[CFS PLAYBOOK] MANAGING ALLEGATIONS

[CFS POLICY] MANAGING ALLEGATIONS

1.0 POLICY STATEMENT

Compass Forest School robustly deals with safeguarding allegations against members of Crew without prejudice and with the co-operation of external agencies where necessary. To achieve this, Crew:

• Immediately report concerns or allegations to the DSL.

• Maintain appropriate confidentiality and share information only with relevant parties.

• Provide suitable support to all involved, with welfare as the priority.

1.1 DEFINITION OF TERMS

The below table sets out a number of terms and definitions used within this document and connected documents:

Allegation; Actions of an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally.

Low Level Concern;  The things put in place for people to confidentially report incidents of bullying.

Substantiated; Sufficient evidence to prove an allegation.

Malicious; Sufficient evidence to disprove the allegation and there has been a deliberate act to deceive.

False ; Sufficient evidence to disprove the allegation

Unsubstantiated; Insufficient evidence to either prove or disprove the allegation. Does not imply guilt or innocence.

Unfounded; Reflects cases where there is no evidence or proper basis which supports the allegation being made.

Child/ren; A person under the age of 18.

Tribe ; The Compass Forest School community which includes all those directly connected - staff members, schools, parents, families and children

Parents ; Adults in a parenting role; e.g birth parents, step-parents, foster carers, adoptive parents, LA corporate parents

Crew ;  All those working for or on behalf of the school, full or part time, temporary or permanent, in either a paid or voluntary capacity

1.2 LEGAL FRAMEWORK AND STATUTORY GUIDANCE

Compass Forest School Playbooks are informed by statutory guidance, legislation and government standards that ensure the safe and effective delivery of Alternative Provision. Each Playbook interprets and applies these documents in ways specific to its area of practice.

Alternative Provision And National Standards

• Non‑School Alternative Provision Voluntary National Standards (2025/26) – The benchmark for quality, safety and outcomes in non-school settings.

• Arranging Alternative Provision (DfE) – Statutory guidance for LAs and schools on commissioning and reintegration.

• Education Acts 1996 & 2002 (Parts 3, 6, 7) – Legal duties for suitable education and pupil registration.

• School Attendance (Pupil Registration) (England) Regulations 2024 – Mandatory requirements for daily attendance reporting and digital registers.

Safeguarding And Child Welfare

• Keeping Children Safe in Education (KCSIE 2026) – Primary statutory guidance for safeguarding, including Operation Encompass and Filtering/Monitoring duties.

• Working Together to Safeguard Children (2026) – Multi-agency guidance for identifying, responding to and preventing harm.

• Children Act 1989, 2004, 2006 – Core legal frameworks for care and protection of children.

• SEND Code of Practice (2015) – Guidance for supporting children with Education, Health and Care Plans (EHCPs) and SEMH needs.

• Prevent Duty (Counter-Terrorism and Security Act 2015) – Duty to protect children from radicalisation and extremism.

• Female Genital Mutilation (FGM) Act 2003, Section 5B – Duty to report FGM in girls under 18.

Behaviour, Restraint And Seclusion

• The Schools (Recording and Reporting of Seclusion and Restraint) Regulations 2025 – Statutory Duty (Effective April 2026): Mandatory same-day written reporting to parents for any restrictive intervention.

• Education and Inspections Act 2006 (Section 93A) – The legal power to use reasonable force, strictly governed by the 2026 statutory duty.

• Education and Inspections Act 2006, Sections 88–94 – Legal requirements for behaviour, engagement, prevention of bullying and discipline policies.

Health, Safety And Medical Management

• Health and Safety at Work etc. Act 1974 – General duty of care for staff, pupils and visitors.

• Management of Health and Safety at Work Regulations 1999 – Requirement for robust risk assessments, preventive measures, appropriate information, instruction and training.

• Supporting Pupils with Medical Conditions (DfE Statutory Guidance) – Requirements for Individual Healthcare Plans (IHPs) and the safe administration/storage of medication.

• Health and Safety (First-Aid) Regulations 1981 – Provision of first-aid equipment, trained personnel and procedures.

• Work at Height Regulations 2005 – Safe practice for climbing, ropes and platform work.

• RIDDOR 2013 – Mandatory incident reporting and record-keeping of serious injuries and dangerous occurrences.

• Control of Substances Hazardous to Health (COSHH) Regulations 2002 – Safe handling, storage and use of hazardous substances (fuels, cleansers, etc.)

Environmental Stewardship

• Environmental Protection Act 1990 (Section 34) – Duty of Care: Legal responsibility for safe waste management and fire safety (ash/embers/waste).

• Wildlife and Countryside Act 1981 – Legal duty to protect habitats, nesting birds, and protected species during sessions.

• Regulatory Reform (Fire Safety) Order 2005 – Fire risk management and outdoor campfire precautions.

• DfE Health and Safety Guidance (2022) – Managing fire risks, emergency procedures and staff responsibilities.

Compliance And Governance

• School Staffing (England) Regulations 2009 – Safer recruitment and Single Central Record (SCR) duties.

• Childcare Act 2006 – Legal framework for Ofsted registration and compliance with the Compulsory and Voluntary Childcare Register including written procedures for handling complaints and maintaining records of complaints.

• Rehabilitation of Offenders Act 1974 – Governs employment eligibility and the filtering of people with convictions.

Compass Forest School works in line with the safeguarding arrangements agreed and published by the local safeguarding partners. Statutory guidance identifies three safeguarding partners with responsibility for making arrangements to safeguard and promote the welfare of children within a local area.

These partners work together to identify and respond to the needs of children at risk of harm:

• The local authority (LA)

• An integrated care board for an area within the LA

• The chief officer of police for a police area in the LA area

Keeping Children Safe in Education makes clear that schools placing children into Alternative Provision retain responsibility for safeguarding those children.

Client schools must ensure that the provision is suitable, meets the child’s needs and provides appropriate safeguarding arrangements, with regular oversight, communication and review.

Compass Forest School supports this responsibility through transparent communication and timely sharing of safeguarding information with Client schools.

1.3 DATA PROTECTION

Compass Forest School processes personal data in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and related legislation. Personal information is collected, stored, used and shared lawfully, securely and proportionately, in accordance with statutory guidance and Data Protection Playbook.

Crew are responsible for ensuring that personal data is handled accurately, confidentially and on a need-to-know basis. Safeguarding and public interest considerations may override confidentiality where this is lawful, necessary and proportionate.

1.4 DISCLOSURE OF INFORMATION

Any use or disclosure of information held by Compass Forest School must have a clear and lawful basis. Unauthorised or unlawful disclosure of personal data may constitute a criminal offence under the Data Protection Act 2018.

All Crew must understand their responsibilities in relation to confidentiality, lawful information sharing and subject access rights under UK GDPR. Information will be shared without consent where there is a lawful basis to do so.

The Data Protection Act 2018 and UK GDPR are not barriers to sharing information where there is a concern that a child may be at risk of significant harm. Where there is uncertainty about whether information should be shared, advice must be sought from a senior leader or Designated Safeguarding Lead before disclosure.

1.5 STATEMENT OF EQUALITY

Compass Forest School is committed to equality, diversity and inclusion in accordance with the Equality Act 2010. Discrimination, harassment and victimisation are not tolerated. Many children attending Compass Forest School experience additional vulnerabilities or barriers to participation, safety or wellbeing.

These may include special educational needs or disabilities, experiences of discrimination, family or environmental adversity, risk of exploitation or abuse, being looked after or previously looked after, or instability in education or care arrangements.

Crew proactively identify and reduce inequality by making reasonable adjustments, adapting practice and ensuring that decisions are fair, proportionate and responsive to individual need. All children and Crew are treated with dignity and respect and are supported to feel safe, valued and heard.

[CFS PROCESSES] MANAGING ALLEGATIONS

2.0 PROCESSES STATEMENT

Compass Forest School takes its responsibility of caring for children seriously and fully endorses the principles and practice of safeguarding and child protection. Crew recognise that children can be vulnerable to harm and abuse in many settings including those where adults occupy ‘positions of trust’. A legal term meaning regular and direct contact with children.

Where an allegation or concern that a member of Crew has behaved in a way that has harmed, or may have harmed a child must be taken seriously and promptly dealt with via a thorough investigation. Any investigation must follow the local and national statutory guidance and legislation. Allegations will not be dealt with under the Company’s general complaints procedure.

All Crew have a duty to safeguard pupils and create a safe learning environment where robust processes deal effectively with any allegations of harm or abuse by a Crew member or volunteer against a child. The Company, as an employer, also has an equal duty of care to Crew, ensuring any individual whom an allegation has been made are treated fairly and provided with effective support.

Compass Forest School identifies eleven core Processes that support Crew in meeting policy aims and statutory responsibilities surrounding Managing Allegations. These are:  Defined Roles And Responsibilities, Managing Allegations Training, Prevention of Allegations, Reporting An Allegation, Investigating An Allegation, Responding To An Allegation, Supporting Those Who Have Made An Allegation, Supporting Those That Have An Allegation Made Against Them, Outcome Of An Allegation Investigation, Confidentiality And Information Sharing For Safeguarding and managing Low Level Concerns.

Each process is underpinned by clear procedures that provide practical guidance and ensure a consistent, proportionate and effective approach to Safer Recruitment.

2.1 DEFINED ROLES AND RESPONSIBILITIES

Clear roles and responsibilities help Crew act quickly, confidently and consistently when everyone understands what they must do and who to pass concerns to. Issues are then identified earlier, decisions are made properly, actions are recorded accurately and effective oversight is maintained at every level of the company.

Defined responsibilities sit with the owner, relevant senior leaders, the Designated Safeguarding Lead (DSL) and all Crew. While some roles carry additional authority and accountability, responsibility is shared. No concern is ever “someone else’s job”. No child or adult should be left at risk because someone assumed another person would act.

Everyone has a duty to speak up, pass on concerns and challenge unsafe practice, poor judgement or wrongdoing in a professional and respectful way. This shared responsibility is critical to identifying risks early and preventing harm wherever reasonably practicable. Within an Alternative Provision context, Compass Forest School places strong emphasis on prevention.

Crew support children to develop the skills, confidence and understanding needed to stay safe and thrive. This is reinforced through clear Playbooks, training, consistent day-to-day practice and oversight by the Designated Safeguard Lead and Deputy. Arrangements are reviewed regularly and updated in line with statutory guidance to ensure practice remains current, effective and proportionate.

2.2 MANAGING ALLEGATIONS TRAINING

Compass Forest School ensures that all Crew receive training on managing allegations as part of their safeguarding responsibilities. This training helps them recognise inappropriate behaviour, understand how to report concerns, maintain professional boundaries, and follow legal requirements under KCSIE 2024 and other relevant statutory guidance and laws. Training is refreshed annually and whenever guidance changes.

2.3 PREVENTION OF ALLEGATIONS

Preventing concerns or allegations is a priority at Compass Forest School. The Company sets clear expectations for conduct, promotes transparent communication between Crew, children, and families, ensures supervision in all interactions, and follows safe recruitment practices. Including DBS checks and thorough vetting in line with statutory requirements.

2.4 REPORTING AN ALLEGATION

If an allegation is made that a Crew member has:

• behaved in a way that has harmed, or may have harmed a child.

• possibly committed a criminal offence against, or related to, a child.

• behaved towards a child or children in a way that indicates they may pose a risk of harm to children.

• behaved in a way that indicates they may not be suitable to work with children.

It should be reported immediately to the Designated Safeguarding Lead (DSL) or deputy and record details accurately on the Company’s intranet. Crew must not discuss the allegation with others, except with the appropriate authorities. If needed, they can refer to the CFS Whistleblowing Playbook.

2.5 INVESTIGATING AN ALLEGATION

Investigations follow KCSIE 2024 and other legal guidance. Once a concern or allegation has been made, a case manager will be assigned to lead the investigation. The case manager will be the DSL or, where the DSL is the subject of an allegation, the Deputy DSL. The Case manager will conduct a basic enquiry to establish the facts to help them determine whether there is any foundation to the allegation. If necessary, the allegation is referred to external agencies like the LADO, police, or social services. If required, temporary adjustments, such as suspension, may be made to protect those involved.

2.6 RESPONDING TO AN ALLEGATION

Compass Forest School follows a structured response when handling allegations. An immediate risk assessment is conducted, and safeguarding measures are put in place. Relevant authorities, such as the LADO, Ofsted, and DBS, are informed when required. The company ensures support for all parties while keeping matters confidential. All decisions and actions are documented.On referral to LADO, a discussion will be held around the nature, content and context of the allegation and decide if:

No further action is needed including harm threshold not met.A strategy discussion should take place.There should be involvement from the police and/or children’s social care.

If the allegation is about physical contact, e.g. restraint, the strategy discussion or initial evaluation with the LADO will take into account that Crew are entitled to use reasonable force to control or restrain children in certain circumstances where a child places themselves in real and immediate danger.

2.7 SUPPORTING THOSE WHO HAVE MADE AN ALLEGATION

The welfare of children involved in an allegation will be paramount. Compass Forest School provides emotional and practical support to those who report allegations, ensuring they feel safe and heard. They are guided to restore safety, confidence and self esteem through tailored support, such as counseling or parental involvement. Where needed, external advocacy services are offered. The company protects individuals and close family from retaliation or victimisation and keeps them informed about the progress of the investigation, outcome and action taken when appropriate. The case manager will work with the LADO to agree who should be informed about the allegation.

2.8 SUPPORTING THOSE WHO HAVE HAD AN ALLEGATION MADE AGAINST THEM

Where an allegation is made against a Crew member, Compass Forest School ensures they are treated fairly and with respect Confidentiality is maintained as much as possible, and welfare support such as union representation or counseling is offered as part of the Company’s duty of care. The Company will communicate next steps clearly and ensure a fair process.

2.9 OUTCOME OF AN ALLEGATION INVESTIGATION

Outcomes vary depending on the findings:

If substantiated, appropriate action is taken, including possible referral to the DBS or legal authorities.

If unsubstantiated or unfounded, no evidence of wrongdoing is found, and the individual may return to their role.

If malicious, no action is taken against the accused, and support is provided.

If false, no wrongdoing is found, and processes are reviewed to prevent similar occurrences in the future.

The options available to the Company will depend on the nature and circumstances of the allegation and the evidence and information available.

2.10 CONFIDENTIALITY AND INFORMATION SHARING FOR SAFEGUARDING

Safeguarding takes precedence over privacy and GDPR compliance. Compass Forest School follows statutory guidance and legislation, adhering to DBS and LADO protocols for handling sensitive information. All safeguarding reports are securely stored, and access is controlled to maintain confidentiality. Child protection information will be stored separately from the child’s school file.

Confidentiality will also be maintained to ensure a fair investigation can be undertaken.All parties involved in an allegation will be made aware of the requirement to maintain confidentiality and guard against unwanted publicity about any allegations made against Crew whilst investigations are in progress.

Breaches in confidentiality will be taken seriously and may warrant a separate investigation. The Company will not provide the media with any information regarding an allegation. Crew should not assume a colleague or another professional will take action and share information that might be critical in keeping children safe.

They should be mindful that early information sharing is vital for effective identification, assessment and allocation of appropriate service provision, whether this is when problems are first emerging, or where a child is already known to local authority children’s social care (such as on a Child In Need or child protection plan).

2.11 MANAGING LOW LEVEL CONCERNS

Compass Forest School encourages Crew to report low-level concerns, no matter how small, to maintain a culture of safeguarding. A low-level concern is any behaviour by a Crew member that does not meet the threshold for an allegation but is inconsistent with the Crew Code Of Conduct and could indicate a pattern of inappropriate conduct.

Crew members should report concerns to the DSL, who will assess and determine if further action is needed. Regular reviews help identify potential issues early. The company fosters a culture where Crew feel comfortable reporting concerns without fear of reprisal, ensuring a safe environment for all.

2.12 RECORD KEEPING

High-quality record keeping underpins safeguarding, accountability and continuous improvement across Compass Forest School. Crew maintain accurate, timely and secure records of concerns, incidents, accidents, decisions and actions to ensure risks are identified, managed and reviewed effectively.

Records are factual, clearly dated, and attributable, written in professional, objective language. They distinguish facts, professional judgement, and actions taken, avoiding assumptions, emotive language, or unsubstantiated conclusions. All relevant matters are recorded without delay on Compass Forest School’s secure 'LearnTrek' system.

Records may support the identification of patterns, trends or emerging risks to inform learning, oversight and proactive planning. Crew are expected to seek guidance from the relevant Designated Lead if unsure whether to record an issue. Records are stored and managed in line with UK GDPR, the Data Protection Act 2018, and other applicable legislation.

Access is restricted to those with a legitimate professional role and information is shared strictly on a need-to-know basis. Records are retained in accordance to statutory requirements and recognised best practice. They are reviewed regularly to support transparency, learning, accountability and the continuous improvement. Crew are accountable for maintaining records that reflect the highest professional standards.

2.13 WHISTLEBLOWING

Compass Forest School creates a culture where concerns can be raised openly, honestly and in good faith, without fear of reprisal or victimisation. Crew have a professional duty to report concerns about the conduct, behaviour or practice of colleagues or the organisation where children, Crew or others may be at risk.

Safeguarding concerns must be reported immediately to the Designated Safeguarding Lead (DSL) or Deputy DSL. If the concern relates to the DSL, it must be raised via the independent whistleblowing service, SafeCall (0800 915 1571). Crew must never investigate concerns themselves or delay reporting. Failing to report, regardless of personal relationships or perceived seriousness, may be regarded as condoning unsafe practice.

Where appropriate, concerns should be documented factually before or during reporting. All reports are treated seriously, confidentially and investigated promptly. Whistleblowing is a vital safeguarding mechanism and forms part of Compass Forest School’s commitment to transparency, accountability, and child-centred practice.

2.14 MONITORING ARRANGEMENTS

This Playbook is reviewed at least annually by the Owner and Designated Safeguarding Lead to ensure it remains effective, compliant and aligned with best practice and statutory guidance. Reviews also consider feedback from Crew, families and Client schools. Playbooks are updated immediately in response to changes in legislation or guidance. Monitoring ensures the Playbook continues to support safe, personalised, and effective provision for all learners.

2.15 LINKS TO OTHER PLAYBOOKS OF RELEVANCE

Compass Forest Schools Managing Allegations Playbook links to the following Playbooks :

Safeguarding and Child Protection

Safer Recruitment
Health And Saf