Code of Conduct

Creative Mindset

Behaviour and Wellbeing Consultants

Code of Conduct

All staff MUST agree to read, understand and Adhere to the following:

Version	Date	Description	Written / Reviewed By	Next Reviewed date:
1	06/08/22	Initial Policy	Mary Sharon Collins and Danielle Barker	06/08/23
2	27/07/23	Policy Review	Mary Sharon Collins and Danielle Barker	27/07/24
3	27/07/24	Policy Review	Mary Sharon Collins and Danielle Barker	27/07/25
4	04/06/2025	Policy Review	Mary Sharon Collins and Danielle Barker	04/06/2026

This policy was created by the Creative Mindset on  06/8/22  

Signed Mary Sharon Collins and Danielle  Barker   (Directors)  

Introduction
Expected professional standards
Confidentiality
Property, behaviour and appearance
Sexual contact with children and young people and Abuse of trust
Infatuations and crushes
Gifts, Rewards, Favouritism and Exclusion
Social contact and social networking
Physical contact, Personal privacy and Personal care
Behaviour management and physical intervention
One to one situations and meeting with pupils
Transporting pupils
Educational visits
Photography, Videos and other creative arts
Reporting concerns and recording incidents
Monitoring and Review

Code of Conduct for All Adults

Introduction

1.1. The Code sets out the professional standards expected and the duty upon adults to abide by it. All adults have a duty to keep pupils safe, promote their welfare and to protect them from radicalisation (the Prevent Duty), abuse (sexual, physical and emotional), neglect and safeguarding concerns. This duty is, in part, exercised through the development of respectful, caring and professional relationships between adults and pupils and behaviour by adults that demonstrates integrity, maturity and good judgement. Following this Code will help to safeguard adults from being maliciously, falsely or mistakenly suspected or accused of misconduct in relation to pupils.

1.2. For the purposes of this Code, the term and references to ‘adult’ means the following: all employees (whether or not paid or unpaid, employed or self-employed and whether or not employed directly by the Creative Mindset, external contractors providing services to pupils on behalf of the Creative Mindset, volunteers and any other individuals who work for or provide services on behalf of or for the Creative Mindset l to include but not limited to all those detailed in the single central record (as amended). For the purposes of this Code ‘young person/people’, ‘pupils’ and ‘child/ren’ includes all those for whom the Creative Mindset provides education or other services.

1.3. This Code takes account of the most recent versions of the following guidance (statutory and non-statutory):

− ‘Keeping Children Safe in Education’ Department of Education (‘DfE’) (statutory)

− Working Together to Safeguard Children’ HM Government (statutory)

− ‘Guidance for Safer Working Practice for those Working with Children and Young People in Education Settings’ (non-statutory)

This Code cannot provide an exhaustive list of what is, or is not, appropriate behaviour for adults. However, it does highlight behaviour that is illegal, inappropriate or inadvisable in relation to the required professional standards. There will be occasions and circumstances in which adults have to make decisions or take action in the best interests of the pupil where no specific guidance has been given. Adults are expected to make responsible and informed judgements about their own behaviour in order to secure the best interests and welfare of the pupils.

1.4. Any behaviour in breach of this Code by employees may result in action under our disciplinary procedure. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. Creative Mindset will take a strict approach to serious breaches of this Code. Some breaches may be considered low level concerns which may be dealt with informally or formally under the disciplinary procedure.

1.5. Safeguarding and Child Protection policy

Adults have a duty to act in accordance with the Safeguarding and Child Protection policy which is available by Director’s at induction and report any safeguarding, child protection, welfare or radicalisation concerns about a pupil to the Designated Safeguarding Lead.

1.6. Whistleblowing

Adults must raise concerns they have about the safeguarding or child protection practices by following the Whistleblowing Policy, which is available from Directors at Creative Mindset. An adult who raises a matter under the whistleblowing policy or makes a public interest disclosure will have the protection of the relevant legislation.

1.7. Allegations of Abuse Against Staff and Other Employees and Volunteers

Where it is alleged that an adult has:

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

− possibly committed a criminal offence against or related to a child

− behaved towards a child or children in a way that indicates they would pose a risk of harm to children

− behaved or may have behaved in a way that indicates they may not be suitable to work with children

then the Directors will follow the Creative Mindset Procedure for Dealing with Allegations of Abuse Against Staff and Other Employees and Volunteers and the guidance set out in Part Four of Keeping Children Safe in Education DfE which is available from the Creative Mindset One Drive.

1.8. Low Level Concerns

In accordance with Part Four of Keeping Children Safe in Education, a low level concern is defined as behaviour towards a child that does not meet the harm threshold, as outlined in 1.7 above, but is a concern that an adult, working in or on behalf of the Creative Mindset may have acted in a way that:

− is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and

− does not meet the threshold or is otherwise not considered serious enough to consider a referral to the LADO.

Examples of low level concerns could include, but are not limited to:

− being over friendly with children;

− having favourites;

− taking photographs of children on their mobile phone;

− engaging with a child on a one-to-one basis in a secluded area or behind a closed door; or,

− using inappropriate sexualised, intimidating or offensive language.

The Directors are committed to creating and embedding a culture of openness, trust and transparency in which the Creative Mindset’s values and expected behaviours, as set out in this policy, are adhered to, monitored and reinforced by all staff. All adults have a duty to report low level concerns, in addition to concerns that meet the harm threshold, to those with designated safeguarding responsibilities to ensure matters are dealt with promptly and appropriately. The Directors will manage all such concerns in accordance with Part Four of Keeping Children Safe in Education.

In the event that an adult has found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards, the adult should self-refer to those with designated safeguarding responsibilities. The Directors are committed to creating an environment where staff are encouraged and feel confident to self-refer.

Expected Professional Standards

2.1. All adults, as appropriate to the role and/or job description of the individual, must:

−	Place the well-being and learning of pupils at the centre of their professional practice
−	Have high expectations for all pupils, be committed to addressing underachievement, and work to help pupils progress regardless of their background and personal circumstances
−	Treat pupils fairly and with respect, take their knowledge, views, opinions and feelings seriously, and value diversity and individuality
−	Model the characteristics they are trying to inspire in pupils, including enthusiasm for learning, a spirit of enquiry, honesty, tolerance, social responsibility, patience, and a genuine concern for other people
−	Respond sensitively to the differences in the home backgrounds and circumstances of pupils, recognising the key role that parents and carers play in pupils’ education
−	Seek to work in partnership with parents and carers, respecting their views and promoting understanding and co-operation to support the young person’s learning and wellbeing in and out of Creative Mindset.

− Reflect on their own practice, develop their skills, knowledge and expertise, and adapt appropriately to learn with and from colleagues

− Ensure that the same professional standards are always applied regardless of culture, disability, gender, language, racial origin, religious belief and/or sexual identity

2.2. An employee who fails to bring a matter of concern to the attention of senior management and/or the relevant agencies is likely to be subject to disciplinary action.

Confidentiality

3.1. As data controllers, Creative Mindset are subject to the General Data Protection Regulation (GDPR) and Data Protection Act 2018 (“Data Protection Legislation”). In addition, staff owe a common law duty of care to safeguard the welfare of their children. This duty is acknowledged in the provisions governing disclosure of information about pupils.

3.2. Adults may have access to special category personal data about pupils and their families, which must be kept confidential at all times and only shared when legally permissible to do so and in the interests of the child. Records should only be shared with those who have a legitimate professional need to see them. In circumstances where special category personal data needs to be shared, the Data Protection Legislation contains ‘safeguarding of children and individuals at risk’ as a processing condition that allows practitioners to share information without consent if it is not possible to gain consent. In such cases, adults have a duty to pass the information on without delay to those with designated safeguarding responsibilities. See paragraph 18 below.

3.3. Confidential or personal information about a pupil or their family must never be disclosed to anyone other than on a need to know basis and advice should be sought prior to disclosure to ensure such disclosure is in accordance with the Data Protection Legislation, The information must never be used to intimidate, humiliate, or embarrass the pupil. The information must never be used by anyone for their own or others advantage (including that of partners, friends relatives or other organisations).

3.4. Confidential information about pupils must be held securely. Confidential information about pupils must not be held off the Creative Mindset site other than on security protected Creative Mindset equipment. The information must only be stored for the length of time necessary to discharge the task for which it is required.

3.5. If a pupil or parent/carer makes a disclosure regarding abuse or neglect, the adult must follow the Creative Mindset’s procedures and the guidance as set out in ‘Keeping Children Safe in Education’ DfE. Confidentiality must not be promised to the pupil or parent/carer, however, reassurance should be given that the information will be treated sensitively.

3.6. If an adult is in any doubt about the storage or sharing of information they must seek guidance from the Designated Safeguarding Lead (Sharon Collins). Any media or legal enquiries must be passed to senior management.

Propriety, Behaviour and Appearance

4.1. All adults working with children have a responsibility to maintain public confidence in their ability to safeguard the welfare and best interests of pupils. They should adopt high standards of personal conduct in order to maintain the confidence and respect of their colleagues, pupils and the public in general. An adult’s behaviour or actions, either in or out of the workplace, must not compromise their position within the work setting, or bring the Creative Mindset into disrepute. No exhaustive examples of unacceptable behaviour are contained in our disciplinary procedure/rules.

4.2. Adults are required to notify Creative Mindset immediately of any allegation/s of misconduct that are of a safeguarding nature made against them (or implicating them), by a child or adult in relation to any outside work or interest (whether paid or unpaid) and, of any arrest or criminal charge whether child-related or not. Where employees fail to do so, this will be treated as a serious breach of this Code and dealt with under our disciplinary procedure.

4.3. Individuals should not behave in a manner which would lead any reasonable person to:

− Question their suitability to work with children

− Act as an appropriate role model

− Make, or encourage others to make sexual remarks to, or about, a pupil

− Use inappropriate language to or in the presence of pupils

− Discuss their personal or sexual relationships with or in the presence of pupils

− Make, or encourage others to make, unprofessional personal comments which scapegoat, demean or humiliate, or might be interpreted as such

4.4. A person’s dress and appearance are matters of personal choice, self-expression, religious and cultural customs. However, adults must maintain an appropriate standard of dress and personal appearance at work which promotes a positive and professional image. Clothing and footwear must be safe and clean and take account of health and safety considerations. Adults must ensure they are dressed in ways which are appropriate to their role and not likely to be viewed as offensive, revealing or sexually provocative and specifically should not distract, cause embarrassment or give rise to misunderstanding, should be religious and culturally sensitive and free of any political or otherwise contentious slogans, and not considered to be discriminatory. Adults who dress or appear in a manner which may be considered as inappropriate could render themselves vulnerable to criticism or, where the adult is an employee, allegations of misconduct that may lead to action under our disciplinary procedure.

4.5. Personal property of a sexually-explicit nature or property which might be regarded as promoting radicalisation or otherwise inappropriate such as books, magazines, CDs, DVDs or such material on any electronic media including links to such material must not be brought onto or stored on Creative Mindset premises or on any Creative Mindset equipment.

Sexual Contact with Children and Young People and Abuse of Trust

5.1. A relationship between an adult and a child or young person is not a relationship between equals; the adult has a position of power or influence. There is potential for exploitation and harm of children or vulnerable young people and all adults have a responsibility to ensure that an unequal balance of power is not used for personal advantage or gratification. Adults must not use their status or position to form or promote relationships with children (whether current pupils or not), that are of a sexual nature, or which may become so. Adults should maintain appropriate professional boundaries and avoid behaviour which might be misinterpreted by others. They should report any incident with this potential.

5.2. Any sexual behaviour or activity, whether homosexual or heterosexual, by an adult with or towards a child/pupil or young person, is illegal. Children and young people are protected by the same laws as adults in relation to non-consensual sexual behaviour. They are additionally protected by specific legal provisions regardless of whether there is consent or not. Where a person aged 18 or over is in a specified position of trust with a child or young person under 18 years, the Sexual Offences Act 2003 makes it an offence for that person to engage in sexual activity with or in the presence of that child or to cause or incite that child to engage in or watch sexual activity.

5.3. Sexual behaviour includes non-contact activities, such as causing a child or young person to engage in or watch sexual activity or the production of indecent images of children. ‘Working Together to Safeguard Children’, Appendix A defines sexual abuse as “…forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening…”

5.4. Adults must not have sexual relationships with pupils or have any form of communication with a child, which could be interpreted as sexually suggestive or provocative i.e. verbal comments, letters, notes, texts, electronic mail, phone calls, social networking contact or physical contact. The adult should not make sexual remarks to, or about, a child or discuss their own sexual relationships with or in the presence of pupils. Adults should take care that their language or conduct does not give rise to comment or speculations. Attitudes, demeanour and language all require care and thought.

5.5. There are occasions when adults embark on a course of behaviour known as ‘grooming’ where the sole purpose is to gain the trust of a child or young person, and manipulate that relationship so that sexual abuse can take place. Adults should be aware that conferring special attention without good reason or favouring a pupil has the potential to be construed as being part of a ‘grooming’ process, which is a criminal offence.

Infatuations and Crushes

6.1. A child or young person may develop an infatuation with an adult who works with them. An adult, who becomes aware (may receive a report, overhear something, or otherwise notice any sign, no matter how small or seemingly insignificant) that a pupil has become or may be becoming infatuated with them or a colleague, must report this without delay to one the Directors so that appropriate action can be taken to avoid any hurt, distress or embarrassment. The situation will be taken seriously and the adult should be careful to ensure that no encouragement of any kind is given to the pupil. It should also be recognised that careless and insensitive reactions may provoke false accusations.

6.2. Examples of situations which must be reported are given below:

−	Where an adult is concerned that they might be developing a relationship with a pupil which could have the potential to represent an abuse of trust
−	Where an adult is concerned that a pupil is becoming attracted to them or that there is a developing attachment or dependency
−	Where an adult is concerned that actions or words have been misunderstood or misconstrued by a pupil such that an abuse of trust might be wrongly suspected by others
−	Where an adult is concerned about the apparent development of a relationship by another adult or receives information about such a relationship

Gifts, Rewards, Favouritism and Exclusion

7.1. It is against the law for public servants to take bribes. Adults need to take care that they do not accept any gift that might be construed by others as a bribe, or lead the giver to expect preferential treatment. There are occasions when pupils or parents/carers wish to pass small tokens of appreciation to adults e.g. at Christmas or as a thank you and this is acceptable. However, it is unacceptable to receive gifts on a regular basis or of any significant value.

7.2. Personal gifts must not be given to pupils or their families/carers. This could be misinterpreted as a gesture either to bride or groom. It might be perceived that a ‘favour’ of some kind is expected in return.

7.3. Care should be taken when selecting children for specific activities, jobs, privileges and when pupils are excluded from an activity in order to avoid perceptions of favouritism or injustice. Methods of selection and exclusion should be subject to clear, fair and agreed criteria.

Social Contact and Social Networking

8.1. Communication between pupils and adults, by whatever method, should take place within clear and explicit professional boundaries. This includes the wider use of technology such as mobile phones, tablets, text messages, emails, instant messages, websites, social media such as Facebook, Twitter, Instagram, chat-rooms, forums, blogs, apps such as Whatsapp, gaming sites, digital cameras, videos, webcams and other handheld devices. Adults should not share any personal information with pupils and they should not request, or respond to, any personal information from the child/young person, other than that which might be appropriate as part of their professional role. They should ensure that all communications are transparent and avoid any communication that could be interpreted as ‘grooming behaviour’.

8.2. Adults must not give their personal contact details such as home/mobile phone number; home or personal e-mail address or social networking details to pupils unless the need to do so is agreed in writing with senior management. If, for example, a pupil attempts to locate an adult’s personal contact details and attempts to contact or correspond with them, the adult should not respond and must report the matter to their manager.

8.3. It is recommended that adults ensure that all possible privacy settings are activated to prevent pupils from making contact on personal profiles and to prevent pupils from accessing photo albums or other personal information which may appear on social networking sites.

8.4. Adults are personally responsible for what they communicate in social media and must bear in mind that what is published might be read by us, pupils, parents and carers, the general public, future employers and friends and family for a long time. Adults must ensure that their online profiles are consistent with the professional image expected by us and must not post material which damages the reputation of Creative Mindset or which causes concern about their suitability to work with children and young people. Those who post material which may be considered as inappropriate could render themselves vulnerable to criticism or, in the case of an employee, allegations of misconduct which may be dealt with under the disciplinary procedure. Even where it is made clear that the writer’s views on such topics do not represent those of Creative Mindset, such comments are inappropriate.

8.5. Adults are advised not to have any online friendships with any young people under the age of 18 unless they are family members or close family friends. Adults are advised not to have online friendships with parents or carers of pupils. Where such online friendships exist, adults must ensure appropriate professional boundaries are maintained.

8.6. It is acknowledged that adults may have genuine friendships and social contact with parents or carers of pupils, independent of the professional relationship. Adults should, however:

−	Inform Directors of any relationship with a parent/carer where this extends beyond the usual parent/carer/professional relationship
−	Advise Directors of any regular social contact they have with a pupil or parent/carer, which could give rise to concern
−	Inform Directors of any requests or arrangements where parents/carers wish to use their services outside of the workplace e.g. babysitting, tutoring
−	Always approve any planned social contact with pupils or parents/carers with senior colleagues, for example, when it is part of a reward scheme
−	If a parent/carer seeks to establish social contact, or if this occurs coincidentally, the adult should exercise their professional judgment and should ensure that all communications are transparent and open to scrutiny.

8.7. Some employees may, as part of their professional role, be required to support a parent or carer. If that person comes to depend upon the employee or seeks support outside of their professional role this should be discussed with senior management and, where necessary, referrals made to the appropriate support agency.

Physical Contact, Personal Privacy and Personal Care

9.1. There are occasions when it is entirely appropriate and proper for employees to have physical contact with pupils, but it is crucial that they only do so in ways appropriate to their professional role and in relation to the pupil’s individual needs and any agreed care plan. When physical contact is made with pupils this should be in response to their needs at the time, of limited duration and appropriate given their age, stage of development, gender, ethnicity, culture and background. Employees must use their professional judgement at all times. It is not possible to be specific about the appropriateness of each physical contact, since an action that is appropriate with one pupil in one set of circumstances may be inappropriate in another, or with a different pupil.

9.2. Physical contact should never be secretive or casual, or for the gratification of the adult, or represent a misuse of authority. Adults should never touch a pupil in a way which may be considered indecent. If an adult believes that an action could be misinterpreted, the incident and circumstances should be reported as soon as possible.

Date: 6^th August 2022

Signed: Mary Sharon Collins and Danielle Barker

9.3. There may be occasions when a distressed pupil needs comfort and reassurance. This may include age-appropriate physical contact. Adults should remain self-aware at all times in order that their contact is not threatening, intrusive or subject to misinterpretation. Adults should always tell a colleague when and how they offered comfort to a distressed pupil.

9.4. Where an adult has a particular concern about the need to provide this type of care and reassurance they should seek further advice from a Director.

9.5. Some employees, for example, those who teach PE and games, or who provide music tuition will on occasions have to initiate physical contact with pupils in order to support a pupil so they can perform a task safely, to demonstrate the use of a particular piece of equipment/instrument or assist them with an exercise. This should be done with the pupil’s agreement. Contact under these circumstances should be for the minimum time necessary to complete the activity and take place in a safe and open environment. Adults should remain sensitive to any discomfort expressed verbally or non-verbally by the pupil.

9.6. All parties should clearly understand from the outset what physical contact is necessary and appropriate in undertaking specific activities. Keeping parents/carers informed of the extent and nature of any physical contact may also prevent allegations of misconduct arising. Any incidents of physical contact that cause concern or fall outside of these protocols and guidance should be reported to the senior manager and parent/carer.

Behaviour Management and Physical Intervention

10.1. All pupils have a right to be treated with respect and dignity. Adults must not use any form of degrading treatment to punish a pupil. The use of sarcasm, demeaning or insensitive comments towards pupils is not acceptable in any situation. Deliberately intimidating pupils by shouting aggressively, hectoring or overbearing physical presence is not acceptable in any situation. Any sanctions or rewards used should be part of our Behaviour Policy.

10.2. Physical intervention can only be justified in exceptional circumstances. Non-statutory guidance is available from the Department of Education website. Adults may legitimately intervene to prevent a pupil from committing a criminal offence, injuring themselves or others, causing damage to property, engaging in behaviour prejudicial to good order and to maintain good order and discipline. Adults should have regard to the health and safety of themselves and others. It is always unlawful to use force as a punishment. The use of unwarranted physical force is likely to constitute a criminal offence.

10.3. Where a pupil has specific needs in respect of particularly challenging behaviour, a positive handling plan, including a risk assessment, should be put in place and agreed by all parties. Where it is judged that a pupil’s behaviour presents a serious risk to themselves or others, a robust risk assessment that is regularly reviewed and a physical intervention plan, where relevant, must be put in place. All incidents and subsequent actions should be recorded and reported to a manager and the pupil’s parents/carers. Where it can be anticipated that physical intervention is likely to be required, a plan should be put in place that the pupil and parents/carers are aware of and have agreed to. Parental consent does not permit the use of unlawful physical intervention or deprive a pupil of their liberty. Creative Mindset has separate policies on Behaviour and the Use of Physical Intervention.

One to One Situations and Meetings with Pupils

12.1. One to one situations have the potential to make children/young person’s more vulnerable to harm by those who seek to exploit their position of trust. Adults working in one to one settings with pupils may also be more vulnerable to unjust or unfounded allegations being made against them. Adults must recognise this possibility and plan and conduct such meetings accordingly. Every attempt should be made to ensure that the safety and security needs of both adults and pupils are met. Directors should undertake a risk assessment in relation to the specific nature and implications of one to one work for each adult and pupil, which should be reviewed regularly. Where such a meeting is demonstrably unavoidable, it is advisable to avoid remote or secluded areas and to ensure that the door of the room is left open and/or visual/auditory contact with others is maintained. Any arrangements should be reviewed on a regular basis.

12.2. Pre-arranged meetings with pupils away from the premises or on the Creative Mindset site are not permitted unless written approval is obtained from their parent/carer and the Directors.

12.3. No pupil should be in or invited into, the home of an adult who works with them unless they are family members or close family friends, in which case adults are advised to notify their line manager. Pupils must not be asked to assist adults with jobs or tasks at or in their private accommodation or for their personal benefit.

12.5. Other than in an emergency, an adult must not enter a pupil’s home if the parent/carer is absent. Always make detailed records including times of arrival and departure and ensure any behaviour or situation that gives rise to concern is discussed with a Director. A risk assessment should be undertaken and appropriate risk management measures put in place prior to any planned home visit taking place. In the unlikely event that little or no information is available, home visits should not be made alone.

Transporting Pupils

13.1. In certain situations, e.g. out of school activities, adults may agree to transport pupils. Transport arrangements should be made in advance by a Director who will be responsible for planning and overseeing all transport arrangements and respond to any concerns that may arise. Wherever possible and practicable, transport should be provided other than in private vehicles, with at least one adult additional to the driver acting as an escort.

13.2. Adults should ensure that their behaviour is safe and that the transport arrangements and the vehicle meet all legal requirements. They must ensure that the vehicle is roadworthy and appropriately insured and that the maximum capacity is not exceeded. It is a legal requirement that all passengers wear seatbelts and the driver should ensure that they do so. The driver should be aware of the current legislation concerning the use of car seats for younger children where applicable. It is illegal to drive using hand-held phones or similar devices and the driver must ensure that they adhere to all driving regulations.

13.3. It is inappropriate for adults to offer lifts to a pupil, unless the need has been agreed with a Director and, if this falls outside their normal working duties, has been agreed with parents/carers.

13.4. There may be occasions where a pupil requires transport in an emergency situation or where not to give a lift may place a pupil at risk. Such circumstances must always be recorded and reported to a Director and parents/carers.

Educational Visits

14.1. Adults should take particular care when supervising pupils in the less formal atmosphere of an educational visit, particularly in a residential setting, or after-school activity. Adults remain in a position of trust and the same standards of conduct apply.

Photography, Videos and other Creative Arts

16.2. Many educational activities involve the taking or recording of images. This may be undertaken as part of the curriculum, to celebrate achievement or, to provide evidence of the activity. An image of a child is personal data and it is, therefore, a requirement under Data Protection Legislation that explicit consent is obtained from the parent/carer of a child before any images are made such as those used for Creative Mindset’s web sites, notice boards, productions or other purposes, unless an alternative legal justification for processing this data is applicable.

16.3. Adults need to be aware of the potential for such images to be taken and/or misused to create indecent images of children and/or for ‘grooming’ purposes. Careful consideration should be given as to how these activities are organised and undertaken. There should be an agreement as to whether the images will be destroyed or retained for further use, where these will be stored and who will have access to them.

16.4. Adults should remain sensitive to any pupil who appears uncomfortable and should recognise the potential for misinterpretation. It is also important to take into account the wishes of the child, remembering that some children do not wish to have their photograph taken.

16.5. Adults should only use equipment provided or authorised by the Creative Mindset to make/take images and should not use personal equipment, mobile telephones or any other similar devices to make/take images.

16.6. The following guidance should be followed:

−	If a photograph is used, avoid naming the pupil
−	If the pupil is named, avoid using the photograph
−	Photographs/images must be securely stored and used only by those authorised to do so
−	Be clear about the purpose of the activity and about what will happen to the photographs/images when the lesson/activity is concluded
−	Only retain images when there is a clear and agreed purpose for doing so
−	Ensure that a senior colleague is aware that the photography/image equipment is being used and for what purpose
−	Ensure that all photographs/images are available for scrutiny in order to screen for acceptability
−	Be able to justify the photographs/images made
−	Do not take images of pupils for personal use
−	Only take images where the pupil consents to this
−	Do not take photographs in one to one situations
−	Do not display or distribute photographs/images of pupils unless there is consent to do so from the parent/carer
−	Only publish images of pupils where they and their parent/carer have given explicit written consent to do so
−	Do not take images of pupils in a state of undress or semi-undress
−	Do not take images of pupils which could be considered as indecent or sexual

− Do not take images of a child’s injury, bruising or similar (e.g. following disclosure of abuse) even if requested by children’s social care

− Do not make audio recordings of a child’s disclosure

Reporting Concerns and Recording Incidents

18.1. All adults must report concerns and incidents in accordance with the guidance set out in Keeping Children Safe in Education. In the event of an allegation being made, or incident being witnessed, the relevant information should be immediately recorded and reported to the Directors, or Designated Safeguarding Lead, as appropriate. Where low level concerns are raised the Directors of Designated Safeguarding Lead should speak to the individual involved and any witnesses and consider the matter under the Disciplinary Procedure which may result in informal or formal action. If any concerns are raised via a third party, the Directors or Designated Safeguarding Lead should collect as much evidence as possible. An employee who fails to bring a matter of concern to the attention of senior management and/or the relevant agencies will be subject to disciplinary action.

18.2. In addition to behaviours outlined elsewhere in this Code and, the types of abuse and neglect set out in Keeping Children Safe in Education DfE, the following is a non-exhaustive list of some further behaviours which would be a cause for concern:

An adult who:

−	Allows a pupil/young person to be treated badly; pretends not to know it is happening
−	Gossips/shares information inappropriately
−	Demonstrates inappropriate discriminatory behaviour and/or uses inappropriate language
−	Dresses in a way which is inappropriate for the job role
−	Does not treat pupils fairly – demonstrates favouritism
−	Demonstrates a lack of understanding about personal and professional boundaries
−	Uses their position of trust to intimidate, threaten, coerce or undermine
−	Appears to have an inappropriate social relationship with a pupil or pupils
−	Appears to have special or different relationships with a pupil or pupils
−	Seems to seek out unnecessary opportunities to be alone with a pupil

Monitoring and Review

19.1. The Directors are responsible for monitoring the implementation, use and effectiveness of this policy and will report on these matters annually or more frequently if necessary.

19.2. This policy will be reviewed by the Directors as necessary.

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