ECHO Safeguarding Policy

Date of issue: 17th Febuary 2018

Policy Statement and Summary


ECHO Language School, hereafter referred to as Echo, is based at Sussex Heritage Centre, Warningcamp, in the South Downs National Park and 1 mile from the historic castle town of Arundel. It offers English language courses to a maximum of 25 children at any one time, between the ages of 12 and 17 years old, during the months of July and August. Students all live on site, a fit-for-purpose country house with garden, in en-suite rooms of up to 5 students. The boys’ rooms are in one corridor and girls’ rooms are in another. The directors and another two members of staff also live on site.


Safeguarding’ refers to our obligation to look after all the children’s welfare in every way in order to promote all aspects of their safety and well-being throughout their time at Echo, including travel to and from the school on arrival and departure.

Child Protection’ is an important part of our safeguarding policy, and refers to our duty to protect children from direct harm, such as emotional, physical or sexual abuse or neglect. We recognise that abuse may come from adults or other children.

Prevent’, an important tool in safeguarding learners, is a government strategy to reduce the likelihood of people becoming involved in violent extremism and/or in supporting terrorism It applies to all forms of extremism, including racism, far-right ideology, religious extremism or homophobia

Child’ and ‘Children’ refer to anyone under the age of 18

Concern’ is anything that causes us to suspect that a child’s safety and welfare might be compromised in some way

Allegation’ refers to an accusation that a person or persons have harmed a child in some way

Disclosure’ refers to the act of telling others about abuse a person has been subjected to.

Designated Safeguard Lead’ (hereafter referred to as ‘DSL’): has lead responsibility for safeguarding and child protection. The role involves, but is not limited to:

    • managing referrals to West Sussex Safeguarding Children Board, the Channel programme (in cases of radicalisation) and/or the Police

    • liaising with the Centre Manager and staff on Safeguarding matters

    • supporting and advising staff on all Safeguarding, Child Protection and Prevent issues

    • ensuring each member of staff has access to, understands and uses this policy appropriately

    • being alert to specific needs of more vulnerable children

    • keeping detailed, accurate, secure written records of concerns and referrals

    • encouraging a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures Echo may put into place to protect them

    • ensuring the child protection policy is available publicly

    • making sure staff are trained to the appropriate level for their Safeguarding responsibilities

Designated Safeguarding Person’(hereafter referred to as DSP): Can be delegated DSL activities when appropriate. However the ultimate lead responsibility for child protection remains with the designated safeguarding lead and cannot be delegated.


We recognise that safeguarding is of paramount importance. Our students are minors, and we have a special duty of care to safeguard the welfare of young and vulnerable learners. This duty of care applies to all members of staff and any other adults associated with the children, be they at the school, on an activity, on an excursion or travelling to or from the school.

Under 18s entitlement

All students, irrespective of disability, gender, race, nationality, religious belief, sexual orientation, identity or any other consideration, are entitled to protection under the terms of this policy and the laws that guide it.

Adults’ Responsibilities

This policy is designed to help promote a strong safeguarding ethos amongst everyone at the school. All staff are expected to read it before starting work at ECHO, and ask the Safeguarding Team for clarification if they do not understand all or part of it. It will be complemented by at least level 1 online training and face-to-face training as part of induction for all staff. All members must be vigilant and report any concerns, however small, and allegations to the Safeguarding Team. The following numbers of external Safeguarding and Child Protection bodies are facilitated in case of need:

The Multi-Agency Safeguarding Hub (MASH) is the single point of contact for all safeguarding concerns regarding children and young people in West Sussex which includes front door access for Early Help.

Referring to the MASH:

West Sussex Safeguarding Children Board (WSSCB), Tel 0330 222 7799, Email:

NSPCC Whistleblowing Helpline, tel 0800 028 0285

Arun Police: To report crimes, Tel. 101

for community advice & concerns, Tel 01273 404928


Associated Policies & Documents Contained Herein

Staff Code of Conduct p.5

Child Protection Policy p.8

Safer recruitment Policy p.15

Welfare and implementing Safeguarding p.18

First Aid and Medical Policy p.23

Emergency Procedures p.26

Behaviour and Discipline Policy p.29

Anti-Bullying Policy p.31

Fire Safety Policy p.33

Airport Transfer Policy p.36

Online Safety Policy p.37

Prevent Policy p.38

Equal Opportunities Policy p.42

Health & Safety and Risk Assessment Policy

Policy Review

This policy, and all the policies contained herein, will be reviewed and signed off by the Centre Manager:

  • Annually.

  • In response to incidents or issues that arise and gaps which may become evident.

  • In response to a change of circumstances.

  • In response to changes to legislation.

The Safeguarding Team: Roles and Responsibilities

  • Designated Safeguarding Lead (DSL): TBC (Director of Studies) Safeguarding Level 3. Tel: TBC

  • Designates Safeguarding Person (DSP): Alex Moore (Centre Manager, Academic Manager) Safeguarding Level 3. Tel: 07597 980080

Under 18s involvement

We aim to ensure that students know that we are always on hand to help, no matter what their concern. We collect information from them in order to detect any possible issues and integrate relevant points in reviews of this policy in the following ways:

  1. Safeguarding information in clear and simple language in the Student’s Handbook is explicitly discussed with new students during their induction session.

  2. Throughout their stay, we monitor each student by talking to them

  3. Early detection of possible issues is encouraged through completion of a feedback form on day 3.

  4. Another feedback form is completed a the end of the course.

Legal Framework and Documents

This policy takes into consideration the following legislation and guidance:

  • March 2015 Working Together to Safeguard Children

  • September 2016 Keeping Children Safe in Educaton

  • Children Act 1989

  • Children Act 2004

  • Sexual Offences Act 2003

Designated Team Working Methods

  • The safeguarding team meets with all teachers as part of the weekly teachers’ meeting on Tuesdays at 2pm.

    1. A time-slot is allocated to safeguarding and welfare issues in every meeting, during which staff share their opinions and any information on the well-being of individual students.

    2. Any issues are noted in the minutes of the meetings and followed up appropriately, with any resulting actions also recorded, subject to point 5 below

    3. The minutes are shared with all staff via the school dropbox account, and read through at the beginning of the following meeting

    4. Additionally, staff are asked to report any issues regarding safeguarding and child protection at any time to the DSL. These ad-hoc meetings and any resulting actions will also be recorded in the meetings log, subject to point 5 below,

    5. Confidentiality
    • Records need to be easy to access, but not necessarily by everyone. Information logged as a concern is not necessarily confidential.
    • Staff who report concerns about other members of staff will not be penalised, and their identification will remain confidential

    • Information may become confidential after further investigation or later, if the concern turns out to be more serious. In this case, records will be kept, together with all other records of allegations concerning child protection/serious issues, in secure personnel files in the office to which only the Safeguarding Team have access.

    • Such records will be kept until the person concerned has reached normal retirement age, and at least for 10 years if longer.
  • The Safeguarding Team will meet after the Teacher’s Meeting to discuss any issues raised, and on an ad-hoc basis in response to feedback, concerns and allegations from any quarter. All decisions will be recorded.

Policy Availability & Formats

  • This Safeguarding Policy is annexed to the Staff Handbook, which is sent to all members of staff before the start of the course.

  • The Staff Handbook is available in digital format in the staff dropbox file system, to which all staff have access,.

  • The Safeguarding and Child Protection policy is posted on our website.

  • A more basic summary written in simple English will form part of the Student’s Handbook

Staff Code of Conduct

Overview and Principles

All staff are required to agree to a Code of Conduct before starting work. This is designed to

  • build trust between our students and the adults working with them

  • create a safe school culture

  • protect both the children in our charge and the adults working with them

  • protect our staff and students from behaviours or actions that may be misconstrued.

Position of Trust

Staff act in accordance with the Sexual Offences Act 2003, which states any person in a Position of Trust engaged in any sexual activity of any sort with persons under the age of 18 is breaking the law, despite the fact that the legal age of consent is 16.

Setting Standards

All staff at ECHO commit to:

    1. carrying out their professional duty to promote the welfare and safeguarding of all young people in our care, in accordance with the ECHO Safeguarding Policy and the Children’s Act1989.

    2. acting professionally at all times

    3. being excellent role models, promoting core British values through example

    4. treating students with respect and dignity

    5. listening to the students

Adult-Student Interaction

All staff at ECHO commit to:

    1. using appropriate language with and around the students.

    2. challenging inappropriate language used by another member of staff or by a student when with or around the students.

    3. using praise and being positive.

    4. being aware of their body language and avoiding physical contact, except in situations where it is required to prevent harm. In cases where a student is distressed and needs comforting, staff should ensure that any contact is measured, unreciprocated and public.

    5. not being alone with a student in a room with the door closed.

    6. not meeting any student outside the school premises unless work related.

Appropriate Appearance

All staff at Echo commit to:

    1. dressing appropriately and with sensitivity to the cultural background of the students. Appearance can impact respect from students positively or negatively

    2. dressing appropriately for the role: in class, on activities, on excursions…

    3. dressing appropriately at night around the school, in particular residential staff

Alcohol, smoking and drugs

All staff at ECHO commit to:

    1. not allowing students to consume alcohol, tobacco or other non-prescribed drugs

    2. not consuming alcohol, smoking or using any other non-prescribed drugs on the premises or anywhere else with or around the students.

    3. not making light of the consequences or dangers of consuming alcohol, tobacco or other drugs

IT and Social Networks

All staff at ECHO commit to:

    1. not giving students their personal email addresses or mobile numbers

    2. sending ‘friend’ requests to, or accepting ‘friend’ requests from, students, or any other contact with them via social networking, chat or messaging sites or services.

    3. Ensuring all communication with children is through school channels


Students’ privacy must be respected. If a member of staff needs to go to a student’s room, for example due to absence in class or illness, they will knock and wait for permission to open the door. Under no circumstances will they enter a student bedroom and close the door behind them


  1. We have written confirmation from the taxi company we use for airport transfers, Castle Cars in Arundel, that all their drivers are DBS checked

  2. We have written confirmation from the taxi company we use for some activities, Arrow Taxis in Worthing, that all their drivers are DBS checked

  3. Staff should not transport students in private cars unless absolutely necessary. If they do, students should sit in the back seat, and the driver must phone through the place and time of the start of the journey before leaving, the place and time of the end of the journey on arrival, and inform of any delays en-route. Times and places will be noted in a journey log at the school

    • If any journeys are unduly long, clarification will be sought from the driver and the student will be interviewed informally about their day and journey by a member of the Safeguarding Team

    • The journey-log may help clarify events in the case of any allegations

  1. When using trains:

    • Staff will be in the same carriage/coach as the students in order to be able to carry out their safeguarding duties appropriately.

    • There will be a maximum staff:child ratio of 15:1

    • students will be made aware of which stop to get out at, and how many stops there are previous to that.

    • When boarding or alighting from a train, one staff will be at the head and another at the tail of the group

    • Staff will perform head-counts at regular intervals, and especially before and after boarding and alighting.

    • Staff will have a list of student profiles for all the students in their group, including full name, telephone number and photo, in case someone gets lost and help is required.

  1. When using buses:

    • Staff will whenever possible ensure students sit together

    • Staff will whenever possible ensure students sit downstairs on double-decker buses.

    • Students will be accompanied by a member of staff in the area where they sit, in order for staff to be able to carry out their safeguarding duties appropriately.

  1. When walking with the students:

    • Before leaving

      • Staff will have familiarised themselves thoroughly with the route

      • Staff will instruct all students to stay together as a group

      • Staff will remind students of the dangers involved in crossing roads or railway crossings

      • Staff will ensure all students have their student cards, mobile phones and, if appropriate, map of the area with them

    • Staff will take the lead, the tail and the middle for larger groups

    • When crossing roads, pedestrian crossings will be used at all times

    • When crossing railway crossings, e.g. the one near the school in Warningcamp, staff will man the gates and ensure students cross one-by-one, quickly and calmly

Favouritism and Gifts

      1. Staff will treat all students equally

      2. Staff will not give gifts to or accept gifts from students

If offered a gift by a student, the member of staff should inform the Centre Manager, who will ascertain if the offering is:

          1. from the child to an individual teacher, in which case the child will be discreetly informed that this is not appropriate.

          2. from the parents to the staff, in which case the parents and the child will be thanked, the staff informed of the gesture, and the gift shared amongst the staff if possible (eg. chocolates)


Staff have a legal obligation to inform management of any concerns about colleagues not following this Code of Conduct. Staff who report this (or any other problems) will not be penalised and their report will be confidential.

For staff who do not feel able to raise concerns regarding child protection failures internally, the NSPCC Whistleblowing Helpline is 0800 028 0285, 8:00 AM to 8:00 PM, Monday to Friday; email:

Child Protection Policy


Echo and it’s staff commit to our duty of care to children, developing awareness of issues that may cause children harm and safeguarding them in the following ways:

  1. Ensuring all staff and students are aware of and act according to their obligations towards others through staff and student Codes of Conduct contained in their respective Handbooks and discussed during induction at Echo.

  2. Drafting and publishing a Child Protection policy, and sharing it with staff, students and parents via the Staff Handbook, Student’s Handbook and our Website

  3. Sharing information about concerns and allegations with external authorities who need to know, in particular the WSSCB, NSPCC and the police, and involving parents and children appropriately

  4. Employing a safer recruitment policy including referencing, DBS checks, barred list checks and prohibited list checks

  5. Promoting a strong safeguarding ethos amongst everyone at the school, such that they are vigilant and feel able and know how to share concerns

Designated Child Protection staff

  • Designated Safeguarding Lead (DSL): TBC (Director of Studies) Safeguarding Level 3. Tel: TBC

  • Designated Safeguarding Person: Alex Moore (Centre Manager) Safeguarding Level 3. Tel: 07597 980080

    • An Advanced Safeguarding (Level 3) trained member of staff will always be available.

Adults need to respond when:

  • noting a concern themselves

  • being told about a concern by another person, child or adult

  • disclosure to them by a student

Recognising the Symptoms of Abuse:

Child abuse constitutes all forms of ill-treatment, abuse, neglect or negligent treatment or other exploitation, resulting in actual or potential harm to the child’s physical or mental health, development or dignity.

Students at ECHO are with us for a relatively short time (normally a period of 2-4 weeks), and the depth of our knowledge of any particular student’s personality traits and mannerisms is accordingly limited. Furthermore, signs and symptoms of abuse may take time to develop. Nonetheless, as professionals working with children, it is our responsibility to be aware of abuse as an unfortunate but widespread reality, and to be aware of the generally recognized signs and symptoms associated with sexual, emotional and physical abuse.

  • There are four main categories of abuse: sexual, emotional, physical and neglect. The signs potentially recognizable within the context of the relationship of staff with students at ECHO are listed below.

    • Sexual Abuse

  • becoming withdrawn

  • personality changes, seeming insecure

  • unaccountable fear of particular places or people

  • changes in eating habits

  • physical signs such as soreness around genitals, sexually transmitted diseases

  • becoming withdrawn or clingy

  • secretive behaviour

  • tiredness, problems sleeping, nightmares

  • acting in an inappropriate sexual way with objects or with peers

    • Emotional Abuse

        • extremes of passivity or aggression

        • sudden speech disorder

        • overreaction to mistakes, or continual self-deprecation

        • neurotic behaviour (rocking, hair-twisting, self-mutilation)

    • Physical abuse

        • unexplained bruises, burns etc

        • wearing clothes to cover injuries, even in hot weather

        • refusal to undress for sports, or join swimming sessions

    • Neglect

        • often hungry; may beg or steal food

        • badly dressed in clothes that need washing

        • poor appearance and personal hygiene

        • often tired

        • doesn’t get necessary dental or medical care

        • abuse of alcohol or other drugs

  • Other forms of abuse include

    • Child Sexual Exploitation (CSE)

      • children are persuaded to engage in sexual activity in return for money, gifts, drugs, affection, status or other rewards. Symptoms include:

        • having a much older boyfriend/girlfriend

        • receiving unexplained gifts or new possessions

        • associating with others involved in exploitation

        • misusing drugs or alcohol

        • regular absenteeism

    • Female Genital Mutilation (FGM)

      • Mainly motivated by religious, social or cultural causes, FGM can cause severe physical, emotional and mental damage.

      • It is illegal in the UK, and cases should be reported to the designated Child Protection staff immediately, who will report it to the police

    • Bullying, especially Cyber-Bullying

      • Bullying is behaviour by an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally, or causes them distress, fear or humiliation

      • Cyber-bullying is bullying by electronic media such as messages, mobile phone calls, cameras, email, hijacking/cloning email accounts, posts on websites, chatrooms or social media sites

      • Symptoms of being bullied included

        • belongings getting “lost” or damaged

        • physical injuries such as unexplained bruises

        • being afraid to go to class, spend time with others, or being mysteriously ‘ill’ each morning

        • not doing as well in class

        • asking for, or stealing, money (to give to a bully)

        • being nervous, losing confidence, or becoming distressed and withdrawn

        • problems with eating or sleeping

        • bullying others.

      • Symptoms of being cyber-bullied include the above, plus:

        • not wishing to answer phone or look at incoming messages

        • nervousness when the phone beeps/rings/sounds

        • getting angry with the phone or computer

        • not wishing to talk about online activity

        • significant reduction in use of technology

      • Signs that a child may be cyber-bullying others include:

        • quickly changes screen/app when an adult approaches

        • not wishing to share their online activity

        • laughing when using technology

        • has multiple email and/or social networking accounts, making tracking more difficult

        • increase in use of communication technology

        • impatience to use communication technology

(many of these may have other causes, but they are signs to look out for)

    • Peer-on-Peer Abuse

        • Abuse may not be perpetrated by an adult, but rather by Under-18s

        • This is most likely to include, but may not be limited to, bullying (including cyberbullying), gender based violence/sexual assaults and sexting (the production and/or sharing of sexual photos and videos of and by young people who are under the age of 18).
        • If a child abuses or is alleged to have abused, the alleged abuser as well as the victim of the bullying need and will be given support.

Disclosure by a child

  • Children who are abused are often threatened by the perpetrators to keep the abuse a secret. Thus, telling an adult takes a great amount of courage. Children have to grapple with a lot of issues, including the fear that no one will believe them. So, care must be taken to remain calm and to show support to the child throughout the disclosure phase.

  • In the case of a disclosure by a student to a staff member, the following guidelines will help lessen the risk of causing more trauma to the child and/or compromising a criminal investigation during the disclosure phase

    • listen; take what the child is saying seriously

    • be reassuring, but don’t make promises such as “everything will be all right now”

    • be attentive, calm, and non-judgemental

    • avoid condemning the alleged abuser

    • do not make assumptions about the child’s feelings

    • never promise confidentiality – tell the child that you will only tell those whose job it is to protect children

    • acknowledge how difficult it must have been to talk.

    • never attempt to investigate the allegations directly, or ask leading questions – do not do anything that may jeopardise a police investigation

    • ask open questions, such as “Is there anything else that you want to tell me?”

    • explain what you have to do next, referring by name to the DSL and/or DSP

    • make brief notes at the time of disclosure if possible

    • record what was said and observed as soon as possible after disclosure, using your notes. Include details such as the date, time, place, words used by the child and how the child appeared to you – be specific. Record the actual words used; including any swear words or slang. Record statements and observable things, not your interpretations or assumptions – keep it factual

    • keep your original notes -they may be required by Court

    • report the disclosure to the Safeguarding Team immediately

    • do not discuss the case with anyone outside the child protection team

  • FGM & Sexual abuse

    • Never ask to see physical signs of abuse; if the child is about to show you, ask them not to.

  • Sexting

    • Never view, download or share the imagery yourself, or ask a child to share or download it – this is illegal.
    • If you have already viewed the imagery by accident (e.g. if a young person has shown it to you before you could ask them not to), report this to the DSL.
    • Do not delete the imagery or ask the young person to delete it.
    • Do not ask the young person(s) involved in the incident to disclose information regarding the imagery. This is the responsibility of the DSL.
    • The DSL will decide whether or not to call in outside agencies (eg. police)
        • An immediate referral to police and/or children’s social care should be made if at this initial stage:
          • the incident involves an adult
          • there is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs)
          • what you know about the imagery suggests the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent
          • the imagery involves sexual acts and any pupil in the imagery is under 13
          • you have reason to believe a pupil or pupil is at immediate risk of harm owing to the sharing of the imagery, for example, the young person is presenting as suicidal or self-harming
        • If outside agencies are not deemed necessary the DSL will:
          • ask the young person to delete images and to record and sign that this has been done, reminding them it is illegal to keep such images

Identifying Vulnerable Students and Early Help

Echo is aware there are factors that that might make certain students more vulnerable. Examples include:

  • SEND (Special Educational Needs and Disability)
  • Different cultural/social background and codes of interaction to local context and/or peers
  • Family backgrounds which afford low levels of emotional support or well-being

Such students will be identified via:

  • parental information (enrolment form)
  • parental information (direct communication)
  • observation by staff on and after arrival at Echo

Any concerns will be reported to the Safeguarding team as soon as possible, allowing for early help and thus improving the chances of avoiding abuse and abusive behaviour towards more vulnerable members of the school.

Keeping Records

Records of concerns, allegations and disclosures will be kept in a secure file to which only the Safeguarding Team and if necessary outside agencies such as WSSCB or the police have access


Echo will deal with allegations quickly, providing effective protection for the child and support for the subject of the allegations

The following procedures will be followed if there is Information which indicates an adult may have:

  • behaved in a way that has/may have harmed a child
  • possibly committed a criminal offence against or related to a child
  • behaved towards a child in such a way that indicates s/he would pose a risk of harm if working closely or regularly with a child

Procedure for allegations against members of staff:

  • Make sure the child is not in immediate danger
  • Inform the DSL or DSP
  • Ensure a written record is made by person making allegation
  • Do not to talk to anyone else about the matter.
  • The DSL contacts WSSCB for guidance before informing the accused person
  • The Safeguarding team will follow guidance from WSSCB, such as on:
    • What immediate action should be taken to protect student
    • When and what parents should be told
    • What should be said to the person facing the allegation and should s/he be suspended
      • Suspension is not an automatic response, and will be considered where students are at risk of serious harm, or the concern is so serious that it would result in immediate dismissal.
      • Echo wil provide a named contact for anyone suspended, and will inform the accused of the reason for suspension within one day
    • If safe / appropriate, try to return child to normal routine

Procedure for allegations against the DSL:

  • Make sure the child is not in immediate danger
  • Inform the DSP/Centre Manager
  • Ensure a written record is made by person making allegation
  • Do not to talk to anyone else about the matter.
  • The DSP/Centre Manager contacts WSSCB for guidance before informing the DSL of the allegations
  • The DSP/Centre Manager will follow guidance from WSSCB:
    • What immediate action should be taken to protect student
    • When and what parents should be told
    • What should be said to the DSL facing the allegation and should s/he be suspended
      • Suspension is not an automatic response, and will be considered where students are at risk of serious harm, or the concern is so serious that it would result in immediate dismissal.
      • Echo wil provide a named contact for anyone suspended, and will inform the accused of the reason for suspension within one day
    • If safe / appropriate, try to return child to normal routine

Procedure for allegations against the Centre Manager:

  • Make sure the child is not in immediate danger
  • Inform the DSL
  • Ensure a written record is made by person making allegation
  • Do not to talk to anyone else about the matter.
  • The DSL contacts WSSCB for guidance before informing the Centre Manager of the allegations
  • Follow guidance from WSSCB:
    • What immediate action should be taken to protect student
    • When and what parents should be told
    • What should be said to the Centre Manager facing the allegation

Procedure for allegations against children:

  • Make sure the alleged victim is not in immediate danger
  • Inform the DSL or DSP
  • Ensure a written record is made by person making allegation
  • Do not to talk to anyone else about the matter.
  • The DSL contacts WSSCB for guidance before informing the child or children facing the allegation
  • The Safeguarding team will follow guidance from WSSCB, such as on:
    • What immediate action should be taken to protect student
    • When and what all the parents of the children involved should be told
    • What should be said to the person facing the allegation
  • The child or children facing the allegation will be given support throughout the process. They are also victims, whether the allegations are founded or not.
  • If safe / appropriate, try to return the victim and/or the accused child to normal routine

Criminal Offences

If the allegations involve a criminal offence and the police become involved, the Safeguarding team will follow their guidance


Everything relevant to the allegation, including information, agencies involved, decisions and actions taken, will be recorded and stored securely.


Responsibility and delivery

The Centre Manager is responsible for ensuring that all staff have carried out the following pre-course actions:

The DSL is responsibe for follow-up face-to-face training during staff induction. This will include

  • reinforcement of the Basic Awareness course content

  • ensuring the safeguarding policy has been understood

  • ensuring ‘Keeping Children Safe in Education – Part 1’ has been correctly understood

  • clarifying any doubts

Sections of the Safeguarding policy will be focused on a regular basis in the weekly teachers’ meetings, including:

  • avoiding actions that might be misconstrued with reference to Code of Conduct

  • signs and symptoms of abuse

  • dealing with disclosures

  • dealing with concerns and allegations

Any gaps in knowledge which become evident as the course progresses will be dealt with in training sessions as part of the teachers’ meetings.

Safer Recruitment


The ECHO recruitment process aims to confirm that all staff coming into our employment are suitable to work with children. Additionally, external agencies, such as taxi companies, group leader employers or activity venues are required to give us written confirmation that workers supervising children have undergone DBS checks and/or overseas criminal records checks.

Recruitment materials

  • All recruitment materials will include the following statement:

Echo Language School operates a strict safer recruitment policy and all staff will have checks made on their suitability to work with children.

All applicants will be required to supply an up-to-date CV, and gaps in employment history must be explained. Applicants will also provide contact details of 2 suitable referees (including former employers) which will be checked prior to employment. The referees will be asked specifically about your suitability to work with children.

All employees will be required to provide proof of identity and qualifications, and undergo an Enhanced DBS (Disclosure & Barring Service) check and a Prohibited List check

All employees will be required to provide proof of identity and all relevant qualifications (originals only) – copies will be taken for our records.

All employees will be expected to share the school’s commitment to safeguarding and actively engage in looking after Under-18s safely.”

  • Job descriptions will include references to our duty of care to children, promoting a strong whole-school ethos of safeguarding, child protection and vigilance, and maintaining confidentiality in cases of allegations and disclosures.

Recruitment stages & information for candidates

Application documents

  • Any gaps in CVs will be explained and original qualification certificates and ID documents will be shown

  • Candidates will be asked at interview about their attitude to working with children

  • Candidates will be reminded that if they are successful, their references (a minimum of two including former employers) will be followed up including a question about their suitability to work with children, and DBS & Barred List and Prohibited List checks will be carried out

  • Any job offers will include the phrase “subject to receipt of a satisfactory DBS check”

  • Pre-Service Safeguarding training (see ‘Training’ section) emphasises our commitment to a whole-school safeguarding ethos designed to maximise protection for children form abuse

  • Contracts will reflect the job description by including references to our duty of care to children, promoting a strong whole-school ethos of safeguarding, child protection and vigilance, and maintaining confidentiality in cases of allegations and disclosures.

  • All staff will sign the Code of Conduct (see above)

Applicants awaiting DBS clearance

Any successful applicants whose DBS checks are delayed for any reason will

  • undergo a Barred List check

  • sign a self-declaration

  • not be allowed to work with or be with children unsupervised until the DBS check comes through

  • only commence work subject to a risk assessment which evaluates the reasons to start work before clearance is received, the impact this may have on the students and the possible safeguarding risks involved.

Applicants with a Criminal Record

  • Having a criminal record does not disqualify a candidate, and various factors will be considered:

  • the seriousness and nature of the offence

  • the frequency of offences

  • the age of the offence

  • the concealment offences during the application process

  • Verification of the disclosure will be sought, and it will be discussed with the candidate

  • Two members of Echo will be involved in the decision

  • If appropriate, the WSSCB will be asked for advice

  • There will be a clear record of the decision, signed by the Centre Manager. This will not contain details of the offences

When Criminal Checks are not Possible

For British nationals who have been living in a country which does not provide a criminal records check, we will:

  • carry out a UK DBS check, Barred List check and Prohibited List check

  • thoroughly check their ID and references, requesting further references if appropriate

  • thoroughly check any gaps in employment history

  • In the light of the above, decide on whether to employ the applicant for the job and on the level of supervision required, and in no case allow students to be under exclusive supervision of the employee without other members of staff on hand.

For overseas nationals, we will:

  • document what action has been taken to obtain a check and why this has not been possible

  • thoroughly check their ID and references, requesting further references if appropriate

  • thoroughly check any gaps in employment history

  • In the light of the above, decide on the level of supervision required, and in no case allow students to be under exclusive supervision of the employee without other members of staff on hand.

Single Central Record

A single central record of pre-appointment checks on all staff will be kept, to include:

  • Identity – name, address, DoB, ID evidence (photo), evidence of check made and date
  • Start date
  • Role in organisation
  • Qualifications – required, evidence of check and date
  • DBS certificate – Disclosure number, date issued, type, evidence of check and date
  • Barred list check (part of enhanced DBS) – evidence of check and date
  • Overseas Police check – check required (Y/N), evidence of check and date
  • Right to work in UK – evidence of check and date
  • Prohibited list check – evidence of check and date
  • Restriction check for teachers who’ve worked in EEA countries
  • Section 128 Prohibition Check for Directors
  • At least 2 references

Welfare & Implementing Safeguarding

Risk assessments

We recognise that whilst it is neither possible nor desirable to remove all risk from young people’s lives, a serious approach must be taken to assessing and managing possible risks to our students’ safety. Our goal at ECHO is to make sure that we have done as much as possible to minimise or manage the risk of anyone coming to harm, whilst ensuring that the learning experience is not jeopardised or undermined.

  • We have written risk assessments which cover the potential hazards to which students may be exposed whilst in the school, and during activities off-site.

  • These risk assessments are regularly reviewed, and all staff are familiar with their content and asked to provide input. The Health & Safety Policy (see Annex) of which risk assessment forms an important part is sent to staff before they start work, and questions on risk assessment form part of staff induction.

  • Staff leading activities read the risk assessment carefully, give appropriate instruction and information to students before leaving, and take a copy with them. Any gaps in the assessment should be noted down during or immediately after the activity

  • We also ask the students to keep an eye out for risks around the school (eg objects left in corridors where they may pose a trip hazard) and to report them to staff.

  • Students are made aware of the risks and their responsibility in keeping them to a minimum through

    • the Student’s Handbook

    • The Student Code of Conduct

    • Instruction during induction

    • Instruction before leaving on an activity or an excursion

The ECHO approach to managing risk is based on guidance from the Health & Safety Executive (HSE) and follows five basic steps:

  • what are the hazards?

  • who might be harmed and how?

  • what are we already doing to minimize this risk?

  • do we need to do anything else? If so: what, by whom and by when?

  • regular revision and review of risk assessments to make sure they are current and complete

The ECHO premises provide a homely, informal and comfortable place for students to live and work, whilst meeting all required health and safety standards.

Supervision Ratios

The1998 DfEE publication Health and Safety of Pupils on Educational Visits advises a staff-to-pupil ratio of 1:15–20 for children older than the age of ten. At Echo, we have a maximum ratio of 1:15, and of 1:10 in the case of excursions to London.

Missing Students

Relevant documents:

  • a list including the names, numbers and copy of passport photo is compiled for each week and a copy taken on every excursion

  • copies of all students’ passports are filed at the school in case of need

  • all students have a student card which they are instructed to keep on them at all times containing contact information for the school and the emergency services.

  • all staff have a staff card including their name, photo and the contact information for the school including the Centre Manager’s mobile

  • a register for each class, activity and meal

  • signing-in and out sheets

In house: class, meals, in-house activities

  • Students are informed of start-times for classes, meals and activities through the Student Handbook and the posting of timetables on the noticeboard in the hall

  • A register of student attendance will be completed for each of these, using the following codes:

    • / for present
    • A for absent
    • B for a notified absence, giving the reason where known
    • S for sick
    • L for late
  • The teacher, activity leader or catering supervisor responsible should inform the Centre Manager if the student is not present within 5 minutes of the allocated time

  • the Centre Manager will:

    • check the signing out/in list

    • check the students room with another member of staff (knock, call, wait, knock again, call again, open door, call again, check making sure door is wide open)

    • check the toilets

    • check the garden

    • ask other students if they know the whereabouts of the missing student

    • telephone the student’s mobile phone

  • if the student remains missing, the Centre Manager will

    • contact the student’s parents

    • seek advice from the police.

Out-of-house: activities and excursions

  • A roll-call of all participating students is taken before leaving

  • regular head-counts are taken on route, in particular before and after using public transport or stops on the itinerary.

  • If there is a meeting point and time, the activity leader will wait 10 minutes before contacting the Centre Manager. If the student should have been with the group all along, the activity leader will act immediately.

  • The activity leader will

    • ask other students if they know the whereabouts of the missing student

    • telephone the student’s mobile phone

    • contact the Centre Manager

  • If the student remains missing

    • the Centre Manger will contact the parents

    • the activity leader will seek help from the police

Unsupervised Time

As a part of the data collected during the enrolment process, we ask parents for explicit permission with regards to allowing Senior and Intensive Course students (age 15+) spending unsupervised time off-premises. Junior students (12-14) may not leave the premises unsupervised.

If a student wishes to leave the premises, they need to ask a member of staff for permission. This permission is granted subject to:

  • parental permission given on the enrolment form

  • number of students participating (minimum 3)

  • whether they have other commitments (classes, activities, meals)

  • the time of day (students are NOT allowed out on their own after dinner)

  • having their mobile phones (sufficiently charged) and student cards on them

  • what they wish to do: they are allowed to walk into Arundel, but they are not allowed to take public transport and go further afield

  • committing to a time when they have to be back at the school

  • Signing out when leaving and committing to signing back in on return. The sign out sheet includes: name of student, permission from, time out, agreed return time, time back

All students will be accompanied to the railway crossing in Warningcamp by a member of staff, who will ensure that they cross one-by-one in a safe and orderly fashion. On return, students must phone the school (the number is on their student card) in order to be met at the railway crossing by a member of staff, who will ensure that they cross safely.

These guidelines are explained clearly in the Student Handbook, Code of Conduct and at induction, and are rigorously applied by staff.

During off-site activities, students are supervised according to a 1:15 staff-to-student ratio. On excursions, students are sometimes given a period of shopping time. In such cases:

  • There is a defined area within which the students must remain.

  • This will be indicated on the map the students are given

  • Students are instructed to remain in groups of at least 3, and must not go off on their own at any time

  • Students are shown the meeting place and told the meeting time

  • Staff question students to ensure they have understood when and where to meet, and which other students they are to stay with.

  • Students are given the Echo mobile number, which staff will be carrying

  • Staff remain in the immediate vicinity, ready to respond quickly if required

  • Staff will have the list of student names, phone numbers and photos

  • If a student is missing at the meeting time and place, the emergency procedure will be followed (See ‘Emergeny Procedures’ below)


  • Sefton Place has 11 bedrooms, 2 downstairs and 9 upstairs.

  • The students are accommodated upstairs, unless they suffer from a disability which requires a PEEP (Persoanl Emergency Evacuation Plan), in which case they may be allocated a downstairs room. The two rooms downstairs are fully equipped for people with disabilities, including wheelchair users.

  • All the rooms at the school have an en-suite bathroom.

  • All rooms are light and well ventilated with windows equipped with safety-stops so that they cannot be fully opened and thus do not pose a danger of students falling out.

  • All rooms are equipped with self-closing fire doors.

  • All rooms have sufficient space and storage for the number of occupants allocated to them.

  • The boys’ rooms are in one corridor, and the girls’ rooms are in another.

  • Staff have rooms close to the students’ rooms.

  • All students are to be in their rooms by 11pm and lights off by 11.30.

  • Students are not allowed to leave their rooms during the night. They have no need to do so.

  • Normally, students will spend the day, from the beginning of the first class to the end of the evening activity, in the areas of the house downstairs, with the other students. They should ask for permission if they wish to go to their rooms during the day, for example to rest or shower after activities.

  • Students may not visit each others’ rooms.

  • English must be spoken at all times, including in the rooms. Rooms are not to become ‘mother-tongue clubs’, which may lead to the social exclusion of others.

  • All students are allocated rooms with students of a similar age, the same gender and, if possible, different nationalities.

  • There are usually 2 to 4 students per room, depending on student profile and the size of the room

Welfare provision

ECHO is committed to providing a high standard of welfare to all our students at all times.

  • If a student feels unwell, unhappy, homesick or needs help of any kind, they will know to contact one of these people, at least one of whom will be available at all times

    • The Centre Manager

    • The Household and Catering Manager

    • The DSL

      • This information is included in the Student’s Handbook, and will be shared during induction

Dealing with a Concern

Reporting a concern

  • Anyone, staff, student or parent, with a concern should report it to the DSL or DSP (Centre Manager).
  • Staff or students are on-site and will most likely report verbally. Thay can also report to the Centre Manager via email ( or phone (+44 7597 980080)
  • Parents will have the above contact information and school number in order to communicate any concerns they might have to the Centre Manager, who is the person that has had all previous contact with them during the enrolment process

Responding to a concern

The Safeguarding Team’s response will depend on the exact nature of the concern; the process is often

  • investigate sensitively to gather more information
  • record
  • inform on a need-to-know basis
  • act according to investigations and discussions
  • monitor as required until No Further Action (NFA) can be noted

Keeping records

Concerns must be recorded. This single piece of information might be part of a larger, possibly ongoing, situation – or the start of a new one.

  • The person raising the concern needs to write and sign the initial report.
  • Designated Staff then take over and continue adding to the record as required.
  • Records will be stored by the Safeguarding Team: information logged as a concern is not usually confidential. It may become so after further investigation or later (if the concern turns out to be more serious)
  • The record will include:
    • the date

    • student’s name & surname, gender, DoB, nationality

    • name of person noting concern, role/connection with school

    • date, time and location of cause for concerned

    • concern

    • response & follow up: name and role of responder, date, time and action taken

  • If a concern develops into an allegation, the procedure for allegations in the Child Protection Policy contained in this document will be followed

First Aid and Medical Policy

We encourage students to let us know if they are feeling unwell, specifying who to contact in the Students Handbook. Our Health & Safety Policy and written risk assessments ensure that the probability of accidents is kept as low as possible.

Information on medical conditions

Information on any medical conditions or allergies the students may have is

  • collected on the enrolment form

  • checked with the students on arrival

  • double-checked with the parents before treatment if at all possible


We have two staff members with a valid Emergency First Aid at Work certificate:

  • Alex Moore (Centre Manager)
  • Carmen Gonzalez (Household & Catering Manager).
    • Students are made aware of who the first aiders are via the Student Handbook

All staff are trained to act as an ‘appointed person’ – that is, they have knowledge of the First Aid Box contents and are able to administer basic first aid using these contents. This training forms part of the Staff induction process and is based on the Emergency First Aid Made Easy guide, copies of which are kept at the school.

For quick access, the British Red Cross First Aid app will be downloaded onto the Echo mobile phones, and teachers are recommended to have the app on their own mobile phones as well.

First Aid Boxes are located:

  • in the kitchen, including materials for the care of burns and cuts (such as might be sustained in the kitchen) and grazes, sprains and strains (resulting from slips or trips).
  • in the dining room
  • in the teachers’ resource area(portable First Aid Packs to take on activities and excursions)
    • These will include:
      • A leaflet giving general advice on first aid
      • Six individually wrapped sterile adhesive dressings
      • Two triangular bandages
      • Savlon spray
      • Gauze swabs
      • Disposable gloves
      • Eye wash pods
      • Eye pads
      • Plasters
      • A face shield (for hygienic mouth to mouth resuscitation) would be useful
    • The nearest 24-hour AEDs (Automatic Defibrilators) are located at Arundel Museum and Arundel Fire Station.

    • There are also AEDs at Arundel Castle and Arundel Wetlands Centre during opening hours.


During off-site activities, supervising staff carry a First Aid Pack for responding to minor injuries such as grazes or minor sprains, and they should call the school if they need further support, such as a taxi service. Staff will carry an emergency fund to cover unforeseeable events.

Should an accident of a more serious nature occur, staff should inform the school and seek the help of emergency services.

All accidents, whether occurring on or off-site, must be properly recorded in the Accident Book, located in the office.

Certain injuries are required to be reported to the Health & Safety Executive (HSE) under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations, These include any injury for which the patient is taken directly from the scene of the accident to hospital for treatment


Following assessment of the student’s needs:

  • over-the-counter remedies may be obtained from the pharmacy to be taken to the student, checking medical information declared by parents on the enrolment form, verbally with the student and if possible contacting the parents beforehand
  • an appointment made with the local doctor:

The Arundel Surgery
Green Lane Close
West Sussex
BN18 9HG

01903 882191

Out of Hours: 01903 882517 or call 111

The student will be visited in their room if necessary, with a frequency dependent on their situation but at least three times a day at mealtimes, until they are well enough to return to their course. Staff visiting the room will be of the same gender as the student and the door to the room will be left open throughout the visit.

Minor Injuries

For minor injuries, the following walk-in clinics can be used:

Bognor Regis War Memorial Hospital

Tel: 01243 865418Shripney RoadBognor RegisPO22 9PP

The Park Surgery

Tel: 01903 717154

St Flora’s Road

West Sussex
BN17 6BF


In an emergency situation, the student may be taken direct to Accident & Emergency at the nearest hospital:

Worthing Hospital

Lyndhurst Road, Worthing BN11 2DH

01903 205111


St. Richard’s Hospital

Spitalfield Lane, Chichester PO19 6SE

01243 788122

Entitlement to NHS Treatment

  • All treatment that is medically necessary before an EEA visitor’s planned date of return is covered as long as they have a valid EHIC. An NHS medical professional needs to make a medical decision on this. In other words, an EHIC covers treatment which cannot wait until the patient’s return to their home country.

  • The EHIC is not an alternative to travel insurance. It will not cover any private medical healthcare, being flown back home, or lost or stolen property. Therefore, we recommend taking out additional private travel insurance. For more information:

  • If you are visiting England from a non-EEA country, even if you are a former UK resident, you need to ensure you are covered for healthcare through personal medical or travel insurance for the duration of your visit. If you need NHS treatment and you have not arranged insurance, you will be charged at 150% of the standard NHS rate. You will need to pay in advance the full estimated cost if the treatment you need is non-urgent, otherwise the treatment will not be provided. Some NHS services or treatments are exempt from charges, so that they are free to all. For more information:

Emergency Procedures

Definition of ‘emergency’

1) An incident where a student / staff member / anyone connected to the school has

  • suffered a life threatening injury or fatality

  • is at serious risk of the above

  • has gone missing for a significant and unacceptable period, particularly if linked to the above. This period differs according to situations but should be no longer than 10 minutes before the Excursion Leader contacts the Centre Manager.

2) An incident that is beyond the normal coping mechanisms of the team leading an off-site visit

An emergency could, therefore, be linked to a road or rail crash, freak weather, a crowd that has gone out of control (e.g. violent demonstration), serious equipment malfunction / collapse, (e.g. at a theme park, or a gas explosion), a random violent attack carried out by a lone person – or a planned terrorist attack.

Emergency Procedures

ECHO will attempt to avoid or limit the impact of an emergency through the following measures:

Before leaving the school:

  • The leader of the excursion is clearly identified

  • A concise, clear, written description of how to respond is taken by all members of staff on the excursion

  • Risk Assessments are conducted for each excursion and destination.

  • Strategically placed safe refuges, which should have lockable areas to keep out danger such as hotels, will be marked on the excursion map given to the students. The map will also have the school mobile telephone numbers staff will be carrying on the excursion.

  • Additionally, students will have the centre number (landline) and ECHO 24-hour emergency number (mobile) on their student cards.

  • Excursion staff have a list of students and their mobile numbers. Copies of all students’ passports are kept at the centre.

  • Staff will check that students have mobiles, numbers and student cards on them. Also, If possible, all members of the excursion will form a ‘circle’ on the free app ‘Life 360’ (, which allows everyone in the circle to message and track the location of everyone else in the same circle. This can be useful if groups get separated.

  • Staff will instruct students to ‘Run, Hide, Tell’ in the event of a terrorist attack. This means they need to escape to a safe place and call/message emergency services and/or the excursion leader.

  • All staff will have received basic first aid instruction.

  • The Excursion staff take an emergency fund with them (normally £100-£150, depending on how many students are in the group), and a First Aid kit.

  • Any students requiring medicine will take enough with them for a couple of days; Any allergies or medical conditions that may be relevant on an excursion will be noted on the student phone list.

In an emergency situation:

At the scene of the emergency

The excursion leader will

  • remain calm, measured and reassuring and require all staff to be the same; any display of panic or emotions such as fear amongst staff to do not help the students.

  • allocate staff to the following tasks according to the situation:

    • make sure all members of the group are accounted for and safe.

    • make sure all children are adequately supervised.

    • administer basic first aid if required, moving other chidren away from the casualty.

    • accompany students to a safe or safer place.

    • instruct students never to take photos and not to contact parents, as misinformation can cause undue upset. If there is a terroridt threat, phones should be in silent mode.

  • if casualties are going to hospital, ensure an adult accompanies them, taking full medical information and any medication. The school will be informed immediately when this happens.

  • contact the emergency services and inform them of their name, the group name (ECHO language School) location, type of emergency, action taken so far and any other details requested.

  • report to , or ask a member of staff to report to, the Centre Manager.

  • start keeping records in the excursion Incident Log as soon as possible.

  • gather witness details and take statements if appropriate.

  • maintain frequent contact with ECHO and with emergency services as required.

  • keep monitoring and reviewing situation to see if any changes are needed to keep group secure, reassured and cared for.

Depending on severity of emergency, the aim is usually to return the group to ECHO as soon as is practical.


The Centre Manager and/or centre staff will

  • be clear on who is the Emergency Response Leader, who will allocate tasks. This will normally be the Centre Manager. In his absence, it would be the AdoS or DSL (TBC)

  • open emergency procedures file and follow steps

  • clear control space – the Centre Manager’s office or the Dining Room

  • alert other members of staff, say their help ight be required, and remind them not to speak to anyone outside ECHO, especially the press; keep them informed as news comes in.

  • assess the situation based on information given by the Excursion Leader; exactly what has happened and the extent of the problem

  • check key information about all members of the group; are they

    • accounted for

    • safe

    • adequately supervised (for children)

    • if anyone is injured, establish extent of injuries

    • which (if any) emergency services have been called?

  • immediately open Incident Log using prepared form

  • inform the Centre Manager if he is not already the Emergency Response Leader

  • look for and provide support at the scene of the emergency if required:

  • send members of staff to scene

  • request collaboration from other ELT organisations in the vicinity of the emergency

  • go online to find and continually monitor information and help available in the area of the emergency, for example offers of beds, food, shelter and support provided by locals

  • ensure everyone (at emergency site and in control centre) has enough sustenance to keep going

  • inform next-of-kin and agents of any casualties, serious and non-serious, using factual, honest and of possible reassuring statements on the phone to ensure the message has got through and to be able to answer questions.

  • reassure next-of-kin and agents of non-casualties, particularly if the incident is in the news.

  • only once it is safe to do so, instruct the Excursion Leader to ask the children to contact their parents and tell them they are OK. This can be done back at the centre if more appropriate – parents will be informed. All calls should be recorded in the Incident Log.

  • Issue regular updates to stakeholders via email – group are travelling home, group have arrived safely etc.


A real-time (as far as possible) log will be kept at the scene of the emergency and another at the centre. They should include all communications, and detailing times of calls, responses, names of those involved, actions taken, times of task-completion.


  • Pre-season: all staff will be issued with the Emergency Procedures document before they start work. They are expected to read it and understand it, and demonstrate their understanding by answering a questionnaire on it at induction. This will be reinforced by face-to-face training

  • On-going: simulations, role-plays and going through risk assessments including safe refuges for the next excursion will form part of the Teachers’ meetings

  • The CitizenAID app, giving concise, quick-reference escape and first aid advice for emergency situations, will be on the ECHO mobiles; teachers will be advised to download it onto their personal mobile phones.

Behaviour and Discipline Policy

Encouraging good behaviour and a respectful, friendly environment

Our philosophy at ECHO is to create a positive learning environment by encouragement and reinforcement of good behaviour. We believe that good discipline owes more to a friendly, supportive atmosphere and good relations between staff and students than it does to sanctions and punishments. This is promoted in the following ways:

  • staff commit to leading by example in the Staff Code of Conduct

  • the English Only Rule

    • encourages cross-national communication

    • encourages even the more reserved students to talk with everyone else

  • Whenever possible, we allocate different nationalities to the same bedrooms, thereby encouraging cross-nationality relations and discouraging the formation of closed social groups with linguistic or cultural boundaries

  • collaborative project groups strengthen the social fabric of the school by

    • mixing nationalities as much as possible

    • encouraging students to have contact with all others

    • providing a platform for working together towards a common goal in which creativity, artistic talent and teamwork are as important as age or linguistic prowess

  • the Monday Mingler (whole school communication activity) helps student break the ice and talk to all the others on the first morning of their course

  • by limiting numbers to 25, a family-like atmosphere is engendered, and monitoring of behaviour and social dynamics is greatly facilitated.

  • all students eat together and with the teachers at mealtimes, thus encouraging a community feel undivided along linguistic, cultural or age lines.

  • our continuous enrolment policy means that the ‘veteran’ students show new arrivals around, introduce them to others and in general make them feel welcome

  • teachers employ strategies of peer scaffolding and collaboration as much as possible in class, ensuring that pairs and groups are not static so that all members become comfortable working with each other

  • students have a lot of fun together on activities and excursions

Rules and Boundaries

We make sure that students are aware of what is expected of them. In the Student Handbook, Code of Conduct and at their induction session, the ECHO rules and sanctions for misbehaviour are clearly explained to new students, and reinforced if necessary during their stay.

Unacceptable behaviour:

  • lateness

  • unruly behaviour

  • dropping litter

  • eating chewing gum on the premises

  • visiting other students’ rooms

  • leaving the school without permission

  • speaking any language other than English

  • swearing

  • theft (from the school, the staff, the students, shops or anyone else)

  • vandalism

  • lack of respect for the property of the school, the staff, the students or anyone else

  • going into another person’s pocket or bag

  • reading another person’s private document or electronic message

  • any activities which contradict core British values, in accordance with the government’s Prevent policy (see below)
  • The viewing or reading of extremist material, either online or in any other form;
  • any illegal activity


Staff are expected to respond directly to disciplinary issues in the first instance, according to the ECHO Disciplinary Policy:

  • We intervene early & quietly – we ‘nip things in the bud’

  • We use the principle of certainty – be consistent and always follow up bad behaviour!

  • We treat everyone in the same way – no-one is favoured over anyone else

  • We make sure consequences are fair and reasonable

  • We offer the student a chance to make good when following up

  • We acknowledge students when they show improved behaviour

Sanctions & measures

  1. Verbal warning and reminder of the rule (eg. speak English)

  2. Help with simple household chores under supervision

  3. Referral to the Centre Manager, who will discuss the problem with the student and may

    1. require extra written awareness tasks (eg. 200 words on ‘Why am I Here’)

    2. contact the student’s parents

    3. exclude the student from certain activities or excursions

    4. give official warnings that the student may be sent home early, reinforced by an email to the parents

    5. send the student home early

    6. In the case of any illegal activity, the Centre Manager may contact the police

Anti-Bullying Policy

All bullying is unacceptable. This policy is annexed to the Staff handbook, and it’s provisions are made clear in the Student’s Handbook, Student Code of Conduct and at induction. No one at ECHO should ever be made to feel unhappy, undervalued or humiliated. We will not tolerate bullying of any kind, including:

  • Deliberate unkindness or any action that gives hurt, whether verbal, physical or mental

  • racial, religious, sexist or homophobic intolerance

  • sexual harassment

  • aggressive behaviour towards staff, students or anyone else, on or off premises

  • writing notes that are offensive, hurtful, annoying or worrying

  • cyber-bullying (see above: Child Protection/Recognising Symptoms of Abuse)

  • sexting

ECHO always aims to be a happy and friendly community in which everyone respects, supports and cares about everyone else, and will take the firmest action against any bullying.

ECHO promotes an open atmosphere in which students are able to speak out without fear and to seek justice for themselves and for others. Any student who feels unhappy or threatened should not regard it as a private or personal problem but should seek the help of a friend, teacher or member of staff.

It is the duty of everyone who sees an instance of bullying – or potential bullying – to act to stop it. This duty applies to all students, teachers and other members of staff.

Parents who are worried about bullying issues can contact the Centre Manager about their concerns. They are provided with contact information on the website and in all correspondence with the school, including the confirmation letter and invoice we send on receiving enrolments and a pre-arrival email we always send with packing and travel advice.


If bullying is suspected or reported, the incident will be dealt with immediately following the procedure for Dealing with Concerns (See above: Welfare & Implementing Safeguarding/Dealing with Concerns)


  • pupils who have been bullied will be supported by:
    • reassuring the pupil

    • offering continuous support

    • restoring self-esteem and confidence

    • allocating a member of staff to help and monitor the student

  • If a child abuses or is alleged to have abused, the alleged abuser as well as the victim of the bullying needs and will be given support by:

    • discussing what happened

    • discovering why the pupil became involved

    • establishing the wrong doing and need to change

    • informing parents or guardians to help change the attitude of the pupil

    • allocating a member of staff to help and monitor the student

The following disciplinary steps can be taken:

  • official warnings

  • community work

  • written work to increase awareness of the issue at hand

  • exclusion from the parts of the course

  • exclusion from all the course

  • permanent exclusion & return home

Fire Safety Policy

Echo Language School acknowledges its legal requirements with regard to management of fire safety at the Sussex Heritage Centre. As a consequence this policy has been created to address requirements and has been written in such a way to be appropriate to the levels of risk and hazards involved.

Further details of risks and risk prevention measures can be found in the Risk Assessment document that forms a part of the Echo Health and Safety Policy.


The Regulatory Reform (Fire safety Order) 2005

Appointed Responsibilities

The Host

Overall responsibility for management of health and safety matters of the Sussex Heritage Centre during the year rests with Maria Whitehouse (The Host) who may appoint Delegates/Fire Marshals as the Competent Persons for fire safety matters. Specialist contractors will be assigned by the The Host to undertake maintenance and modification of fire detection systems, emergency

lighting, extinguishers and all other fire safety installations in accordance with

legal requirements and British Standards.

The Centre Manager

Alex Moore of Echo Language School (The Centre Manager) will assume the day-to-day responsibility for fire checks and procedures during the period 01.07.2017 to 31.08.2017. During this period, he will ensure general maintenance, building and testing activities are undertaken to minimise the risk of fires from faulty equipment and installations. He will retain records, documents and information on all safety matters, including fire safety.

Fire Marshals

All other members of Echo Language School staff will assist with fire prevention, reporting of fire safety problems, controlling fires (when safe to do so) and with the organisation of evacuations/fire drills.

Overview Of Premises And Fire Safety Installations

The building is equipped with a fire alarm panel connected to smoke detectors, heat detectors, emergency lighting and manual call points located throughout the building.

Fire extinguishers (CO2, foam, water, powder and fire blankets) are located throughout the building to enable staff to control fires when appropriate. Extinguishers will be checked by the The Host periodically to ensure they are entirely satisfactory. Signage is deployed throughout the building to ensure ready identification of escape routes, fire doors, fire extinguishers, etc.

Notices are also displayed on each room identifying the procedure to be followed in the event of the discovery of fire or the sounding of the fire alarm.

All rooms are equipped with fire doors with self closing mechanisms that will be kept closed when nobody is present and at night.

Assessments Of Risk And Control Measures

The Host will undertake recorded fire risk assessments

on an annual basis or whenever it is clear elements of the previous fire risk

assessment have been subject to significant change. Specialist expertise

consultancy will be used to assist or guide fire risk assessments should it be

deemed necessary by the Host.

Fire Risk Assessments will be held on file for a minimum period of 5 years.

In order to assess the risk (likelihood) of fire, the Host will consider legal requirements and recommendations from specialist contractors (who work in accordance with the relevant British Standards) regarding fire safety and fire precautions.

She will also consider items relating to the actual conditions within the

premises, e.g., building fabric and layout, storage of flammable material, the

nature of the processes involved in the daily business of the Heritage Centre,

maintenance and cleaning tasks, numbers and types of staff/visitors within the

building, existing fire safety installations, etc.

Control Of Contractors

Contractors will be issued with instructions defining the safety requirements

that will apply to their work on site. The contractors will sign to signify their

acceptance of these terms which will be retained on file.

Before “hot work” is undertaken, (i.e. welding, etc) formal permission will be

issued by the Host who will determine the safety precautions that relate to the work.

Method statements and risk assessments will be obtained from contractors in

advance of any work should it be deemed necessary by the Host.

Training & Instruction


All Echo Language School staff members will receive fire marshal training from the Centre Manager during induction. A record of this training will be retained. The Centre Manger will also issue additional information when appropriate to ensure staff remain suitably aware of fire safety and keep a record of such. All staff know how to use fire extinguishers and what to do in the case of a fire. Should evacuation be required, different areas of the building will have been allocated to staff according to different times of day and activity (class, activities, meals, free-time, night)


As we have a new intake of young students every week, we inform our learners of what to do in a fire in the following ways:

  • there are specific indications on how to react in case of fire in their Student Handbook, as well as a plan of the building indicating exits, alarm points, and fire equipment

  • exits and escape are pointed out to students when they arrive and are taken on a tour of the school, with particular attention paid to those nearest their bedrooms

  • fire drills involving a complete evacuation of the building take place every Monday, once all the students have arrived. A record of drills and any actions to be taken arising from them is made and kept on file.

Personal Emergency Evacuation Plan (PEEP)

Should a visitor suffer from a disability which impedes their ability to exit the building at a normal pace, the individual concerned or their parent or carer will ensure this is entered onto the enrolment form in the space provided when booking a course.

The Centre Manager will establish a plan to ensure the disabled person can evacuate the building satisfactorily in the event of an emergency, including the allocation of one of the downstairs bedrooms equipped for people with disabilities and located very close to fire exits.

Airport Transfer Policy

All students are offered an airport transfer service with the following guarantees:

  • We always use the same taxi company – Castle Cars in Arundel – who provide us with a reliable and trustworthy service.

  • All drivers carry official photo identification, their company policy states that all are DBS-checked and vetted by the council, and they have confirmed this directly to us in writing.

  • Our students are met in the Arrivals Hall by their driver, carrying a name board bearing the company logo as well as our school name. They are brought directly to the school.

  • All our students are provided with our landline number and 24-hour mobile number in order to contact us at any time on the day of travel

  • Parents provide us with their children’s mobile numbers on the travel information form, which is sent to them as soon as a booking is made, in case we need to contact them.

  • In a pre-arrival email from the Centre Manager, parents are asked to ensure their children also carry the letter of confirmation we send on receiving an enrolment, which states the student’s name and the dates and location of their course as well as the school contact data on headed paper. Immigration authorities may ask for this before allowing minors through to the Arrival Hall.

  • If the students can’t find the driver, their parents have been instructed via the pre-arrival email from the Centre Manager to tell their children there may be delays on the roads so they shouldn’t worry, and that they should telephone the Centre Manager on the number provided.

  • On departure, students are picked up from the school by the taxi company. At the airport, they are either dropped off, or escorted through check-in to Departures.

  • ECHO will confirm with parents before arranging a check-in service with the taxi company, but as a rule, we expect that all students under 18 will need to be accompanied.

  • If parents prefer their children not to be helped through check-in, Echo will make the final decision after conducting a risk assessment for each individual case, taking into account factors such as age, level of independence demonstrated during the course, previous travel experience, how many students are travelling together, ability to communicate in English, complexities of the airport terminal they are flying from…

  • Students who are travelling as unaccompanied minors will be collected from the airline representative by a named driver, and on departure are handed over to a representative from the airline who will escort them to their flight. Parents will have informed the centre Manager who will be picking the children up from the airline authorities at their destination, and this information will be shared with the airline, either by the taxi driver or via a form or other means determined by the airline

  • Castle Cars keep a close eye on delays and cancellations, and the Centre Manager liaises with them, with the parents and if necessary with the students in order to ensure as smooth a journey as possible.

  • In the event of a cancelled flight back to their home country, Echo will provide all the assistance required in order to book another flight and the student will be invited to stay at Echo until transport home can be arranged

Online Safety Policy

Young students need to be protected as much as possible from inappropriate material on the internet. This includes racist, violent, sexist, pornographic or otherwise exploitative content. It also includes extremist websites and websites which directly contradict the ‘core British values’ of democracy, the rule of law, individual liberty, and mutual respect and tolerance of those with different faiths and beliefs.

Filters are in place on the school’s Wi-Fi network. However, we are aware that students may have their own 3G/4G mobile access to internet. Therefore we educate them about the dangers of, and put boundaries on, their use of the Internet.

Students are instructed:

  • never to access or share illegal or inappropriate sites whilst on the course, on the school network or via their own connections
  • not to disclose any personal information
  • that it is easy to lie online, using false words and images; many people do
  • that things online are forever
  • that things online are for the world to see, not just a few friends.
  • how to block people online
  • to tell staff if they receive unwanted or sexual messages
  • not to access the Internet during classes, meals or activities, thus limiting substantially time spent online
  • that inappropriate pictures/words sent online (text/email/social media) are cyberbullying, and not a joke
  • that the police may need to be involved in the case of illegal online activity; they can trace anything sent online, even when you think it is deleted

Students will all read and sign an Online Safety Agreement, which will point out the dangers of the Internet, define parameters of use, commit students to acting within these parameters and inform them on possible disciplinary actions for not doing so.

Staff will monitor online behaviour by:

  • showing a friendly interest in what students do online
  • watching for students who seem secretive or defensive about their online activity
  • being aware that a student who quickly changes screens, turns their device off, logs off a site etc. when a member of staff approaches may be an indication of inappropriate activity

All concerns will be reported to the DSL and/or Centre Manager, who will monitor further and take action as required.

Prevent Policy

ECHO understands its responsibilities under the Counter Terrorism & Security Act 2015 to prevent people of all ages being radicalised or drawn into terrorism and seeks to meet its obligations in the ways shown below, after setting the context.


  • ECHO accepts students aged 12-17 during the months of July and August from Europe

  • In its busiest weeks it may have 25 students and 8 staff. As we are a residential centre we do not work with homestay providers

  • The school has always promoted a multi-cultural environment where respect for and tolerance of others beliefs is required

  • ECHO is located in the village of Warningcamp, near Arundel, West Sussex, with a predominantly Caucasian local population.


  • Responsibility for ensuring the Prevent Duty is met and for the Prevent risk assessment and action plan and policy lies with the Centre Manager, Alex Moore.

  • Responsibility for the delivery of the policy while students are at the school lies with the Centre Manager, Alex Moore, and the DSL, TBC

  • Their duties are to ensure delivery of an effective risk assessment, action plan and policy as outlined here.

Risk Assessment of current situation and Action Plan for future

A risk assessment and action plan has been produced showing what is already being done and

what still needs to be done; it will be reviewed and updated at least annually and signed off by the Centre Manager, Alex Moore

Working with local partners

ECHO will

  • make and maintain contact with the local police/ local authority Prevent coordinator to understand their role and the support available, (e.g. via the Channel process).

  • make contact with local authority to ascertain other useful local agencies

  • share information with all local organisations as appropriate

Understanding terminology

  • Radicalisation: act or process of making a person more radical or favouring of extreme or

  • fundamental changes in political, economic or social conditions, institutions or habits of mind

  • Extremism*: holding extreme political or religious views which may deny right to any group or

  • individual. This can be expressed in vocal or active opposition to

  • Core British values: including

    • (i) democracy

    • (ii) the rule of law

    • (iii) individual liberty

    • (iv) respectful tolerance of different faiths or beliefs.

  • NB: extremism can refer to a range of views, e.g. racism, homophobia, political ideology, as well as any religious extremism.

Understanding risk of extremism

  • Staff, students and other adults may arrive at the ECHO already holding extremist views. Or, whilst attending the centre, they may be influenced by a range of factors: global events, peer pressure, media, family views, extremist materials (hardcopy or online), inspirational speakers, friends or relatives being harmed, social networks, and more

  • People who are vulnerable are more likely to be influenced

  • Their vulnerability could stem from a range of causes, including: loss of identity or sense of belonging, isolation, exclusion, mental health problems, sense of injustice, personal crisis, victim of hate crime or discrimination, and bereavement.

Ways to counteract risks

  • We promote a safe and supportive international environment via clear expectations of accepted behaviours and those, including radicalisation and extremism, that will not be tolerated

  • We promote core British values through documents given to students, notices around the centre, stand-alone sessions on British culture and traditions on arrival and exemplary behaviour and appropriate intervention with reference to core British values if required by Staff. Our approach is to educate that this is how things are in UK, even if different to students’ home countries.

  • We promote critical awareness to counter accepting extremism without question, especially of online material via our Online Safety Policy

  • All staff will challenge radical or extremist views in any context (formal or informal). In most situations this requires an immediate response, referring to the international environment of ECHO and tolerance expected. All concerns will then be reported.

  • We will be ready to react when world or local events (e.g. Paris attacks) cause upset and the likelihood of conflicting feelings being expressed. The DSL will take initiative in these situations by

    • meeting Staff in order to remind them of the importance of upholding core British values at this sensitive time, and identifying and monitoring vulnerable students.

    • meeting students in order to offer understanding, assurance and reinforce ECHO’s commitment to core British values.

  • We will have strong filters on the school Wi-Fi network and clear rules on accessing extremist or terrorist websites and uses of social networks to exchange extremist or terrorist views, agreed to by students via the Online Safety Agreement (see Online Safety Policy).

  • We will ensure that extremist speakers do not use premises to distribute material or expound views; all visits are through pre-arrangement with the school, and visitors (parents, local authority representatives, contractors…) are not left alone with students, other than parents’ own children exclusively.

  • As Echo is a small centre, staff get to know students, their home circumstances and friendship groups very easily and quickly, making it easier to spot changes in behaviour. Staff will be observant and vigilant in noticing any signs of radical or extremist behaviour.

  • All staff will work hard supporting any students identified as vulnerable.


Prevent values, policy and procedures are transmitted to staff via this policy, the Staff Code of Conduct, the Staff Handbook and induction training, as follows

  • Role-specific pre-season online training:

  • ECHO has requested a WRAP from the local authorities

  • ECHO will complement online training with face-to-face training as part of induction, including simulations of situations within the ECHO context and role-plays of how to challenge extreme views calmly and firmly without getting dragged into argument

These documents and training initiatives are designed to ensure staff understand::

  • the context and expectations of Prevent

  • their duty to implement the policy

  • the terminology and risks associated with radicalisation and extremism

  • how to identify and support vulnerable students

  • ways ECHO will counteract the risks, including effective sharing of information

  • signs to notice that may cause concern

  • know the lead Prevent person and procedures for communicating concerns

  • know the importance of their own behaviour and professionalism in being exemplars of British values, and not discussing inflammatory subjects with students

Students and parents are made aware of the following key parts of the policy via the posting of this policy on the ECHO website, the Student Code of Conduct, induction sessions, booking terms and conditions and the Student Handbook:

  • understanding terminology

  • importance of maintaining a supportive and tolerant society at ECHO

  • what core British values are and why they are considered important

  • any changes to rules, particularly those regarding IT

  • that they must report concerns/ incidents and understand the procedure to do so

Signs that may cause concern

  • Students talking about exposure to extremist materials or views outside ECHO (in this event, information must be shared with relevant local authorities)

  • Changes in behaviour, e.g. becoming isolated

  • Fall in standard of work, poor attendance, disengagement

  • Changes in attitude, e.g. intolerant of differences/ having closed mind

  • Asking questions about certain topics (e.g. connected to extremism)

  • Offering opinions that appear to have come from extremist ideologies

  • Attempts to impose own views/ beliefs on others

  • Use of extremist vocabulary to exclude others or incite violence

  • Accessing extremist material online or via social network sites

  • Overt new religious practices

  • Drawings or posters showing extremist ideology/ views/ symbols

  • Students voicing concerns about anyone

As all our students are under 18, any concerns regarding them are safeguarding issues and will be dealt with by safeguarding staff and, where necessary, the WSSCB

How and when to react to concerns

(Also see ‘Welfare & Implementing Safeguarding/Dealing with a Concern’)

  • Contact the Safeguarding team:

    • Designated Safeguarding Lead (DSL): TBC (Director of Studies) Safeguarding Level 3. Tel: TBC

    • Designates Safeguarding Person (DSP): Alex Moore (Centre Manager, Academic Manager) Safeguarding Level 3. Tel: 07597 980080

  • Anyone who reports concerns about other members of staff will not be penalised, and their identification will remain confidential

  • All concerns or incidents should be reported, however small. The safeguarding team may have received other reports, and frequency of concerns is an important factor

  • Concerns will be dealt with sensitively and carefully

Policy preparation and review

Policy prepared by Alex Moore, Centre Manager on 17/02/2018

Policy will be reviewed after 12 months or earlier if there are changes in relevant legislation or in response to any significant incidents or changes in circumstances

Equal Opportunity Policy

Policy Statement

At ECHO, recognition and respect are cornerstones of our belief system. We are committed to the practice and encouragement of tolerance, fairness and inclusivity in everything we do, from the recruitment of our staff to the delivery of our curriculum. We are also aware of our legal obligations under the Equality Act 2010 and of the various codes of practice and guidance documents available to help us meet those obligations in all areas of our work.

The current legislation protects people against discrimination based on the following characteristics:

  • age
  • disability
  • gender reassignment
  • marriage and civil partnership
  • pregnancy and maternity
  • race
  • religion or belief
  • sex
  • sexual orientation

This policy aims to publicize our beliefs and practices such that all interested parties (students, parents, staff, agents etc.) are aware of the importance that ECHO places on non-discrimination, and the consequences that may follow should this policy be breached.



We take care to ensure that all marketing and publicity material accurately reflects our operation. We advertise widely, eliminating the risk of targeting, whether consciously or unconsciously, either student or staff applicants of any particular group. All prospective students/parents are entitled to clear and accurate course information and we endeavour to provide this in alternative formats if requested, for example, translated.

Student enrolment

All students who apply to come and study with us are accepted based on our capacity to fulfil their requirements within the framework of the courses we offer. We will always do our best to accommodate students with disabilities.

Staff recruitment / management

ECHO recruits and manages its staff according to EHRC guidance and codes of practice. As such, staff are selected and progressed solely on their ability to meet the requirements of the job. We will not discriminate against any applicant with a physical disability who is able to meet the requirements of the job without special facilities that ECHO, as described above, may be unable to offer.

Our courses

We are dedicated to treating each of our students as individuals and delivering the same high quality learning experience to everyone, no matter what their background, personal characteristics or learning style. We therefore design our courses and plan our lessons to include a wide range of resources and learning activities, placing the utmost importance in ensuring that these are always free from discriminatory assumptions, images or language. Our goal is to maintain a neutral environment in which nobody feels threatened or intimidated.

Whilst our aim is to expose our students to a full range of issues, thoughts, ideas and materials, including those which may be seen as challenging or controversial, we ensure that our teachers understand their obligation to deliver the content of their classes in a way that does not subject any individual student to discrimination.

Around the school

At ECHO we pride ourselves on our atmosphere of respect, acceptance, kindness and trust. We recognize the fact that diversity is a key feature of the nature of our business, and work to ensure that our students are stimulated, rather than challenged, by the differences between them. Our staff are made explicitly aware of their responsibility for implementing and promoting a culture of tolerance and non-discrimination. Students are warned in the Student Handbook of the possible consequences of any form of bullying or harassment, and reminded of their duty to report any such behaviour they may see.

Breach of policy

ECHO will fully investigate any claims of discrimination or discriminatory practice brought to our attention by staff or by students. If any student or employee is found failing to abide by our Equal Opportunity Policy, serious disciplinary action will be taken.