This policy covers children and vulnerable adults who are applicants or registered students at UCL and establishes safeguarding practices.
This policy covers:
- children and vulnerable adults who are considering applying to become students at UCL, their parents and guardians
- registered students under the age of 18 and students who are vulnerable adults
- any member of the UCL community as they may come into contact with students under the age of 18 and students who are vulnerable adults during their time at UCL
- UCL departments that do not have their own specific safeguarding policies and practices
Departments which offer work or study placements or field trips to their students are required to have their own safeguarding policies and procedures in place.
Additionally, due to the specific responsibilities to their professional bodies, some departments within UCL are required to have local safeguarding policies and procedures in line with the requirements of their governing professional body.
Applicants under the age of 18
There are some extra forms that need to be completed as part of the appliction process for students under the age of 18:
- Guidance for Students and the Parents/Legal Guardians of Students Aged Under 18 on Entry
- Form for parents and guardians
- Emergency contact details
- Form confirming the appointment of a UK guardian
Reporting a Concern
You can use the student of concern form to report a concern about an applicant or registered student under the age of 18 and students who may be vulnerable adults. The report lines are monitored during office hours Monday to Friday from 9am to 5pm.
If you have concerns that a student is in immediate danger of hurting themselves or others you should phone 999 or take them to any Accident and Emergency department.
This policy includes
- policy ownership and status
- guiding principles
- working with children and vulnerable adults
- legal framework
- policies relevant to the safeguarding of children and vulnerable adults
- support for children who are applicants or students at UCL
- under 18 dedicated induction session
- support for vulnerable adults who are applicants or students at UCL
- working collaboratively with the UCL community
- responsibilities and obligations of staff members
- Child: anyone under the age of 18 (Children Act, 1989)
- Young people: children who are 16 to 17 years old
- Age of consent: the legal age to have sex which in the UK is 16 years old*
- Vulnerable adult: a person who has attained the age of 18 and for a range of reasons may be, either temporarily or permanently and in different situations, potentially vulnerable
The full legal definition of ‘vulnerable adults’ as outlined in the Safeguarding Vulnerable Groups Act 2006 can be found on Government’s website.
*Although a child can consent to sexual activity once they reach the age of 16, it is a criminal offence for an adult to engage in sexual activity with a person under the age of 18 where the adult is in a position of trust in relation to the under 18 year old (Sections 3 and 4 of the Sexual Offences Amendment Act 2000 refers). UCL academic and administrative staff, student mentors etc. are considered to be in a position of trust.
The UCL Children and Vulnerable Adults Safeguarding Policy is owned by the Director of Student Support and Wellbeing, Denise Long, based in Student and Registry Services. The Director has the following responsibilities with regard to the policy:
- taking on the role of Designated Safeguarding Lead
- reporting to and supporting the Nominated Senior Officer at UCL (Vice-Provost (Operations)), Fiona Ryland, who has an overall accountability for safeguarding children and vulnerable adults at UCL
- monitoring, promoting and reviewing the UCL Children and Vulnerable Adults Safeguarding Policy and any relevant guidance documents and resources
- acting as a first point of contact for safeguarding concerns unless this resides within a specific programme, academic department or the Human Resources department
- keeping records of all referrals made to her and their outcomes
- working collaboratively with the Director of Human Resources, who is the owner of the UCL Working with Vulnerable Groups policy, UCLU and UCL’s Network of Safeguarding Contacts
The Student Support and Wellbeing Manager (International and Welfare) deputises for the Director in his/her absence.
The Vice-Provost (Operations), the Director of Student Support and Wellbeing, the Student Support and Wellbeing Manager (International and Welfare), all members of the Network of Safeguarding Contacts as well as designated members of the Student Support and Wellbeing and academic departments are required to undertake Disclosure and Barring Service checks and appropriate safeguarding training.
UCL is committed to the safety and wellbeing of all of its students and staff. Providing a secure environment to all applicants and students who come into contact with our services and facilities is of the highest priority.
UCL recognizes that it has social, moral and legal obligations to safeguard the wellbeing and safety of children and vulnerable adults involved in any UCL activities.
UCL advocates a holistic approach to safeguarding, through assessment and proportional management of risk, and integration of good safeguarding practice into all activities.
UCL’s policies and procedures observe the relevant statutory duties and guidance documents, and are informed by any known evidence of good practice across the higher education sector in safeguarding children and vulnerable adults.
The Human Resources Working with Vulnerable Groups policy provides guidance to all UCL staff and students on the expected standards of behaviour when working with children and vulnerable adults, including the responsibilities and processes in reporting any concerns.
The Students’ Union UCL (UCLU) is responsible for providing guidance to all UCLU staff, clubs and societies and for student activities organised by and/or taking place on UCLU’s premises.
At present, there is no legislation in the area of safeguarding that is directed specifically at higher education institutions. The UCL Children and Vulnerable Adults Safeguarding Policy is informed by law and guidance that seek to protect children, namely:
- Children Act 1989Safeguarding Vulnerable Groups Act 2006
- Data Protection Act 1998
- Sexual Offences Act 2003
- Children Act 2004
- Equality Act 2010
- Protection of Freedoms Act 2012
- Counter-Terrorism and Security Act 2015
- relevant government guidance on safeguarding children
The Human Resources Working with Vulnerable Groups policy, which complements the UCL Children and Vulnerable Adults Safeguarding Policy for Applicants and Current Students, provides guidance to all UCL staff and students on the expected standards of behaviour when working with children and vulnerable adults, including the responsibilities and processes in reporting any concerns.
The following UCL policies are also relevant to safeguarding children and vulnerable adults who may come into contact with UCL:
- Health and Safety Policy
- Mental Health Policy
- Policy on Harassment and Bullying
- Taking Action for Equality
- Data Protection Policy
- Freedom of Information Policy
- Personal Relationships Code of Conduct
- Support to Study Policy and Fitness to Study Procedure
- Halls of Residence
- Prevent at UCL
- Students’ Union UCL (UCLU)
Like most universities, UCL is a mainly adult, independent learning environment. Studies and connected activities will involve UCL staff, fellow students and others, and may take place on a one-to-one basis or within a group setting which is likely to involve a cohort of mixed gender and age.
UCL cannot act ‘in loco parentis’ and the ultimate responsibility for students under the age of 18 rests with those who have parental responsibility. Offers of admission to applicants under the age of 18 are made on the understanding that they are equipped to study within a predominantly adult, independent learning environment and are able to act responsibly, appropriately and in accordance with English laws and the regulations of UCL. UCL’s main regulations are described in the summary of the UCL Student relationship.
If housed in UCL managed student accommodation, students under 18 are allocated places in designated halls and are required to complete an under 18’s risk assessment and induction. The Management and Wardenial teams of these halls have received the appropriate security clearance and training in supporting the needs of students under the age of 18.
Some study and social activities may also include off-campus and/or overnight trips. Due to the legal obligation to abide by safeguarding protocols, participation of students under the age of 18 may be subject to risk assessment and participation in some of these activities may not always be permitted.
UCLU’s safeguarding principles should be observed when participating in clubs and societies activities and events organised by the Union. Due to the legal obligation to abide by safeguarding protocols, access and participation to some of these activities and events may be restricted.
UCL does not offer emergency accommodation but there some options are available to students who have found themselves without suitable accommodation.
Facilities and services for students at UCL are designed with a predominantly adult user group in mind. Therefore, it is assumed that students under 18 are competent to make decisions regarding their personal data and their consent is required, in the same way as for adults, with regard to any matters of data protection. In view of this, UCL will not ordinarily share or discuss personal information of students under 18’s with any third parties, including parents or guardians unless the student has submitted a written request asking for us to share their personal information with another named person. Consent for UCL to share information needs to be submitted in writing to the UCL Admissions Office.
The Director of Student Support and Wellbeing on occasion, taking into account UCL’s moral responsibility and its duty of care to a student who is a child, and when there is a reasonable level of concern about the wellbeing and/or safety of a student, may decide to contact their next of kin, parent/guardian and/or emergency contact.
It is mandatory for students under the age of 18 to provide parent/s* and emergency contact details as part of the admissions processes at UCL.
Where parents are not resident within the Greater London area, it will be necessary to appoint a guardian for the student. The guardian is expected to reside in the Greater London area and be a member of the family or a family friend that is known to the student. Agency representatives will not be accepted as guardians. It is necessary that the guardian is made fully aware of their responsibilities by the family. Additionally, UCL expects the following of the guardian:
- to understand and accept the information provided in this policy
- to remain primarily responsible for the student’s personal supervision and welfare
- to provide up to date and full contact details and take the role of a first emergency contact for the student if their emergency contact is not resident within the Greater London area
- to respond to communication from UCL and where appropriate accompany the student to induction sessions and meetings
- in the case of international students, to be involved in his/her travel arrangements and receive them on initial arrival in the UK
*Where the student is primarily cared for by a legal guardian and not a parent, the words ‘legal guardian’ should be assumed.
In addition to the above, all students under the age of 18 are required to provide full emergency contact details. An emergency contact can be a family member or a friend. This information needs to be provided to UCL before a student can be permitted to enrol.
UCL may get in touch with the parent/s, the appointed guardian and/or emergency contacts of students under the age of 18 to verify their details and/or to invite them to a meeting and/or induction events. The student’s permission will not be requested prior to this.
The Student Support and Wellbeing department, under the leadership of the Director of Student Support and Wellbeing, takes a proactive approach in supporting students under the age of 18 studying at UCL.
Students under the age of 18, their parents and guardians, are invited to attend a dedicated induction session at the start of their study at UCL and meet with the Director of Student Support and Wellbeing (or a designated representative) and/or the academic department.
Further sessions and follow up meetings may be arranged for the students by a designated member of staff within the academic department with specific responsibility for students under the age of 18.
Students are made aware that they can contact the Student Support and Wellbeing team for information and assistance and/or a designated member of staff within the academic department if this is needed.
Through the individual academic departments and faculties, all students have access to a wide range of academic, English language (for students whose main language is not English) and pastoral support. UCL works closely with a GP practice which covers the local postcodes and can also see non-registered students as temporary patients if this is needed.
Through Student Psychological Services, UCL provides effective support to any student who may be experiencing emotional and psychological problems. Student Disability Services support students who have longer term mental health conditions, physical disabilities and/or learning difficulties and are able to make reasonable adjustments for these students to ensure they can study as independently as possible during their time at UCL.
UCL provides all new students with an A-Z guide of support services available to them.
The support mentioned above is likely to be sufficient for most of UCL’s students during most of their time at UCL. However, some students may have the potential to be/become vulnerable (either temporarily or permanently) for a variety of reasons and in different situations during their time as a student at UCL.
A student who may become vulnerable during their time at UCL if they:
- have particular needs because of their age
- have a form of disability
- have a physical or mental health problem of such description as is prescribed
- are detained in custody
- are receiving community services because of age, health or disability
- are living in sheltered or residential care home
Not everyone who meets one or more of the criteria listed above is necessarily vulnerable all of the time or at all. However, they become vulnerable if unable, for any reason, to protect themselves against significant harm or exploitation.
Due to the fact that applicants have very limited contact with the UCL community before they become registered students, it is expected that it can be difficult for UCL to identify applicants who may be or have the potential to become vulnerable. However, where an applicant, or a third party whom the applicant is known to, perceives the applicant to be vulnerable, they can contact the Director of Student Support and Wellbeing to discuss support needs by completing the UCL Student of Concern form.
If a member of the UCL community becomes aware that a student may be vulnerable, they should alert the Director of Student Support and Wellbeing as soon as possible by competing the UCL Student of Concern form. The Director will then liaise with the appropriate internal stakeholders and/or external agencies to ensure effective support is put in place for the student.
When supporting a student who is vulnerable, the Director will apply the relevant adult safeguarding principles, namely:
- empowerment: outcomes of the safeguarding process will be discussed and agreed with the student.
- prevention: the student will be provided with information about what abuse is, how to recognise the signs and what support is available
- proportionality: the support offered or put in place will be in the student’s best interests, as they sees them, and stakeholders supporting the student will only get involved as much as this is needed.
- protection: the student will receive help and support to report abuse and will be supported to take part in the safeguarding process to the extent to which they wants to and is able to.
- partnership: any personal and sensitive information about the student will be treated in confidence and only shared on a need to know basis and when this is helpful, internal and external stakeholders will work collaboratively to ensure the best result for the student is achieved
- accountability: the student will be informed of the roles of all who are will be working to support them
UCL recognises that the success of the policy depends on its effective implementation within the UCL community. The Director of Student Support and Wellbeing will ensure that the Policy is disseminated to all UCL staff by ensuring this is included in the agenda of various forums, committees and stakeholder meetings. The policy is published on the UCL website and a link is included in student communication at pre-arrival stage and after students have enrolled at UCL.
All departments recruiting students under the age of 18 are required to have a designated academic and/or administrative staff trained and equipped to support children and vulnerable adults.
With regard to their safeguarding responsibility, these members of staff form part of the Network of Safeguarding Contacts and report to their respective Head of Department, Faculty Tutor or Designated Safeguarding Lead and liaise with the Director of Student Support and Wellbeing as appropriate. The names and contact details of all members of staff are available and easily identifiable on each department’s relevant webpages and are kept up to date.
Information about the responsibilities and obligations of staff members working with children and vulnerable adults is available. However, the guidelines below on handling a conversation regarding their safety and/or wellbeing with a student under the age of 18 or a vulnerable adult may be useful:
If you are having a conversation with a student or applicant under the age of 18 or a vulnerable adult about their safety or wellbeing:
- inform the student that you must pass the information on, but that only those that need to know about it will be told
- listen carefully and stay calm
- make sure that you do not ‘quiz’ the student, you should use open questions and without putting words into their mouth and only to understand what they are telling you
- reassure the student by telling them they have done the right thing in talking to someone
- make a detailed note of the date, time, place, what the student said and did and the questions you asked
- inform your departmental Designated Safeguarding Lead and complete a Student of Concern form to alert the Director of Student Support and Wellbeing of the situation
UCL staff are not expected to investigate concerns or allegations themselves.