Safeguarding and Child Protection Policy

Organisation address: Cramp Hill, Darlaston, Walsall, WS10 8ES
Telephone: 0121 8190 311 / 07424 590 311
Email: info@khalsapanthacademy.com
Website: www.khalsapanthacademy.com

Important status note:

Khalsa Panth Academy is an after-school and weekend supplementary education and tuition centre. It is not a full-time school, independent school, academy school, college or alternative provision. Children and young people remain enrolled at their own mainstream school or education provider. KPA does not replace compulsory school education.

This policy applies to activities delivered by Khalsa Panth Academy in person, online, at events, during workshops and during educational visits. It also applies to trustees, staff, tutors, instructors, volunteers, contractors, visitors and anyone acting on behalf of the Academy.

Document control

Approval statement

The trustees approve this policy and confirm that safeguarding is a standing governance priority. The trustees will review safeguarding practice, training, incidents, recruitment checks and the safeguarding risk register regularly. Although a named safeguarding lead is listed for day-to-day reporting, safeguarding remains under collective trustee oversight and no one trustee will dominate safeguarding decisions or the work of the Academy.

1. Policy statement

Khalsa Panth Academy is committed to keeping children, young people and adults at risk safe from harm. Safeguarding is part of our Sikh values of respect, service, dignity and care for others.

We will take reasonable steps to protect people who come into contact with the Academy through our classes, tuition, Sikh education, Gurmat Sangeet, Punjabi language, Gatka as Sikh heritage learning, events, workshops, volunteering and community activities.

Under no circumstances may any trustee, staff member, tutor, instructor, volunteer, contractor or visitor inflict physical harm, emotional harm, psychological harm, humiliation, bullying, discrimination or abuse on a child, young person or adult at risk.

All concerns must be taken seriously, recorded properly and reported through the safeguarding route without delay.

2. Who this policy protects

This policy protects:

• children and young people under the age of 18;
• adults at risk, including adults who may need care or support and may be unable to protect themselves from abuse or neglect;
• students, parents, carers, staff, volunteers, trustees, visitors and community members who come into contact with the Academy.

3. Setting type and activities

KPA provides structured, part-time, supplementary education and tuition. It runs outside normal school education and does not provide full-time education or childcare as its main purpose. The Academy will keep its registration position under review and will seek advice if any future activity could require Ofsted registration, separate registration or approval.

The Academy may provide structured learning in:

• Gurbani, Sikh teachings, Sikh history, Sikh values and Sikh heritage;
• Gurmat Sangeet, Kirtan, Tabla, Harmonium and Sikh musical instruments such as Dilruba, Sarangi, Taus, Tota Sarangi, Taar Shehnai, Israj and Sitar;
• Punjabi language, including reading, writing, speaking and understanding;
• Gatka as Sikh heritage learning, delivered with discipline, safety, respect and cultural understanding;
• supplementary tuition such as 11 Plus, GCSE and A-level support where suitable tutors are available;
• workshops, talks, performances, visits and youth learning linked to the Academy purposes.

4. Legal and guidance framework

This policy has been prepared with regard to the current law and guidance relevant to the Academy as an after-school and weekend supplementary education and tuition centre. This includes:

• Charity Commission guidance: Safeguarding and protecting people for charities and trustees;
• Department for Education guidance: After-school clubs, community activities, and tuition – Safeguarding guidance for providers running out-of-school settings, February 2026;
• Working Together to Safeguard Children 2026;
• Keeping Children Safe in Education 2026, considered as good practice where relevant. KPA is not a school or college and is not presenting itself as one;
• Children Act 1989 and Children Act 2004;
• Safeguarding Vulnerable Groups Act 2006 and Protection of Freedoms Act 2012;
• Care Act 2014 for safeguarding adults at risk;
• Counter-Terrorism and Security Act 2015 and the Prevent duty, where relevant;
• Equality Act 2010;
• Data Protection Act 2018 and UK GDPR;
• Disclosure and Barring Service guidance, eligibility rules and code of practice;
• Walsall Safeguarding Partnership and Walsall Council referral routes.

5. Roles and responsibilities

Trustees

The trustees are responsible for the overall safeguarding culture and governance of the Academy. They will:

• make safeguarding a standing agenda item at trustee meetings;
• approve and review this policy and related procedures;
• ensure there is a suitably trained DSL and a clear alternate reporting route if the DSL is unavailable or involved in a concern;
• ensure safer recruitment, DBS checks and suitability checks are followed;
• review the safeguarding risk register regularly;
• ensure concerns are referred to the correct external agency where required;
• make Charity Commission serious incident reports where required, once registered;
• act together as a board and not allow one trustee to dominate safeguarding decisions.

Designated Safeguarding Lead

The DSL has day-to-day lead responsibility for safeguarding. The DSL will:

• receive and record safeguarding concerns;
• give guidance to staff and volunteers;
• make referrals to Walsall MASH, LADO, police, DBS or adult safeguarding services where required;
• keep secure safeguarding records;
• ensure staff and volunteers receive safeguarding induction and refresher training;
• report safeguarding themes, risks and training needs to trustees, while keeping personal details confidential where appropriate.

Deputy DSL / alternate safeguarding contact

The Deputy DSL or alternate safeguarding contact supports the DSL where appointed. If the concern is about the DSL or Safeguarding Trustee, the matter must be reported to another trustee not involved in the concern, or directly to Walsall MASH, LADO or the police where urgent. Concerns must not be delayed because the DSL is unavailable.

Staff, tutors, instructors and volunteers

All adults working with or around learners must:

• read and follow this policy and the code of conduct;
• complete induction and safeguarding training suitable for their role;
• treat all learners with dignity and respect;
• avoid unsafe one-to-one situations and maintain professional boundaries;
• report concerns to the DSL as soon as possible;
• never promise confidentiality to a child who discloses abuse or harm;
• never investigate safeguarding concerns themselves unless asked to do so by a statutory agency or the trustees as part of a safe process.

Parents, carers and learners

Parents and carers will be told how to raise a safeguarding concern. Learners will be encouraged to speak to a trusted adult, tutor, DSL or parent if they feel unsafe or worried. Emergency contact, medical and collection details must be kept up to date.

6. Safer recruitment and suitability checks

KPA will take reasonable steps to check that people are suitable for their roles before they work with children, young people or adults at risk.

The checks will be proportionate to the role and may include:

• application or role information;
• identity checks;
• right to work checks where relevant;
• qualification and experience checks where relevant;
• at least two references where suitable;
• interview or meeting questions covering safeguarding and conduct;
• appropriate DBS checks for eligible roles, following current DBS eligibility guidance;
• enhanced DBS with children barred list information where the role is in regulated activity and the law allows this check;
• risk assessment and trustee approval where any issue arises from a check or reference.

KPA will not knowingly allow a barred person to work in regulated activity with children or adults at risk. Where DBS information is used, KPA will handle it securely, fairly and in line with the DBS Code of Practice and data protection rules.

Visitors, guest speakers, contractors and occasional helpers will be supervised unless the trustees and DSL are satisfied that appropriate checks and controls are in place. Young volunteers under 18 remain children for safeguarding purposes and will be supervised.

7. Training and awareness

All trustees, staff, tutors, instructors and regular volunteers must know about safeguarding and people protection. KPA will provide:

• safeguarding induction before or at the start of their role;
• access to this policy and related procedures;
• role-appropriate safeguarding refresher training at least annually;
• DSL and trustee safeguarding training at a suitable level, normally refreshed regularly and recorded;
• awareness of reporting routes, whistleblowing, online safety, safer recruitment, Prevent, child-on-child abuse, SEND, one-to-one teaching and shared premises arrangements.

Training records will be kept and reviewed by the trustees.

8. Types and signs of abuse

Staff and volunteers must be alert to abuse and harm that may happen in person, at home, in the community or online. Concerns may include:

• physical abuse;
• emotional abuse;
• sexual abuse;
• neglect;
• domestic abuse and the impact on children;
• bullying and child-on-child abuse, including online bullying;
• child sexual exploitation and child criminal exploitation;
• harmful sexual behaviour;
• radicalisation or extremism concerns;
• online abuse, grooming, inappropriate communication or unsafe sharing of images;
• discrimination, harassment or hate incidents;
• self-harm or serious mental health concern;
• abuse or neglect of adults at risk.

A concern does not need to be proved before it is reported. If anyone is unsure, they must speak to the DSL.

9. Responding to a child or adult who discloses abuse

If a child, young person or adult at risk tells a member of staff or volunteer about abuse or harm, the adult must:

• listen calmly and take them seriously;
• avoid leading questions and do not investigate;
• reassure them they have done the right thing by speaking up;
• explain that the concern must be shared with the DSL and may need to be shared with safeguarding agencies;
• record the words used as accurately as possible, including date, time, place and people present;
• report to the DSL as soon as possible, and immediately if there is risk of harm.

If someone is in immediate danger or a crime is happening, call 999 without delay.

10. Reporting and referral procedure

KPA will use the following safeguarding route:

1. The person who notices or receives the concern records the facts and reports to the DSL as soon as possible.
2. The DSL reviews the concern, checks immediate safety and decides whether to contact parents or carers, unless doing so could increase risk.
3. Where a child may be at risk of harm, the DSL contacts Walsall MASH or the police as appropriate.
4. Where the concern relates to an adult at risk, the DSL contacts Walsall Adult Safeguarding or the police as appropriate.
5. Where the concern is about a staff member, trustee, volunteer, contractor or other adult working with children, the DSL contacts the Walsall LADO for advice.
6. All decisions, actions and reasons are recorded securely.
7. Trustees are informed of safeguarding matters at an appropriate level, without unnecessary sharing of personal details.

If a staff member or volunteer believes a child is at risk and the DSL or trustees have not acted properly, they may contact Walsall MASH, the LADO, police or NSPCC directly.

11. External safeguarding contacts

These external contact details must be checked at least annually and whenever this policy is reviewed.

12. Allegations or concerns about staff, volunteers or trustees

Any allegation or concern that an adult working with children may have harmed a child, behaved in a way that may harm a child, committed a criminal offence against or related to a child, or behaved in a way that raises concern about suitability must be referred to the DSL immediately.

If the allegation is about the DSL or Safeguarding Trustee, it must be reported to another trustee not involved in the concern, or directly to Walsall MASH, the LADO or the police where urgent. If the allegation is about a trustee, the remaining non-conflicted trustees must manage the matter and seek external advice where required.

The DSL or trustees will contact the LADO for advice before taking internal action, unless emergency action is needed to protect a child. The person subject to the concern will not investigate the matter. KPA will cooperate with statutory agencies and will consider suspension, temporary role changes or supervision where needed to protect children while a matter is considered.

Where required by law, KPA will make a referral to DBS and, once registered, will consider whether a serious incident report must be made to the Charity Commission.

13. Child-on-child abuse and behaviour

KPA will not dismiss harmful behaviour between children as normal banter. Child-on-child abuse may include bullying, online abuse, harassment, physical harm, sexual comments, harmful sexual behaviour, threats, sharing images or intimidation.

Staff must report concerns to the DSL. The DSL will consider support for the child harmed, the child who caused harm, and any other children affected. Parents may be informed unless doing so increases risk. External agencies will be contacted where the concern reaches safeguarding threshold or a crime may have been committed.

14. One-to-one teaching, music tuition and professional boundaries

Some music, language or tuition support may need one-to-one or small group teaching. KPA will manage this safely.

• One-to-one teaching must be approved by the Academy and known to parents or carers.
• Sessions should take place in a visible or accessible space, such as a room with a window, open door, or nearby adult presence where practical.
• Adults must avoid unnecessary physical contact. Any instruction involving posture, instrument position or Gatka movement must be explained first and handled respectfully.
• Staff must not meet learners privately outside approved Academy activity.
• Staff must not contact children directly through personal social media, private messaging or personal phone unless there is an emergency or clear written parental consent and Academy approval.
• Communication about classes should normally be with parents or carers, using official Academy channels.

15. Online safety and communication

KPA will manage online safety even where children do not have unsupervised internet access during a session.

• Online classes, if used, must be approved and supervised appropriately.
• Meeting links must be sent to parents or carers, not directly to children where possible.
• Recording of online sessions requires prior approval and consent.
• Staff and volunteers must not share inappropriate content or communicate privately with learners.
• Concerns about online abuse, grooming, bullying or unsafe sharing of images must be reported to the DSL.
• Phones and cameras must not be used in changing/toilet areas or in any way that compromises dignity or privacy.

16. Attendance, collection and missing child procedure

• KPA will keep attendance records for classes and activities.
• Parents and carers must provide emergency contact details, medical information and authorised collection details for children.
• Children should only leave with an authorised adult unless written permission has been given for independent travel.
• If a child is unexpectedly absent, staff may contact the parent or carer where appropriate.
• If a child goes missing during an Academy activity, staff must alert the DSL or lead tutor, search safe areas, contact parents and call police if the child is not found quickly or there is concern for safety.
• A missing child incident must be recorded and reviewed.

17. Health, first aid, medical needs and accidents

KPA will keep emergency contact details and known medical or allergy information for children. A first aid kit will be available and a first aid lead will be identified. Accidents, injuries and near misses will be recorded and reviewed.

Medication will not normally be administered unless agreed in writing with parents or carers and recorded. Emergency services will be contacted where urgent medical help is needed. If children aged 5 or under attend, the trustees will ensure suitable paediatric first aid arrangements and will review any childcare registration duties that may apply.

18. Gatka and physical activity safety

Gatka is delivered as Sikh heritage learning and personal development, not as a separate sports club. Any Gatka or physical movement activity must be supervised, risk assessed and delivered safely.

• Learners must follow instructor instructions and safety rules.
• Equipment must be suitable, checked and used only under supervision.
• Unsafe behaviour, aggression, bullying or misuse of equipment will not be tolerated.
• Instructors must adapt activities to age, ability, health needs and experience.
• Injuries or safeguarding concerns must be reported and recorded.

19. Shared premises, visitors and separate organisations

KPA may operate from premises where a separate organisation has its own office or signage. This does not make that organisation part of KPA.

Any separate office area, including an office used by another organisation, must remain separate from KPA teaching and safeguarding arrangements. Staff, visitors or representatives of another organisation must not supervise KPA learners, access KPA learner records, enter teaching areas without permission, or have unsupervised contact with children unless KPA has completed suitable checks and authorised the role.

Visitors, contractors and guest speakers must sign in where practical, be identifiable, and be supervised unless the trustees and DSL are satisfied that proper checks and controls are in place. Any concern about an unknown adult or visitor must be reported to the DSL immediately.

20. Photography, video and media

• Written parent or carer consent will be obtained before using identifiable images or videos of children for publicity, website, social media or promotional material.
• Children will not be named in full with images unless there is a clear reason and consent.
• Images must be respectful and must not place a child at risk or embarrassment.
• Parents taking photos or videos at events must follow Academy guidance and must not publish images of other children without permission.
• Any concern about inappropriate photography, filming or sharing must be reported to the DSL.

21. SEND, inclusion and reasonable adjustments

KPA will treat children and adults fairly and with respect. The Academy will make reasonable adjustments where possible for learners with special educational needs, disabilities, medical needs, communication needs or other vulnerabilities.

Where extra support is needed, KPA may ask parents or carers for information to help plan safe participation. Personal care is not normally provided by KPA. If any personal care need arises, it must be discussed with parents, risk assessed and approved by trustees before the arrangement starts, except in a genuine emergency.

22. Prevent and harmful influences

KPA will be alert to concerns about radicalisation, extremism, coercion, grooming, hate, intolerance or harmful influence. Staff and volunteers will be expected to report concerns to the DSL. The DSL will seek advice or make referrals through local safeguarding routes where required.

Faith-based teaching at KPA must be delivered with respect, care and public benefit. It must not promote hatred, violence, abuse, unlawful discrimination or harm.

23. Safeguarding adults at risk

Although KPA mainly works with children and young people, some adults may also be at risk due to age, disability, illness, care needs, mental health, language barriers, isolation or other circumstances.

Concerns about an adult at risk must be reported to the DSL and, where appropriate, to Walsall Adult Safeguarding, police or emergency services. The adult should be involved in decisions where possible, but safeguarding action can be taken without consent where there is serious risk, coercion, crime, or risk to others.

24. Record keeping, confidentiality and data protection

• Safeguarding records will be factual, dated, signed or named, and kept securely.
• Records will include the concern, actions taken, referrals made, decisions and reasons.
• Safeguarding information will only be shared with those who need to know, or where required to protect a child or adult at risk.
• KPA will follow Data Protection Act 2018 and UK GDPR requirements.
• Safeguarding records will be kept separately from general learner records where practical.
• Records will be retained securely for an appropriate period and disposed of safely when no longer required.

25. Complaints and whistleblowing

KPA will have a clear complaints route for parents, carers, learners, staff, volunteers and visitors. Safeguarding complaints will be treated as safeguarding concerns and referred to the DSL.

Staff, volunteers and trustees must speak up if they believe safeguarding practice is unsafe, a concern has not been handled properly, or someone is being allowed to work unsafely with children. Concerns can be raised with the DSL, another trustee not involved in the concern, Walsall MASH, LADO, police, NSPCC or Charity Commission where appropriate.

26. Safeguarding risk register and trustee review

KPA will keep a safeguarding risk register. The register will identify safeguarding risks, control measures, responsible persons, review dates and actions needed. The trustees will review the register at least termly, and sooner after a serious incident, complaint, change in activity, change in premises use, or change in law or guidance.

The safeguarding risk register will cover, where relevant:

• one-to-one teaching and music tuition;
• shared premises and separate office areas used by other organisations;
• drop-off, collection and missing child risks;
• online contact and use of social media or WhatsApp;
• photography and filming;
• Gatka and physical movement activities;
• visitors, contractors and guest speakers;
• SEND, medical needs and allergies;
• recruitment, DBS checks and supervision;
• safeguarding records and data protection.

27. Review of this policy

This policy will be reviewed at least annually and sooner if there is a safeguarding incident, serious complaint, change in law or guidance, change in activities, change in premises use, or trustee decision requiring review. Updates will be approved by trustees and shared with staff and volunteers.