contribute to the assessment of children; refer suspected cases, as appropriate, to the relevant body (local authority children’s social care, Channel programme, Disclosure and Barring Service, and/or police), and support staff who make such referrals directly;

• The DSL will also keep the headteacher informed of any issues and liaise with local authority case managers and designated officers for child protection concerns as appropriate. •

8.9. The role of DSL and Deputy DSL is explicit in the role holder’s job description.

Governance

8.10. The Board of Trustees and the Executive Leadership team (ELT) will approve this policy at each review. In upholding their governance function the Regional Education Director and regional team will hold the headteacher to account for its implementation. 


8.11. The Regional Safeguarding System Leader will ensure the academy contributes to multi-agency working in line with the DfE statutory guidance Working Together to Safeguard Children 2018. The academy must understand their role in the new safeguarding partner arrangements in the local authority. 


8.12. The Regional Safeguarding System Leader will monitor the effectiveness of this policy. The system leader is responsible for liaising with the headteacher and Designated Safeguarding Lead over all matters regarding child protection issues. 


8.13. The Regional Safeguarding System Leader will liaise with the headteacher and the Designated Safeguarding Lead to produce an annual report for the local authority (s175/s157).

8.14. The Regional Education Director, or when appropriate, the Deputy Regional Education Director, will act as the ‘case manager’ in the event that an allegation of abuse is made against the headteacher, where appropriate (see Appendix 3). 


The Headteacher

8.15. The headteacher, or where appropriate her/his deputy, is responsible for the implementation of this policy, including:

• Ensuring that staff (including temporary staff) and volunteers are informed of this policy as part of their induction; communicating this policy to parents when their child joins the academy and via the academy website; 


• Ensuring that the DSL has appropriate time, funding, training and resources, and that there is always adequate cover if the DSL is absent;

• Ensuring that all staff undertake appropriate safeguarding and child protection training and update this regularly; 


• Acting as the ‘case manager’ in the event of an allegation of abuse made against another member of staff or volunteer, where appropriate (see Appendix 3); 


• Ensuring the relevant staffing ratios are met, where applicable; 


• Ensuring that each child in the Early Years Foundation Stage is 
assigned a key person. 


Confidentiality 


8.16. The school has a separate policy with respect to confidentiality and data protection. This includes a list of guidelines for staff to follow to avoid breaching confidentiality. All staff must be aware that:

• Timely information sharing is essential to effective safeguarding; 


• Information must only be shared on a ‘need-to-know’ basis, but you do not need consent to share information if a child is suffering, or at risk of, serious harm; 


• Staff should never promise a child that they will not tell anyone about an allegation, as this may not be in the child’s best interests; 


• Confidentiality is also addressed in this policy with respect to record- keeping in section 11, and allegations of abuse against staff in Appendix 3. 


9. E-Safety

Slovak Learning CIC has a policy that covers the use of all ICT related activities including the use of social media, email and internet.

8.1 If you experience or are subject to any form of abuse via any form of ICT communications we take this matter very seriously and all and any incidences are required to be reported immediately

10. Mobile phones and cameras

10.1. In Slovak Learning CIC, no member of staff may use their own tablet, phone or other device to take photographs whilst children are present. Academy tablets, phones, devices may only be used in the main classroom area (not toilets or changing rooms or where children are changing their clothes) during work time when they may want a record of a child’s learning for assessment purposes. 


10.2. Staff are allowed to bring their personal phones to the academy for their own use but will limit such use to non-contact time when pupils are not present. Staff members’ personal phones will remain in their bags or cupboards during contact time with pupils. 


10.3. Staff will not take pictures or recordings of pupils on their personal phones or cameras. This includes at performance events. Headteachers and other key roles will be provided with an E-ACT mobile device. 


10.4. We will follow the General Data Protection Regulation4 which formed the Data Protection Act 2018 when taking and storing photos and recordings for use in the academy. 


11. Confidentiality

11.1 The organisation should ensure that any records made in relation to a referral should be kept confidentially and in a secure place. 
Information in relation to child protection concerns should be shared on a "need to know" basis. 


11.2 However, the sharing of information is vital to child protection and, therefore, the issue of confidentiality is secondary to the need for protection. 


12. Notifying parents

12.1. Where appropriate, we will discuss any concerns about a child with the child’s parents. The DSL will normally do this in the event of a suspicion or disclosure. 


12.2. Other staff will only talk to parents about any such concerns following consultation with theDSL. 


12.3. If we believe that notifying the parents would increase the risk to the child, we will discuss this with the local authority children’s social care team before doing so. 


12.4. In the case of allegations of abuse made against other children, we will normally notify the parents of all the children involved. 


13. Useful Slovak Learning CIC Telephone Numbers:

- Slovak Learning CIC The Chair of Governors - 07960753005


- LADO (Local Authority Designated Officer)

o For London: 020 7974 3317 (Out of Hours Tel: 020 7974 4444; https://cscp.org.uk)

o For Cambridge: 01733 864180, (Out of Hours Tel: 01733 234724, LADO@cambridgeshire.gov.uk)

- Metropolitan Police Service 0300 123 1212 


- London Safeguarding Children Board 020 7934 9714


14. Further Slovak Learning CIC policy references 


This policy is further supported by the following additional policies and guidelines; - Data Protection Policy 
 - Social Media Usage Guidelines 
 - Remore Learning Policy
 - Health & Safety Policy 
 - COVID-19 Risk Assesment Policy - Induction for New Staff 


15. Policy Review

This policy will be reviewed annually. At every review, it will be approved by the Executive Leadership Team (ELT) and the full governing board of Counsellors.