Since the early days of school inspections it has been a school’s responsibility to have proper procedures relating to child protection. A co-ordinated set of minimum standards was first introduced for boarding schools in 2002
At its core was the requirement for every school to have a “designated senior member of staff” responsible for safeguarding, including liaising with appropriate authorities such as social services and the police. In many senses, therefore, the role of Designated Safeguarding Lead (DSL), or equivalent, has been with us for at least 20 years and, in some form or another, in all regions of the UK.
More recent is the inexorable development of the scope and depth of the responsibility and the fact that many DSLs cannot now reasonably fulfil the role without a considerable team of deputies and other welfare staff around them. Central to this has been the move away from a focus solely on child protection – the basic duty to protect children from significant harm – towards a much broader duty to focus on child wellbeing, as rooted in section 10 (2) of the Children Act. In a sense, therefore, DSLs now find themselves with prime responsibility for every aspect of the welfare of pupils in the school.
Complex issues
Not only has the scope of the role grown, but the nature of the issues being dealt with has also evolved. Although many schools work very hard on their key relationships with local safeguarding experts and partners, it is clear that independent schools are now themselves responsible for picking up much of the engagement which would previously have been called ‘early help’ given that certain services, particularly around mental health, are very difficult to access because of a hugely increased demand and a much reduced capacity.
“Not only has the scope of the role grown, but the nature of the issues being dealt with has also evolved.”
Recording and reporting requirements have also grown in complexity, as have the complicated discussions around who has a “need to know” critical information. This has been hugely helped by the range of very effective and well-constructed software packages which pick up much of the burden. But, of course, any information system is only as good as the data which is input in the first place. Equally, they only perform effectively if they have been properly calibrated to ensure communication is fluent and that evolving concerns and patterns of behaviour can be tracked appropriately.
Also adding to the burden has been the reduced availability of good quality training provided by local partners, and the subsequent need for DSLs to source or deliver the training content themselves. Equally frustrating can be the complexities of working across different police and local authority boundaries, where the same paperwork can sometimes be required by different agencies in different formats and on different forms, and sometimes with different thresholds for action. The sometimes maligned “Common Assessment Framework” was never ideal but was at least a step in the right direction.
Appropriate status and authority
With the role having evolved so much, and in so many different ways, schools have had to respond rapidly to developments. It is unfortunate, but perhaps not surprising, that a few schools have been left behind by the pace of these changes.
However, the expectations of the role of a DSL are very clear, not only in terms of evolving practice but also the requirements for the post-holder to have “appropriate status and authority within the school to carry out the duties of the post” and to be given the “time. funding, training, resources and support” they need to carry out the role. Obviously, many schools spread this responsibility across a wider team, including a number of deputy DSLs (DDSLs), but it is crucial that the core responsibility, particularly for child protection decisions, remains with the designated lead.
Key questions schools may consider when crafting the role of a DSL can include:
Must the DSL be on the senior leadership team? In England and Wales it is a core requirement for the DSL to be on the leadership team. It is good practice for all schools.
Should the DSL be a teacher? This will depend on circumstances. In many schools all senior appointments are members of the academic staff, so the designated lead will be too – often a Deputy Head Pastoral or similar. In other schools the role will be a standalone with no additional responsibilities. The fundamental requirement is for the person to have sufficient time and resources to fulfil the role successfully.
Must the DSL be available 24/7? The requirement is for a DSL or deputy to be available all the time in school hours in term time. This is more complex with independent and boarding schools, and it is frequently the case that someone on the team will indeed be contactable 24/7. It is also essential for there to be proper cover available during any holiday trips and activities.
Must the DSL be on site? It is not a specific requirement for a DSL to be resident or even on site. Each school must risk assess what is necessary and appropriate. A school with a large number of boarding pupils would probably choose to have a member of the DSL team on site at all times. Day schools, or those with very few boarders, might make other arrangements. The key thing is for all staff at all times to know how to contact someone if they have any concerns.
“A school with a large number of boarding pupils would probably choose to have a member of the DSL team on site at all times”
What level of training do the DSL and deputies need? The key requirement is for training to provide all members of the team with the knowledge and skills to carry out the role effectively. For England, Annex C of Keeping Children Safe in Education (2021) contains the core requirements, and these expectations are also universally appropriate. The full list is on pages 147 and 148 of KCSIE.
How does the DSL help raise awareness among staff and volunteers? The DSL must ensure appropriate procedures are in place to ensure that all staff have access to and understand the key documentation, which includes the child protection policy and, in England, Part 1 or Annex A of KCSIE. Also vital is the school Code of Conduct for staff and volunteers. The DSL must also ensure that staff have access to appropriate training, and this must include a full understanding of the DSL’s own role.
What are the DSL’s responsibilities in relation to recording and reporting? Any information which needs to be shared should be shared with consent where possible but must comply with the relevant requirements that it be shared accurately, proportionately, adequately and in a timely and secure fashion. All information, including decisions to share or not to share, must be recorded properly, and any information systems should give appropriate access to those who “need to know”. These are complex issues, and schools should routinely review their procedures.
“The importance of working with local partners cannot be underestimated.”
What about working with local partners? One of the key responsibilities of a DSL is to work closely with those in other agencies, such as external experts and services, social care, health services and the police. The importance of this aspect of the role cannot be underestimated.
Where do parents and carers fit in? A vital part of the role is to ensure there are sufficient procedures in place to liaise with parents and carers in all matters relating to their child.
What are the responsibilities of the wider leadership team? The Head and other school leaders have an essential role in ensuring the DSL is fully supported in all aspects of the role and that there is appropriate scrutiny and collective ownership of wider policy and decision making.
Leaders make a vital contribution to the oversight of good safeguarding practice by providing professional support for and appropriate scrutiny of those undertaking the role. They also drive the core expectations relating to the overall safeguarding culture within a school, where everyone knows ‘it could happen here’ and everyone is ready to act on any concerns.
“Leaders make a vital contribution to the oversight of good safeguarding practice.”
This is the fundamental reason why an inspection failure for safeguarding is considered also to be a failure of leadership and management. The DSL team should expect and require robust scrutiny from their leadership colleagues, but are also entitled to expect suitable support.
How about the safeguarding governor? Most schools have a governor with lead responsibility for safeguarding and/or child protection. The lead governor is responsible for scrutinising all essential policies, procedures and practices, for holding the relevant staff to account and for reporting as appropriate to the wider board. It is essential that the person in question has, or is given, sufficient knowledge and training to discharge the role successfully, and that the wider board ensure that this person is carrying out those duties effectively.
Who is ultimately responsible? Governing bodies and proprietors have the ultimate responsibility. and must ensure that their schools are complying with their duties under legislation and guidance. The Independent Inquiry into Child Sexual Abuse (IICSA) recommended that there must be “openness to external scrutiny, transparency and honesty within the governance arrangements” and that the ability of governors to have difficult conversations must be secured. Most of all, however, the board is responsible for ensuring that there is a whole school approach to safeguarding.
This article first appeared in the latest summer print edition of Independent School Management Plus, out now.
