CODE OF CONDUCT POLICY

The Digital Native UK (sometimes referred to as ‘The Centre’) Code of Conduct aims to promote the key issues of respect and self-discipline. This Code gives clear guidance with regard to Digital Native UK’s high expectations regarding Apprentices’ behaviour both inside and outside The Centre and when apprentices are working on their apprenticeship during their Off The Job (OTJ) time.

Attendance

Digital Native’s apprenticeships are planned around apprentices completing their Off The Job training flexibly. This can be through a mix of; attending one of the delivery centres for 1-3 days / month, working remotely on nominated dates with their coach, or by agreement for on employer premise delivery.

The Apprenticeship day starts at 9:30am and finishes at 4:30pm with 30 mins for lunch.
Digital Native recognises that full attendance and punctuality is key to success.
Any variation from the agreed schedule must be requested by the apprentice’s manager and discussed with a Digital Native Coach for approval.

Attendance and punctuality are the responsibility of all apprentices and will be closely monitored by Digital Native coaches.
Where attendance and/or punctuality does not meet the above, the apprentice’s employer will be informed.
NB: For apprentices who are under 19 or considered vulnerable, parents / guardians / supporters will also be informed.

Digital Native recognised that from time to time apprentices may be unable to attend the delivery centre as required.
In these circumstances apprentices must report any absence by sending an email to the attendance email address before 9am of the day of absence.
The apprentice’s employer will be notified of this absence.
For an unreported absence, at 10 am Digital Native will attempt to contact the apprentice and then their employer.

All attendance at a Digital Native centre or remote work should be recorded by the apprentice in their ‘Off The Job’ OTJ tracker.
Digital Native may also record attendance through facial recognition software and manual registers.
If requested apprentices are required to register with the facial recognition system.
This data will be processed to track and monitor attendance and retained in accordance with our GDPR policy.

At Digital Native we behave in a manner that allows good learning to occur

• We are quiet and attentive at the start of sessions
• We bring all required equipment/kit
• We arrive on time
• We listen to others when they are speaking
• We behave in a way that allows everyone to learn.
• We follow instructions from all members of staff.

We respect others’ point of view and rights as individuals

• We treat students and staff with respect.
• We are polite.
• We always use appropriate language
• We produce our own work
• We always use non-violent means to solve problems
• We are aware that certain items are prohibited in The Centre (e.g. knives, cigarettes, illegal substances etc).

We behave outside Digital Native UK in a manner that enhances our reputation

• We take pride in our work attire
• We only gather in small groups
• We always use appropriate language
• We use litter bins for our rubbish
• We behave in a considerate manner towards members of the local community.

We move calmly and quietly around the centre and wider environment

• We talk quietly and not shout
• We walk, not run

We take care of the Digital Native UK environment

• We only eat in the designated areas
• We take care of the centre property, including furniture, resources, IT equipment
• We encourage others to use litter bins for their rubbish
• We do not chew gum

Drugs and Alcohol

• Drugs, alcohol and tobacco have no place at Digital Native UK.

Being Healthy

• Choose not to take illegal drugs.
• Promotion of healthy lifestyles for young people.
• Know the dangers associated with the use of alcohol or smoking of tobacco.

Staying Safe

• Reduce the risk of students turning to crime to pay for drugs, alcohol or tobacco.

Enjoy & Achieve

• Students who are leading a healthy lifestyle will be less likely to be absent from their apprenticeship place
• Enable students to achieve to their full potential at Digital Native UK

Making A Positive Contribution

• Reduction of offending behaviour and/or fixed period or permanent exclusions.
• Enable students to deal with life changes and challenges in a positive way .

Achieve Economic Well Being

• Increase student’s future chances of accessing further education, training or employment.
• Increase student’s chances of living in decent housing conditions in adult life.
• Decrease chances of material deprivation in adult life.
• Decrease chances of students living in low income or workless households in adult life.
• Students who bring drugs to the centre or use drugs in the centre may be punished using any Digital Native UK sanctions. External agencies, including the police, may be informed.
• Exclusion, including permanent exclusion, is a probable response to drug dealing on Digital Native UK premises or drug usage.
• Staff who abuse substances or encourage substance abuse may face disciplinary action.
• We will inform and involve parents in any instance of substance misuse.

Definition Of “Drugs”

The Government defines “Drug Misuse” as the non-medical use of drugs that are only intended for use in medical treatment, and the use of drugs that have no accepted medical purpose. Such drugs are controlled under the Misuse of Drugs Act 1971. (The Act does not cover solvent misuse). We further believe that the word ‘Drugs’ includes all mood and performance changing substances, both legal and illegal, and including prescribed drugs, alcohol, tobacco and solvents.

Medicines

Many drugs are lawfully carried as medicines. If students supply prescription drugs to others in the centre, they are acting unlawfully and so this policy applies.

The Law on Drugs

It is an offence under the Misuse of Drugs Act 1971:

• To supply or offer to supply a controlled drug to another in contravention of the Act;
• To be in possession of, or to possess with the intent to supply another, a controlled drug in contravention of the Act; it is a defence to the offence of possession that, knowing or suspecting it to be a controlled drug, the accused took possession of it for the purpose of preventing another from committing or continuing to commit an offence and that as soon as possible after taking possession of it he/she took all such steps as were reasonably open to him/her to destroy the drug or to deliver it into the custody of a person lawfully entitled to take custody of it;
• For the occupier or someone concerned in the management of any premises knowingly to permit or suffer on those premises: the smoking of cannabis, or the production, attempted production, supply, attempted supply, or offering to supply any controlled drug.

Digital Native UK procedures

The centre will liaise closely with the local police force to ensure that there will be agreement for dealing with any incidents which might arise involving illegal drugs. The staff dealing with an incident will, wherever possible, take possession of any substance suspected of being a controlled drug. The centre will hand the substance to the police who will be able to identify whether it is an illegal drug; centre staff should not attempt to analyse or taste any unidentified substance. Whenever possible any quantity of the suspected substance must be taken to a secure place e.g. the centre office. This should be done in the presence of the person from whom it has been taken and another adult. The suspected substance must be placed in a sealed envelope and the details/time/quantity should be recorded on the outside. The envelope should then be placed in a locked cabinet in the centre office.

Where students are suspected of concealing illegal drugs on their person, every effort should first be made to secure the voluntary production of any unlawful substance, e.g. by asking them to turn out their pockets and bags in the presence of another adult. If the student refuses, the police should be called in to deal with the situation. Where a member of staff is told, or is aware, of possible criminal activity outside of the centre, they must inform a director of Digital Native UK who will inform the police, in the interests of safeguarding the health and safety of young people in the area.

All incidents involving illegal drugs must be reported to a director of Digital Native UK. Parents must be informed of the incident as soon as is possible.

A director of Digital Native UK will retain the responsibility for deciding how to respond to particular incidents involving illegal drugs. The director will consider each incident individually and recognise that a variety of responses may be necessary. The implications of any action taken will be considered very carefully.

Outside of Digital Native UK: Procedures

Digital Native UK has no role in dealing with drug incidents outside the premises of Digital Native UK, and their employment hours other than:

• To the extent that the effect of some substances may persist into their apprenticeship time.
• By passing information onto relevant agencies when the safety or well being of students is threatened in line with the Every Child Matters Agenda.
• To assist police in preventing the use of premises surrounding the centre for drug trading.

The following has been provided and will contribute to, but not constrain, a director of Digital Native UK decision making:

Whether:

• The substance known/admitted?
• The substance legal? If not, into which category does it fall?
• There any intention to supply to others?
• The quantity such that it could only be for personal use by the possessor
• The possessor has been of previous good conduct?

Summary of responses available:

1. Confiscation of the substance.
2. Offering counselling
3. Referral to Health Education Unit/Coordinator
4. Institute disciplinary procedures
5. Inform the police of any relevant information

Taking into consideration the above and the individual circumstances of each case the centre will institute disciplinary proceedings within the context of their policy. Accordingly, infringement of the centre standards by involvement in a drug related incident(s) will be regarded as a serious breach of the centre’s behaviour and discipline policies, for which the centre reserves the right if considered appropriate in all the circumstances to implement permanent exclusion even for “one off” events.

In the interests of safeguarding the education and/or welfare of all the students at Digital Native UK, there is zero tolerance of drug dealing/supplying (including selling, offering and distributing to other students). Accordingly, save in exceptional circumstances, any students will be permanently excluded from the programme for drug dealing/supplying. A student may also be permanently excluded for repeated instances of possession or use of drugs on the centre premises.

Signs of Drug Misuse or Substance Misuse

Early detection of drugs misuse is extremely important. If a young person’s drug misuse is identified at an early stage, it is easier for action to be taken to prevent further misuse of drugs. Staff should be alert to the warning signs which may indicate that a student is misusing drugs. Staff need to be particularly vigilant when they are in charge of activities which take groups away from the centre premises.
Some of the main signs which may be associated with drug misuse:

• continually increasing the dose of drugs to get the same effect
• a feeling of dependency on drugs or a fear of stopping using drugs
• withdrawal symptoms if they stop taking the drug for a short time
• sudden mood changes,
• a negative or changed outlook on life,
• a loss of motivation,
• poor performance at work or training,
• problems with personal relationships,
• borrowing or stealing money from friends and family, and
• being secretive about activities and actions (www.nhs.uk)

The presence of these signs alone is not conclusive proof of drug or solvent misuse; many of them are part of normal adolescence. All incidents must be reported initially to a member of staff.

Media Contact

It is important that staff do not report incidents and/or issues concerning drug misuse to the local press and media generally. A director of Digital Native UK will deal personally with all media matters.

THE COMPLAINTS POLICY

At Digital Native we care about complaints. Complaints matter for everyone using our services, who deserve an explanation when things go wrong and want to know that steps have been taken to make it less likely to happen to anyone else. They matter because every concern or complaint is an opportunity to improve. Complaints may signal a problem and we need to know as a business how to improve at all times and at all opportunities.

Complaints matter because they tell us about the quality of our delivery. They tell us about how responsive a member of staff is, how safe, effective, caring and well-planned they are.

Digital Native place feedback from people who use our services at the heart of our work because every concern is an opportunity for us to improve the quality of our provision. We also want to hear about positive experiences so we can highlight good and outstanding services.

We take complaints seriously – and we expect our staff to do so too. All apprentice inductions describe complaints handling. Poor practice will be found and acted on. Good practice will be shared.

We work to make it easier to give us good quality feedback, and work with our staff/associates to improve apprentice experience.

SCOPE

This policy applies to all apprenticeship provision provided by Digital Native. We want to provide good-quality services for everyone, but things sometimes go wrong.  If they do, we need to know about them so that we can put them right and learn from them.  This will help us to improve our performance.

HOW WILL WE DO THAT?

We will make it easy for apprentices to make a complaint by doing the following.

Giving you the chance to make a complaint:

• in person to their coach
• feedback form that goes to the board of directors
• email: hello@dn-uk.com
• by phone 0121 623 7230 Option 2

WHAT IS A COMPLAINT?

Anyone who feels that they have had a poor service from us, or from someone providing the service for us, and have tried to get the problem solved by speaking to someone in the relevant department. This will affect you and will need a particular response from us.

WHAT HAPPENS THEN?

Except in exceptional circumstances, every attempt will be made to ensure that both the complainant and Digital Native maintain confidentiality. However, the circumstances giving rise to the complaint may be such that it may not be possible to maintain confidentiality (with each complaint judged on its own merit). Should this be the case, the situation will be explained to the complainant.

RESPONSE FROM US

We will acknowledge your complaint within two working days of receiving it.  We will tell you the name of the person who is dealing with your complaint.  You will receive a full response within five working days.  If this is not possible, we will send you an email explaining why there is a delay and saying when you will receive a full response.

SOLUTIONS

If your complaint is accepted, the person involved will try to solve the problem by doing the following.

• Apologising to you and explaining what went wrong
• Providing the service you are entitled to receive
• Changing procedures so that the mistake is not repeated
• Asking you to detail any recommendations of areas where we can improve our performance concerning the information, advice and guidance given

EQUALITY AND DIVERSITY

Apprentices have the right to express dissatisfaction with the services they receive from Digital Native. Apprentices using this policy can expect to be treated fairly and without discrimination.

As part of the Prevent strategy we promote the Fundamental British Values to reflect life in modern Britain. These values are Democracy, Rule of Law, Respect and Tolerance, Individual Liberty.

Fundamental British Values underpin what it is to be a citizen in a modern and diverse Great Britain valuing our community and celebrating diversity of the UK.

Fundamental British Values are not exclusive to being British and are shared by other democratic countries as a way of creating an orderly society, where individual members can feel safe, valued and can contribute for the good of themselves and others.

These will mirror our principles and values and all the work areas that we support. These will occur throughout our programmes and will be promoted by all staff.

DISSEMINATION OF THE COMPLAINTS PROCEDURE

The Complaints Procedure shall be:

• Discussed upon induction and form part of the policies on the training plan
• Included in the apprentice induction
• Available on the Digital Native website dn-uk.com
• The web link will form part of the training plan signed by employer, apprentice and Digital Native

COMPLAINTS PROCEDURE STAGE 1

The Stage 1 procedure has three stages:

• Informal
• Formal 1 – Director
• Formal 2 – Board of Directors/governance board

INFORMAL

Apprentices who wish to raise issues about the conduct of coaches may request an informal meeting with one of the directors. The purpose of the meeting is to enable the apprentice to talk through and clarify any issues they have concerning their apprenticeship; a record will be kept of such meetings. The meeting should be requested within two weeks of the event occurring.

FORMAL 1

If this meeting fails to resolve the matter to the satisfaction of the apprentice then a director will conduct a meeting with the coach or staff member in question to explore the substance of the apprentice’s complaint.

A record will be kept of action and timescale agreed and a director will report this back to the apprentice within three working days. If subsequent action fails to resolve the matter, within the timescale, then the apprentice has the right to initiate the second stage of the formal complaint.

FORMAL 2

If an apprentice wishes to complain, the complaint is lodged in writing with a director within ten days of the previous stage of the procedure being completed or expiry of agreed informal action timescale. The director:

• Formally acknowledges receipt of the
• Sets a date for the complaint to be considered by the board of directors/governance board
• Notifies the appropriate external agency (if appropriate) that a complaint has been lodged and gives details of how it will be heard, including the composition of the complaint

We would request that you substantiate any complaints or allegations with as much written factual evidence as you can.  It might be that we contact you for further information if required in order to investigate any complaint raised, please ensure you enclose contact details. This will assist in reaching a speedy conclusion to the complaint.

The board of directors meets to consider the complaint within 28 working days of the date of receipt of the complaint

OUTCOME

The outcome of the complaint shall also be recorded, together with reasons for that decision, with the outcome falling into one of the following categories:

• Complaint resolved
• Complaint dismissed
• Complaint to be dealt with under another procedure
• Complaint upheld and the appropriate action deemed to be one of:
• Counselling
• Training
• General supervision
• Other management action including disciplinary

FURTHER INFORMATION

Education and Skills Funding Agency Complaints:

https://www.gov.uk/government/publications/complaints-about-post-16-education-and-training-provision-funded-by-esfa/complaints-about-post-16-education-and-training-provision-funded-by-esfa  (Updated April 2024)

BCS Complaints: Separate Policies attached

ASSESSMENT EXAMINATION OR EPA DECISION APPEALS

Digital Native aims to provide a high-quality service to all our apprentices. However occasionally, individuals may be unhappy about some aspect of their training or assessment which may give rise to concern. Each apprentice has the right to appeal against an assessment decision if he/she feels that a decision is unfair.

This process is designed to ensure concerns are dealt with effectively and in the shortest possible time

HOW DO I APPEAL?

• If you feel that you have been wrongly or unfairly treated, you should, in the first instance, speak to the coach concerned to try and resolve the problem informally within 2 weeks of the assessment/feedback taking place.
• If the issue remains unresolved then the apprentice should submit a formal letter of appeal to Tony Harper (curriculum director) (within two weeks of feedback provided), with the details of the qualifications and any supporting evidence.
• If the appeal remains unresolved as a result of the curriculum director’s review of the evidence provided, the appeal will then be referred to the EPA organisation.
• Should the apprentice remain unhappy with the decision then the apprentice has the right to appeal to the relevant awarding body/EPA, within 7 days.
• The awarding body/EPA decision is final.

QUALITY ASSURANCE

The Quality Manager will monitor the appeals procedure, in order to ensure that quality standards and the effectiveness of the procedure are maintained.

The Quality Manager will ensure that records on any matters related to the Appeals Procedure are maintained. These records will be held securely and remain confidential to the parties involved.

FURTHER POINTS TO RAISE

• If at any stage of the appeal you require any guidance, support or further assistance you should speak to a member of the senior management team. Alternatively, you could speak to your coach (if appropriate). Any help you seek will be in the strictest confidence.
• It is important that if you make the decision to appeal you appreciate that no one will proceed further without your agreement. If you feel your concern has been resolved, you can withdraw at any stage.
• Any apprentice who thinks that there are circumstances outside the course, such as health or personal problems, which could adversely affect their performance in any form of assessment should bring these to the attention of the coach as soon as possible before the relevant assessment.
• Any apprentice who believes that the assessment is taking place in conditions, which could significantly adversely affect their performance, should bring these to the attention of the coach at the time of the assessment.

COUNTER FRAUD AND ERROR POLICY 

1. Introduction

The legal definition of fraud is: ‘The making of a false representation or failing to disclose relevant information, or the abuse of position, in order to make a financial gain or misappropriate assets’. As an organisation we have a duty to our stakeholders to take all reasonable steps to prevent fraud and theft occurring.  Fraud could potentially be committed by staff, associates, learners, subcontractors, suppliers, contractors, other organisations or members of the public.  

2. Scope of the Counter Fraud and Error Policy 

All staff and associates have a responsibility for reporting practices which they think may be fraudulent. The primary responsibility for preventing fraud and theft lies with senior managers who have put in place policies, procedures and training to protect the organisation.  Digital Native have an identified Fraud Prevention Lead who will oversee: 

• Our approach to the identification of risks 

• The drafting and implementation of policies and procedures designed to prevent fraud 

• The development of a culture which complies with our policies and procedures 

• The promotion of fraud awareness and the training of staff and associates 

• The investigation of any issues which need further examination 

Senior leaders have also put in place a Board which includes external members.  The Fraud Prevention Lead will be responsible for reporting to the Board which will provide guidance on the role and expectations of the Fraud Prevention Lead.  The Board and the Fraud Prevention Lead will seek to ensure that we implement legislation and respond proactively to any guidance issued by the DfE/ESFA and other funders. 

The Fraud Prevention Lead will be responsible for investigating any allegations and for ensuring appropriate action is taken.  All matters which are deemed to require investigation will be reported to the Board, regardless of the nature of the allegation or the outcome of the investigation.  Digital Native is also contractually required to notify the DfE/ ESFA immediately it becomes aware of any instance of suspected fraud or financial irregularity. 

All staff and associates have a responsibility to be aware of the potential for fraud and to take steps to minimise risks to the organisation (including theft). Staff should ensure that they are familiar with the Whistleblowing Policy which is shared with all staff and associates at induction and is available under policies in the coaches section of the portal. 

Depending on the nature of the issue we will also report issues of potential theft or fraud to our insurers and to the police. 

3. Policy Statement 

Our intention as an organisation is to ensure that we maintain robust control mechanisms to both prevent and detect fraud and theft. All staff and associates have a responsibility to protect the assets of the organisation and should be alert to the potential for fraud and theft. Confidential processes are in place to report suspected theft or fraud to either the Fraud Prevention Lead, Directors or to the Board.   Where required a response plan will be produced which documents the detailed process for investigating the issue/allegation.  All allegations of theft and fraud will be investigated in a consistent and timely manner.  

Fraud is one or more of the following:  

False representation. “False” in this respect means the representation must be untrue or misleading, and the person making it must know it is, or might be, untrue or misleading.  

Failing to disclose information that one is under a legal duty to disclose. 

Abuse of a position in which one is expected to safeguard, or not act against, the financial interests of another person. To commit this offence the person’s conduct must be dishonest with the intention of making a gain or causing a loss to another.  

Theft means dishonestly appropriating property, including money or other assets.  

4. Examples of fraud

• Associate staff claiming payment for hours they have not worked; 

• Staff claiming mileage for journeys they haven’t made; 

• Claiming to have qualifications in an application/interview that they do not have; 

• Working for another organisation whilst claiming sick pay; 

• Falsely ordering goods or services for personal benefit; 

• Knowingly submitting falsified/incorrect data returns to the ESFA or other funders, resulting in the inaccurate/overstated funding claims (ILR Fraud). 

For the purpose of this policy an act will be considered fraudulent if it involves the use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to the organisation or another party.  

The best protection against fraud and theft is through staff and associates adhering to the organisations procedures and not being inhibited to challenge matters which do not appear to be correct.  

If a staff member or associate is at any time unsure of policy/ procedures they should seek guidance and support from the Fraud Prevention Lead. 

The emphasis at Digital Native is on the development of a culture that values ethical behaviour and financial probity and has a zero tolerance policy towards fraud and theft.  

5. Procedure

The prevention and detection of fraud and theft is made possible by having strong internal controls constantly applied. Routine checks and monitoring by management to ensure that procedures are being followed are, therefore, essential especially in those areas where risk of fraud and theft is greatest.  

The primary responsibility for the prevention and detection of fraud and theft lies with management through the implementation, documentation and operation of effective systems of internal control. Monitoring of compliance with controls by management will be reinforced by reviews conducted by internal staff and from time-to-time externally appointed funding and compliance specialists. 

As an organisation we expect all suspicions about fraud and theft to be reported and investigated. Our Fraud Response Plan is attached to this policy and will be implemented when fraud is suspected or alleged. 

The organisation will always attempt to recover any sums lost through fraud or theft using the civil and/or criminal law and relevant insurance policies. 

1. Monitoring, Review and Evaluation  

 

This policy/procedure will be reviewed every 12-months or in response to changes to legislation or best practice, whichever is the sooner. The Fraud Prevent Lead is responsible for monitoring and reviewing this policy reporting to Board. 

 

 

Annex A  

 

FRAUD RESPONSE PLAN  

Purpose  

This response plan provides a documented framework for the Fraud Prevention Lead (and if necessary other managers) to follow if fraud or theft is suspected or reported. 

The plan seeks to ensure that in the event of fraud or theft timely and effective action is taken to prevent further losses, identify fraudsters, safeguard evidence, minimise adverse effects on the organisation and learn lessons.  

Reporting fraud & theft  

All actual or suspected incidents of fraud and theft should be reported without delay to the Fraud Prevention Lead who will normally also be the Investigating Officer.  

Where the Fraud Prevention Lead is suspected of fraud or theft the report should be made to one of the Directors or to the Board who shall in turn appoint an Investigating Officer.   

When reports of fraud or theft are made, the suspicions will be treated seriously, and all details provided will be recorded accurately and in a timely manner. The decision by someone to report a suspected fraud may be traumatic for them, and those reporting fraud are assured that all information will be treated in the strictest confidence.  

Anonymity will be preserved where it is reasonably practicable to do so.  

The Fraud Prevention Lead will be responsible for liaising with the Board and this should be done in a timely manner in all instances where a potential theft or fraud is reported.  At this stage, management should take steps to prevent further losses, for example by suspending payments without compromising evidence or alerting the alleged fraudsters. 

The Fraud Prevention Lead must also consider the need to report the issue to the DfE/ESFA or other funding bodies as required by contracts or funding rules. 

Initial enquiry  

On receiving details of a suspected theft or fraud, the Fraud Prevention Lead will undertake an initial review and decide if any further action will be required, liaising in a timely manner with the Directors and the Board. 

The further action may include referral to: 

Board of directors: fraudulent activity is a breach of contract and where there are reasonable grounds for suspicion, then suspension may be required pending the outcome of enquiries.  

The Police: delays in contacting the Police may prejudice the gathering of evidence and future enquiries.  

DfE/ESFA/Other Funders: in accordance with contractual obligations and funding rules. 

 

 

Conducting an Investigation 

The Fraud Prevention Lead should decide the detailed remit and scope of the investigation and also determine the investigation timescales, reporting arrangements and deadlines ensuring that any investigation by the police is not compromised. 

The Fraud Prevention Lead (or other trained member of staff) as nominated by the Fraud Prevent Lead, should undertake an internal investigation, producing a report of their findings with all details being recorded fully and accurately.  If the issue is complex, the Fraud Prevention Lead may need to produce interim reports documenting progress and intended next steps. 

The report should see to identify (where possible) any losses attributable to the fraud/theft.  This report may need to be made available to the police and also to insurers.  

Where necessary and appropriate the disciplinary policy will also be followed. 

Concluding an investigation  

At the end of the investigation, irrespective of the outcome, the Fraud Prevention Lead should review the position and see what lessons can be learned. Such reviews will help identify any weaknesses in controls that initially led to the fraud/theft and should highlight any deficiencies that should be addressed.  

On completion of the review, a detailed report should be submitted to the Board for consideration. The report should cover the description of the incident, the loss incurred, the people involved and means of perpetrating the fraud. It should set out the measures taken to prevent a recurrence and any timetabled actions for monitoring.  

Equality Policy Statement

 

Digital Native’s vision is to be a company that is valued by all its stakeholders, which achieves exceptional results in all different aspects of its business. Key to achieving this, Digital Native is committed to providing an excellent training service, contributing to the wider regeneration and sustainability of local communities. We understand that in order to provide the commitment necessary to realise this vision, we must exemplify the principles of promoting equality and valuing diversity in all our activities, as a service provider and as an employer. These ambitions can only be achieved through people. Digital Native employees will reflect the culture, values and ambitions that Digital Native will aim to achieve.

 

Digital Native priority will be to tackle all forms of discrimination and exclusion across the main protected characteristics, recognising that any one person may be disadvantaged on more than one of these grounds. We also recognise that there may be other groups who may be vulnerable to discrimination. Digital Native Equality Policy applies to the recruitment, selection, education and assessment of apprentices and in the recruitment, selection, training, appraisal, development and promotion of staff, the only consideration must be that the individual’s abilities and needs, in relation to the requirements of the programme post.

If requirements are met, no apprentice or employee will be discriminated against on the basis of their sex, sexual orientation, race, colour, ethnic origin, nationality (within current legislation), disability, marital status, sexuality, caring or parental responsibilities, age, or beliefs on matters such as religion and politics. Digital Native is committed to provide a learning, working and social environment in which the rights and dignity of all its members are respected, and which is free from discrimination, prejudice, intimidation and all forms of harassment including bullying.

This policy means that all apprentices and employees of Digital Native have the right to study or work in an environment free from discrimination, prejudice and all forms of harassment or bullying. Digital Native has a ZERO tolerance approach to bullying and harassment.

Digital Native is committed to a programme of action to ensure that this and other equalities policies are implemented and monitored at an organisational and individual level. Digital Native seeks to employ a workforce which reflects the diversity of the wider community. It does so because it values the individual contribution of people irrespective of sex, age, disability, sexual orientation, race, religion or belief, gender, gender reassignment, maternity, or because someone is married or in a civil partnership, or any other personal characteristics. Digital Native will treat all employees with dignity and respect and will provide a working environment free from unlawful discrimination, victimisation or harassment on the grounds of any of the protected characteristics or other personal characteristics. The protected characteristics are:

• Age
• Disability
• Sex
• Gender reassignment
• Pregnancy & maternity
• Race
• Sexual orientation
• Religion or belief
• Married or in a civil partnership

 

 

Digital Native will not tolerate acts that breach the Equality and Diversity policy and all instances of such behaviour, or alleged behaviour, will be taken seriously, be fully investigated and may be subject to the Company’s disciplinary procedures. Additionally, any person found to be inciting, encouraging or condoning discriminatory actions or behaviour may be subject to disciplinary action.

Digital Native values innovation and feels that diversity within the team and client base brings positive benefits that will improve and strengthen the business.

The adoption of a Diversity Policy goes further than simply complying with the letter of the law. It aims to get the best from people by treating them fairly and with respect and providing a safe and rewarding working environment. There are sound operational as well as ethical reasons for having a policy which supports and encourages staff to develop and demonstrate their full potential, including:

• Attracting and retaining employees from the wider community
• Selecting the best person for the role
• Improving individual and corporate performance
• Creating a healthy and constructive working atmosphere and organisational culture
• Enhancing staff morale
• Demonstrating to clients and the community that the Company is a fair and diverse organisation, representative of the local community.

 

The Senior Leadership Team are committed to developing and maintaining policies and working practices designed to promote equality of opportunity and to address the elimination of discrimination of any form, in particular discrimination in relation to ‘protected characteristics’.

Digital Native will ensure that discrimination in any form is challenged and addressed in all its activities. It will through systematic reviews, ensure that its policies, procedures and practices address any potential or actual discrimination or disadvantage and regular monitoring and evaluation of their effectiveness will be undertaken.

Digital Native will actively challenge discrimination through reviewing its processes, attitudes and behaviour supported with appropriate staff training programmes. Digital Native grievance procedure will make it clear that instances of discrimination and/or harassment should be raised with the coach in the first instance to reflect Digital Native intolerance of such behaviour.

Digital Native will monitor and evaluate the effectiveness of the Equality and Diversity policy with its employees, customers and associated partners. Recruitment records, along with reports from complaints, incidents, safeguarding and feedback interviews will be discussed by the directors and, where necessary, any changes can be implemented

Equity for staff will be supported by policies and practices which foster:

 

• equitable recruitment and promotion procedures for all staff
• a staff composition which reflects closely the communities we serve
• a non-sexist, non- racist and disability supportive working environment
• a monitoring and feedback system capable of highlighting areas for improvement
• considering and acting upon feedback from staff when reasonably practical to do so.

 

 

 

 

 

 

 

 

 

WHAT IS MEANT BY “EQUALITY”?

 

Equality is ensuring individuals or groups of individuals are treated fairly and equally and no less favourably, specific to their needs, including areas of race, gender, disability, religion or belief, sexual orientation and age.

Promoting equality should remove discrimination in all of the following factors; sex, sexual orientation, marital status, ethnic origin, race, religion, colour, nationality, political beliefs, disability and age should not be taken into account for the purposes of:

 

STAFF:

Recruitment, appointment, training, appraisal, promotion, discipline etc.

APPRENTICES:

Application to and acceptance on to a course of study, and assessment of academic performance

Selection for a course of study or for a job should be made solely on merit

 

RESPONSIBILITIES

 

The Directors are responsible for ensuring:

• The Company implements and follows its equality and diversity policies and codes of practice and meets its legal responsibilities.
• A consistent and high-profile lead on equality and diversity.
• Promotion of equality and diversity inside and outside the training organisation.
• Policies and procedures are in place to comply with all applicable legislation.
• The Company implements its equality and diversity policies and codes of practice.
• Quality audits are carried out in all areas of Equality & Diversity.
• There is baseline data on admission used to ensure learner progression and for staff recruitment and career progression and this is reported to the board of directors
• That all staff and apprentices know their responsibilities and receive the necessary support and training.
• Making sure that staff know about Digital Native Equality and Diversity policy and that any kind of harassment or discrimination is not acceptable.
• Keeping a look out for changes in behaviour
• Challenging inappropriate behaviour, taking prompt action wherever there is evidence of bullying or harassing behaviour, whether or not anyone has complained.
• Checking that office banter is appropriate and not upsetting anyone
• Always take issues seriously where required
• Investigate all allegations with consistency and an open mind
• Listen carefully without bias to what employees have to say
• Making sure that staff know they can approach you if they have a problem.
• Do not jump to premature conclusions about the validity of a particular complaint
• Always do a follow up after any issue or complaint to ensure that the matter has been properly resolved
• Discuss promptly with your coach any complaint of bullying or harassment
• Ensure you are familiar with all HR policies and procedures
• Ensure you lead your team by observing the Digital Native Code of Conduct at all times
• Relevant procedures and actions are followed in cases of unfair discrimination, harassment or bullying.

 EMPLOYEES AND VOLUNTEERS ARE RESPONSIBLE FOR:

 

• Co-operating with the Company to ensure that this policy is effective to ensure equal opportunities and to prevent discrimination.
• Promoting equality and diversity, and avoiding unfair discrimination.
• Reviewing on an annual basis the existing policy.
• Challenging, reporting and analysing any incidents of unfair discrimination racial, sexual or other stereotyping perpetrated by staff, volunteers and apprentices.
• Keeping up-to-date with equality law and participating in equality and diversity training.
• Employees should also bear in mind that they can be held personally liable for any act of unlawful discrimination.
• We all have a responsibility to help create and maintain a work environment which celebrates diversity and promotes equality.
• Being aware of how your own behaviour may affect others and changing it, if necessary – you can still cause offence even if you are ‘only joking’
• Treating your colleagues with dignity and respect
• Making it clear to others when you find their behaviour unacceptable unless it should be obvious in advance that this would be the case
• Taking steps to stop harassment or bullying and giving support
• Making it clear that you find harassment and bullying unacceptable
• Reporting equality and diversity issued and harassment or bullying to your director and supporting the Company in the investigation of complaints
• If a complaint relating to equality and diversity or harassment or bullying is made, not prejudging or victimising the complainant or alleged harasser.
• Staff who feel they require support and guidance should contact a director.

 

 

APPRENTICES ARE RESPONSIBLE FOR:

 

• Participating in equal opportunity and diversity training.
• Respecting others in their language and actions.
• Having an input into policy amendments.
• Reporting instances of unfair discrimination, or racial, sexual or other stereotyping.
• Implementing the Company’s equality and diversity policies and codes of practice.

 

 

Digital Native will seek to involve and consult staff on the Equality and Diversity policy, action points and any other equality and diversity initiatives as appropriate. Digital Native has a number of methods of consulting with and involving staff including:

 

• Team meetings and daily stand up

• Cultural events
• Information bulletins and information
• Interactive quality management system

 

DISCRIMINATION

 

   The following are the kinds of discrimination which are against the Company’s policy:

 

Direct discrimination: where a person is less favourably treated than another person because of a protected characteristic they have or are thought to have. An example is if someone is refused entry onto a learning programme on the grounds that he or she is black, disabled, homosexual, of a

particular religion or belief or she is a woman

Associative discrimination: this is direct discrimination against someone because they associate with another person who possesses a protected characteristic.

Perceptive discrimination: this is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic.

Indirect discrimination: where a requirement or condition which cannot be justified is applied equally to all groups but has a disproportionately adverse effect on one particular group. Some examples are:

• where an age limit for new recruits may exclude many women of that age group because they are unable to apply for the job as a result of family commitments, or
• the restricting of recruitment to areas where there are few ethnic minorities, or
• Victimisation: where an individual is treated less favourably because they have made or supported a complaint or raised a grievance under the Equality Act; or because they are suspected of doing so. An employee is not protected from victimisation if they have maliciously made or supported an untrue complaint.

 

 

HARASSMENT

 

Harassment may be defined as unwanted conduct related to a relevant protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.

The key is that the actions or comments are viewed as demeaning and unacceptable to the recipient. Please refer to our Bullying and Harassment policy for more information.

We will treat all our Employees with dignity and respect and will provide a working environment free from bullying or harassment on any grounds.

We will not tolerate acts that breach this policy and all instances of such behaviour, or alleged behaviour, will be taken seriously, be fully investigated and may be subject to our disciplinary procedures. Additionally, any person found to be inciting, encouraging or condoning such behaviour may be subject to disciplinary action.

Digital Native will not tolerate acts which breach this policy including third parties such as employers and clients. Staff who feel they require guidance and support should contact their director.

Employees are also protected from harassment because of perception and association.

 

 

 

GENDER EQUALITY

 

We will work with our partners to eliminate sexual harassment, support victims and take action against perpetrators.

Definitions:

• Sexual Discrimination: Occurs when someone is treated unfairly or less favourable than others in the same circumstances, on the basis of their gender.
• Direct Discrimination: Direct sexual discrimination occurs when a person is treated less favourably than others, in comparable circumstances, on the basis of their gender. For example- An assumption that women are more suited (or not suited) to certain types of work, or are more (or less) available for certain jobs than their male counterparts.
• Indirect Discrimination: Indirect sexual discrimination occurs when a condition or requirement is applied which adversely affects or favours one particular group more than another- For example “must have two years’ unbroken service” as a requirement would discriminate unfairly against women, due to women having maternity leave. Indirect discrimination can also occur where sexual harassment is used to create a hostile, abusive or offensive working environment.
• Sexual Harassment: “unwanted conduct of a sexual nature, or other conduct based in sex, affecting the dignity of men and women at work. This can include unwelcome physical, verbal and non-verbal conduct” (European Commission)
• Sexual Victimisation: Occurs when a person victimises another person for bringing a claim or giving evidence in connection with a claim of discrimination or harassment.

 

 

Digital Native believes that the organisation will benefit from engaging employees at all levels of responsibility and across all areas of work regardless of their sexual orientation. Digital Native recognises the right of every person to be treated in accordance with these values. Digital Native employees of all sexual orientations have a statutory right to fair treatment under s12 Equality Act 2010. The Act sets out a framework for eliminating employment or occupational inequalities based on sexual orientation, i.e. to ensure there will be no discrimination against employees, either directly or indirectly, on the grounds of sexual orientation in access to employment, training, promotion or dismissal, in the provision of work-place benefits, or the provision of references.

It is Digital Native’s aim to create an inclusive company where people are enabled to meet their full potential and are treated as individuals. This includes recognising and supporting a person’s self-identity as male or female. Digital Native is committed to ensuring that transgender people are treated with respect and that it does not discriminate unlawfully. This commitment is an important aspect of our overall commitment to providing equal opportunities in employment and to ensure that no current or prospective members of staff are subject to discrimination or victimisation as a result of the gender in which they present themselves.

 

  DISABILITY EQUALITY

 

We will ensure that the working environment is accessible and meets the needs of disabled people, taking into consideration particular needs as required.

Ensure that we work with our partners to eliminate harassment of disabled people, support victims and take action against perpetrators.

 

Ensure that information we provide is accessible to disabled employees.

Definitions:

S6 Equality Act 2010 defines a disabled person as someone with ‘A physical or mental impairment, which has a substantial and long term adverse effect on his or her ability to carry out normal day to day activities’. The definition is complex and it is important not to think too narrowly when considering whether a person is disabled or not. For example hidden disabilities such as epilepsy and diabetes are included within the definition.

 

 

• Mental impairments include learning, psychiatric and psychological impairments. However where an impairment concerns mental health, it falls within the definition only if the condition is clinically recognised, such as schizophrenia, manic depression, and severe and extended depressive psychoses.
• A person’s impairment amounts to a disability only if it affects their ability to carry out day to day activities.
• Staff who have a disability and consider that they may fall within the definition may wish to record this with Digital Native and contact their director.

 

 

REASONABLE ADJUSTMENTS:

 

• Digital Native has a statutory duty to make reasonable adjustments and conduct health and safety risk assessments to avoid discrimination against disabled employees or prospective employees. Adjustments are a means of levelling the playing field to help disabled people contribute fully to the work force and enable that person to perform the job.

 

• Adjustments apply to all aspects and stages of employment and needs are always considered during: recruitment, selection, training and induction, transfers, promotion, opportunities for training and career development, terms and conditions, employee benefits, retention, redundancy and dismissal.
• Types of adjustments will be discussed with the directors and, in conjunction with advice from a medical professional and other professional advisory bodies may include: alter premises, allow absences during working hours for rehabilitation assessment or treatment, supply additional training, acquire special equipment or modify existing equipment, modify instructions or reference manuals (this list is not exhaustive).

 

 

 

RACE EQUALITY

 

We will ensure that we work with all partners to eliminate racial harassment and racially motivated crime, support victims and take action against perpetrators.

Digital Native will take steps to ensure that applications are attracted from all races and will ensure that there are equal opportunities in all stages of the recruitment process. Where appropriate, staff responsible for recruitment will receive training in equal opportunities, and guidance will be available to all staff. Promotion within the Company is based solely on merit.

 

Digital Native main centre is in a diverse area of the United Kingdom and where ever possible we actively promote applications from clients from our local centre for jobs at Digital Native.

 

 

RELIGION OR BELIEF

Digital Native welcomes all people regardless of their religions, philosophical beliefs and faiths and is strongly committed to promoting equality of opportunity in all its activities. Members of any religion, followers of any faith or belief and those without religious belief will be treated with equal dignity, respect and fairness.

Digital Native is committed to protecting and promoting the rights of every member of the community to freedom of thought, conscience and religion, freedom of expression and freedom of association. These rights apply to people with or without formal religious affiliation, of all faiths and none, and provide for the principle of respecting other people’s freedom to express their beliefs and convictions. However, any expression of belief has to take account of the rights and reasonable sensitivities of others.

Some religions require their followers to pray at specific times during the day. Staff may therefore request access to an appropriate quiet place to undertake their religious observance. Many religions or beliefs have special festival or spiritual observance days. An employee may request holiday in order to celebrate festivals or attend ceremonies. Digital Native are sympathetic and will consider such a request where it is reasonable and practical for the employee to be away from work, and they have sufficient holiday entitlement in hand.

If it is practical and safe to do so, staff may welcome the opportunity to wear clothing consistent with their religion. Staff should contact their director for guidance.

 

 

AGE

Age discrimination in employment is unlawful. The UK legislation protects people of all ages in employment. Direct and indirect discrimination, victimisation and harassment are covered in all aspects of employment including unfair dismissal and redundancy provisions.

Digital Native recognises the contributions that people of all ages can bring, and welcomes and believes that all employees should, wherever possible, be permitted to continue working for as long as they wish to do so.

 

 

RECRUITMENT

 

The Company applies selection processes for both internal and external applicants which ensure the appointment of the highest quality staff.

As part of our commitment, Digital Native will aim to:

• Ensure all appointments are fair and free from discrimination;
• Ensure that the operation of the Recruitment and Selection policy processes delivers fair and evidenced equality of treatment for all applicants.
• Improve retention rates as the right people are recruited for the right roles

 

 

 

The Company’s selection criteria are designed to give applicants every opportunity to demonstrate their skills and abilities in a variety of relevant activities and to learn as much as they can about our Company and the role they are applying for. Activities may include: criteria based interviews, presentations and written exercises.

A person specification should link to the job description and outline the skills, experience and knowledge a person needs.

It is our policy to advertise vacancies in publications that are relevant to the nature and level of the job.

In line with our policy Digital Native positively encourages applications from suitably qualified and eligible candidates regardless of sex, gender, race, disability, age, sexual orientation, or religion or belief, gender reassignment, maternity or because someone is married or in a civil partnership. At the interview or selection stage questions are asked, and where appropriate tests set, to check for the skills and competences needed for the post. Interviewers will not ask personal questions which may be perceived to be intrusive and imply potential discrimination. Where applicants volunteer personal information, those selecting will not to be influenced by such information.

The Company will take steps to ensure that applications are attracted from all sexes, races and from disabled people, and will ensure that there are equal opportunities in all stages of the recruitment process. Where appropriate, staff responsible for recruitment will receive training in equal opportunities and guidance will be available to all staff.

Promotion within the Company is based solely on merit and without regard to race, sex, disability, sexual orientation, religion or belief.

The business development director will monitor recruitment and selection practices through the collection of equal opportunities monitoring data, which will be reviewed and used to inform improvements and changes in processes where required.

 

DISCIPLINARY

 Acts of discrimination or harassment by employees of the Company may result in disciplinary action. The Company will treat seriously and consider resolutions when any employee has a grievance as a result of discrimination or harassment.

It may be difficult for individuals experiencing discrimination or harassment to bring the matter formally into the open. Support and guidance will therefore be made available, in confidence, to people wishing to pursue this avenue. Formal complaints may be made in writing initially to their director.. All investigations will be carried out in the strictest confidence and all people involved in the investigation will be expected to respect this confidentiality. Only once the facts have been established will a course of action be recommended.

Should any person feel that an investigation has been managed in an inappropriate or unfair manner

they may appeal to the Managing Director.

Please refer to the Disciplinary and Grievance policies for further information.

​HARASSMENT AND ANTI-BULLYING POLICY 

​The Every Child Matters (ECM) Agenda states that all young people have the right to be healthy, be safe, enjoy and achieve, make a positive contribution and achieve economic wellbeing. This document details how Digital Native UK (known also as ‘the centre’) aims to prevent and tackle unpleasant and intimidating behaviour at our premises, so allowing the fulfilment of the ECM agenda and permitting apprentices to fulfil their potential. 

• ​We will take bullying seriously 

• ​We will make sure young people who experience bullying know how to get help and support. 

• ​We will offer services to young people who bully others to help understand the consequences of their actions. 

• ​We will monitor services to make sure they are working to the agreed anti bullying standards. 

​The Ethos of Digital Native UK 

​In order for students to fulfil their potential both academically and socially and to meet the criteria of ‘Every Child Matters’ we want to ensure the safety and welfare of students at Digital Native UK. The centre believes in an ‘inclusive approach’ for all young people and any barriers to their learning or development need to be minimised. We recognise social barriers such as bullying do exist. This will not be tolerated and needs to be tackled. It is made clear to all our students that bullying will be dealt with seriously. Challenging bullying effectively will improve the safety, happiness and performance of students. It also improves confidence, performance and attendance of vulnerable students, and provides guidelines and controls for students whose behaviour is a concern. 

​What is Bullying? 

​The Anti-Bullying Alliance (ABA) defines bullying as:
“The repetitive, intentional hurting of one person by another, where the relationship involves an imbalance of power. Bullying can be carried out physically, verbally, emotionally or through cyberspace”. Bullying is a form of discrimination. This is when a person or a group of people are treated differently because of a perceived difference and/or prejudice. These differences can be a range of things for example; race, educational achievement, height, sexuality, weight, accent, gender or name. 

​Types of Bullying: 

• ​Racist, Religious and Cultural bullying. Racial taunts, graffiti, gestures. The Race Relations Act 1976 states that schools and governing bodies have a duty to ensure that students do not face any form of racial discrimination, including attacks and harassment. We see this to include Digital Native UK as an apprenticeship provider. 

• ​Sexual. Unwanted physical contact or abusive comments. 

• ​Homophobic. Any hostile or offensive action against lesbians, gay males or bisexuals or those perceived to be lesbian, gay or bisexual. 

• ​Abuse of the vulnerable. For example, children with physical disabilities, on the autism spectrum, or with special educational needs. Bullying also happens to children who are carers or children who have experienced a divorce or death in the family. 

• ​Emotional bullying; such as ridicule and exclusion, seems to be more common than physical violence and it can also be more difficult to cope with or prove. 

• ​Cyber bullying. New methods have also followed this old problem—texting, cruel photos from mobile phones, emails and web-based attacks are increasingly prevalent. 

​Bullying may occur in the form of name-calling or exclusion or it can escalate to aggressive and intimidating actions that prevent students from taking advantage of the opportunities that the centre provides. 

​If Bullying Occurs – A General Overview 

​Digital Native UK has a range of options for students to seek advice and get help. We consistently reinforce the message to inform someone of any incidence of bullying immediately and that dealing with bullying is everyone’s responsibility. 

​Tutors – encourage students to discuss issues/problems with them. This information will be treated with respect and due seriousness.
Directors – Discuss any issues with a director of Digital Native UK
Web-based Reporting and information – where pupils can email tutors directly to report incidents of bullying. 

​How Digital Native UK will deal with bullying 

• ​When a bullying incident is reported, those accused of bullying and witnesses of the incident will be asked to write down an account of what has taken place. All those involved will be interviewed by their tutor. 

• ​Bullying incidents will be recorded by the tutor for future reference and all documentation to do with specific incidents will be placed on the student’s files. 

• ​If a student either admits to bullying or it can be been proved beyond reasonable doubt that they have taken part in this behaviour then the following methods and sanctions can be used: 

• ​The incident will be reported to their parents and a meeting arranged in centre to discuss the matter and the action to be taken. 

• ​Once the bullying incident has been resolved, and the victim of the bullying considers the matter closed, a support programme will be put in place for the person who did the bullying. The centre recognises that people who bully have often been victims themselves. Parents may attend a meeting with their child’s tutor to discuss the incident and to agree the appropriate action to be taken. The centre relies on the support of parents in matters such as this to stop the problem continuing and to help the child improve their behaviour 

​How we can prevent bullying: 

• ​We must all raise awareness of bullying throughout the centre by addressing all students, parents and staff teaching and non-teaching. 

• ​We must all publicly acknowledge that Digital Native UK considers bullying to be unacceptable, and is committed to dealing with it. 

• ​We must all help to create and support a culture of care and consideration for others. 

​Coaching Staff 

​The important thing is to establish environments where bullying is less likely to occur. This may be by setting boundaries around ‘courtesy’ and ‘respect’. You may need to get some background information on a teaching group and how they work together.
You also need to: 

• ​Set clear boundaries about expected standards of behaviour 

• ​Act on information given out by other members of staff 

• ​Encourage students to talk to you about their concerns 

• ​Think carefully about the seating plan. 

• ​Minimise problems by seating pupils away from potential difficulties 

• ​Discuss the role of the ‘bystander’ in bullying – talk about what bystanders need to do if they witness bullying 

​Parents 

​Parents are often best placed to detect changes in behaviour or attitude which might indicate that a child is upset or unhappy and that bullying may be taking place.
Parents should also: 

• ​Set clear boundaries about expected standards of behaviour at home 

• ​Encourage your son or daughter to talk to you about their concerns 

• ​Use a ‘significant other’ adult if your son/daughter doesn’t wish to talk to you 

• ​If necessary, approach the centre to discuss any difficulties 

• ​Report any incidents of bullying to staff as soon as possible. Please do not wait until for the bullying to ‘develop’. 

• ​Discuss the role of the ‘bystander’ in bullying – talk about what bystanders need to do if they witness bullying 

​Apprentices 

• ​The Golden Rule is to tell someone! 

• ​Bullying can happen through no fault of your own, don’t let it build up. You must act immediately when anything happens 

• ​Try not to be confrontational or spiteful. 

• ​Don’t act as an ‘audience’ for bullies. So don’t stand and watch or encourage, either walk away or go and tell someone 

• ​Don’t be a ‘bystander’. If you witness something, report it (even if it’s anonymous). You’d like someone to do the same if it was you being bullied 

​How can we help? 

​Staff and Directors 

• ​Students and parents need to have faith in the system and students need to feel confident that the centre will take the matter seriously. 

• ​Digital Native UK will encourage students to empathise with others and encourage social and emotional behavioural skills throughout . 

• ​Centre staff will take every opportunity to make it clear to all students that bullying is unacceptable. This will be done through reinforcement within the centre. 

• ​Students will be told that bullying (verbal or physical) is not tolerated in the centre. Everyone is expected to ensure that bullying does not happen and everyone has the responsibility to tell someone – this is not telling tales. 

​Parents 

• ​Encourage your child to be assertive but not confrontational in their manner. 

• ​Encourage them to talk openly with them about any social problems at the centre and reiterate that bullying’ is not something that should be tolerated. 

​Apprentice 

• ​Students need to work as a team and realise they are all members of the same community. 

• ​Students need to support the efforts of each other, and celebrate the different skills and interests that each person brings 

• ​It is unrealistic to assume that everyone will get on with each other at all times, but no student has the right to make their apprenticeship an unpleasant experience for another student. 

• ​Tell a member of staff Telling about bullying isn’t ‘telling tales’ or ‘grassing’. You have the right to be safe from attacks and harassment and you should not be silent when you are being hurt. 

• ​Tell a friend what is happening. Ask them to help you. It will be harder for the bully to pick on you if you have a friend 

• ​Try to ignore the bullying or say ‘No’ firmly, then turn and walk away. Don’t worry if people think you are running away. Remember, it is very hard for the bully to go on bullying someone who won’t stand still to listen. 

• ​Try not to show that you are upset or angry. Bullies love to get a reaction. If you can keep calm they might get bored and leave you alone. 

• ​Don’t fight back if you can help it. 

​What is Restorative Justice? 

​Digital Native UK is committed to moving towards Restorative Justice as a way of resolving bullying issues. ‘Restorative Justice’ brings the ‘victim’ and ‘perpetrator’ together to discuss their actions and 

​be aware of how their actions have affected another person. It accepts conflict is part of life and it allows students to take responsibility for their feelings and behaviour and is a good way to repair the damage caused. It does not make the ‘perpetrator’ less responsible, but looks at reparations for damage done. Joan Nash, Cabinet Member for Schools “When people take responsibility for what they have done it is much more effective in stopping them from re-offending than a punishment”. 

​Apprentice Friendly Advice and Guidance on Bullying 

​In most cases the two-people involved will be encouraged to eventually come face to face and realise the hurt and pain they may have caused, restoring justice and building bridges.
What you can remember to do: 

• ​Treat others as you want to be treated! 

• ​Be respectful to everyone in the community 

• ​If you witness something unpleasant, report it (even if it’s anonymous). 

• ​If you are unhappy – tell someone! The sooner we know the sooner we can help! 

• ​Don’t act as an ‘audience’ for bullies. So don’t stand and watch, walk away and tell someone 

• ​Everyone is different and that is what makes us so special – difference is not a bad thing – celebrate it! 

• ​If someone is being unpleasant to you, be ‘assertive’ but not ‘aggressive’ when dealing with bullying. If you feel able, tell the bully clearly to stop – this isn’t always easy. If no one knows you need help then no one can help you! 

​If you have a problem to do with friends or bullying then you can talk to any of the people mentioned below, but you should have a good relationship with your tutor so they would probably be the best person. 

​We would hope that you feel comfortable talking to at least one member of staff about your problems, but if you don’t, then you might want to contact the following people: 

• ​Childline Freephone 0800 111 111 

• ​childline.org.uk, 

• ​NSPCC 0808 800 500 

• ​nspcc.org.uk. 

• ​Anti-Bullying Campaign 01713 781 446 

• ​Parent Line 01702 559 900 

• ​Samaritans 0345 909090 / 01452 306 333 

​Cyber Bullying 

​Technology is utilised both in and out of the centre as a source of valuable information to further students  learning. However Digital Native UK recognises that cyber-bullying is on the increase and needs to be tackled.
Cyber bullying includes: 

• ​Text messaging 

• ​Mobile phone calls 

• ​Picture/video clips (via mobile phone cameras) 

• ​Email 

• ​Chat rooms 

• ​Instant Messaging 

• ​Websites (such as Bebo, Myspace, Facebook) 

​What to do 

​Apprentices 

• ​Do not reply to any message 

• ​Report it to a member if staff or parent (if it occurs out of the apprenticeship environment then it will become a police matter) 

• ​Save the message as evidence 

​Parents: 

• ​Encourage your child to have an open relationship and talk about any problems they might have 

• ​Take an interest (but don’t be intrusive) in what they do on the internet. 

• ​Make it clear that cyber bullying is bullying! It is unacceptable, but without them talking about it no one can do anything to stop it! 

​Staff: 

• ​We realise that you cannot control what students do with their mobile phones and computers outside of Digital Native UK 

• ​Make it clear that bullying of any kind will not be tolerated and will be dealt with. 

• ​Ensure mobile phones are not used during lesson unless specific to a task 

​ 

HEALTH AND SAFETY POLICY

It is the policy of Digital Native UK, so far as is reasonably practicable, but in accordance with the relevant legislation, statutory requirements and good practice, to ensure the health and safety of staff, students and visitors to the training facility located at the Innovation Campus.

This statement sets out the commitment of the senior management of Digital Native UK to implementing this policy, provide leadership in health and safety and ensure that proper consideration and support are given to health and safety provisions, as appropriate.

In practical terms the responsibility for ensuring the safe performance of any activity rests with those who have, to any degree, the management, stewardship, supervision or control of it, or, who arrange and direct it, as well as with those who carry it out. Everyone must have regard for health and safety and the importance of maintaining appropriate standards.

Digital Native UK considers that health and safety procedures are about the management of risk and not necessarily about the complete elimination of risk. Their purpose is not to prevent activities on the grounds that an element of risk exists, but to enable activities to be undertaken in a reasonably safe manner.

Digital Native UK is also committed, as far as is reasonably practicable, to ensuring:

• The prevention of injury and health impairment to all those affected by the activities of the training facility
• The promotion of good practice in health and safety and the promotion of a health and safety culture across the company.
• The promotion of a positive and healthy working environment for staff and students and continued improvement in overall health and safety performance.

In pursuance of these commitments, Digital Native UK’s objectives are to:

• Integrate awareness of health and safety requirements into everyday working activities and managerial systems.
• Appropriately resource health and safety management and the implementation of this Policy Statement through the provision of adequate personnel, support, expert assistance, competent advice, time and funding.
• Provide and maintain premises and equipment that are without significant risk to health, safety and welfare.
• Consult and work with employees and employee representatives on health, safety and welfare matters.
• Identify all significant hazards that may arise through the activities undertaken and to assess the risks arising from these and to institute effective control measures to eliminate, minimize or manage these risks so as to enable those activities to occur.
• Supplement this Policy with more detailed Policy Standards and information on particular hazards and risks.
• Implement safe systems of work that eliminate or control, all significant hazards and risks to health, safety and welfare.
• Provide such information, instruction, training and supervision as is necessary to ensure the health and safety of staff, students and others.
• Implement a monitoring, inspection and auditing procedure to ensure effective management of health and safety throughout the company.
• Encourage staff to set good standards of health and safety by personal example so that students leaving the facility take with them a positive attitude of mind to health and safety.
• Make arrangements for the dissemination of relevant information, co-ordination of policy and practice and cooperation with other employers, employees and students of the shared premises / facility.
• Make arrangements for the dissemination of relevant information, co-ordination of policy and practice and co-operation with employees of other employers and contractors who may be required to work at the facility controlled premises.
• Promote a healthy lifestyle amongst staff and students.
• Keep all Health and Safety Policies, Policy Standards and procedures under review so that important and relevant legislation, Codes of Practice and appropriate guidance are taken into account.
• Keep informed about and comply with government advice for the education sector as it relates to COVID or other public health matter.

Introduction

Digital Native is committed to preventing modern slavery and human trafficking in all its operations and supply chains. We uphold the highest standards of integrity and ethical conduct in all our business dealings.

Our Commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business relationships.

Scope

This policy applies to all persons working for Digital Native or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, and business partners.

Our Practices

• Risk Assessment and Due Diligence: We conduct regular risk assessments of our operations and supply chains to identify and mitigate the risk of modern slavery.
• Supplier Code of Conduct: We expect our suppliers to adhere to the same high standards and take steps against forced, compulsory, or trafficked labour; this includes productive, value-adding, unpaid internships.
• Training and Awareness: We train our employees to ensure they understand the risks of modern slavery and how to report any concerns.
• Reporting and Whistleblowing: We encourage all employees and business partners to report any concerns related to modern slavery to one of the directors. We have a confidential whistleblowing policy in place to protect those who report in good faith.

Responsibility for the Policy

The directors is responsible for ensuring that this policy complies with our legal and ethical obligations. The compliance team is responsible for implementing and monitoring the policy’s effectiveness.

Review and Updates

This policy will be reviewed annually and updated as necessary to ensure it remains relevant and effective in combating modern slavery.

The Privacy Policy

This privacy policy is for this website; [www.dn-uk.com] and served by Digital Native Ltd, Innovation Birmingham, Holt Street, Birmingham, West Midlands B7 4BB and governs the privacy of its users who choose to use it. It explains how we comply with the GDPR (General Data Protection Regulation), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations).

This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR, DPA & PECR are adhere to. Additionally it will explain the use of cookies or software, advertising or commercial sponsorship from third parties and the download of any documents, files or software made available to you (if any) on this website. Further explanations may be provided for specific pages or features of this website in order to help you understand how we, this website and its third parties (if any) interact with you and your computer / device in order to serve it to you. Our contact information is provided if you have any questions.

The 2018 Data Protection Act

Digital Native and this website complies to the 2018 Data Protection Act.

Apprentice Data Statement

During recruitment and induction all apprentices before providing personal information are informed of how and why Digital Native will share their data and how long their data will be retained for. Upon induction to the apprenticeship, each apprentice will be asked to confirm:
“I have read the below Data Protection Act 2018 statement and consent to Digital Native processing my data”

The apprentice acknowledges the following statement:
To register you for your apprenticeship, Digital Native needs to collect personal data about you. We need to share this data with:

– The Education Skills Funding Agency (ESFA) – the government department who fund your apprenticeship. –
– The Office for Standards in Education (OFSTED)
– The British Computer Society (BCS) – they are the End Point Assessment Organisation (EPA) for Apprenticeship Standards.
– ACE360 – they process data on behalf of the BCS and the ESFA.

– Pluralsight – Apprentices will have an account created on Pluralsight using their name and Digital Native email address.

Digital Native will retain this information along Apprentice portfolios for 6 years inline with ESFA funding audit guidelines.

Use of Cookies

This website uses cookies to better the users experience while visiting the website. As required by legislation, where applicable this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of /saving of cookies on their computer / device.

What are cookies?

Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

Website Visitor Tracking

This website may use tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

Adverts and Sponsored Links

Digital Native is not funded by adverts or sponsors, none of our websites or online resources contain sponso links or adverts.

Remarketing

This website uses cookies when you visit our website and the websites and apps where we display advertisements. This information may include the content you view, the date and time you viewed this content and the location associated with your IP address. We use this information to serve you more relevant advertisements. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. You can opt out of personalised advertisements on Facebook by visiting Facebook’s Ad settings.

Downloads & Media Files

Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti virus software or similar applications.

We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti virus software or similar applications.

Contact & Communication

Users contacting this us through this website do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.

Where we have clearly stated and made you aware of the fact, and where you have given your express permission, we may use your details to send you products/services information through a mailing list system. This is done in accordance with the regulations named in ‘The policy’ above.

Email Mailing List & Marketing Messages

We operate an email mailing list program, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named in ‘The policy’ above. Subscribers can unsubscribe at any time through an automated online service, or if not available, other means as detailed in the footer of sent marketing messages (or unsubscribe from all HubSpot lists). The type and content of marketing messages subscribers receive, and if it may contain third party content, is clearly outlined at the point of subscription.

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

Our EMS (email marketing service) provider is; HubSpot and you can read their privacy policy in the resources section.

External Website Links & Third Parties

Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites.

Shortened URL’s; URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this (example: https://bit.ly/2u6Xfmo). Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.

We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Policy & Usage

We adopt a Social Media Policy to ensure our business and our staff conduct themselves accordingly online. While we may have official profiles on social media platforms users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.

There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.

Resources & Further Information

• Overview of the GDPR – General Data Protection Regulation
• Data Protection Act 1998
• Privacy and Electronic Communications Regulations 2003
• The Guide to the PECR 2003
• Twitter Privacy Policy
• Facebook Privacy Policy
• Google Privacy Policy
• Linkedin Privacy Policy
• HubSpot Privacy Policy

SAFEGUARDING AND PREVENT DUTY POLICY 

Digital Native are fully committed to safeguarding the welfare of our apprentices. The development and implementation of this policy and procedures are an integral part of Digital Native’s determination to provide high-quality responsive services, which meet the needs of our customers and service users. 

All staff, associates and volunteers have a responsibility to take appropriate steps to protect our apprentices at risk and to understand their responsibility to operate within this policy. Good safeguarding includes arrangements for prevention as well as responding to allegations of harm and abuse. Harm and abuse may include physical, sexual, psychological, financial and institutional abuse, acts of neglect and omission and discrimination. All allegations concerns or suspicions of abuse or neglect are taken seriously by Digital Native and responded to in line with our procedures and within the reporting structures of the local authority in which we work. 

Allegations made against members of staff will be dealt with. Digital Native handle all disclosures in accordance with the requirements of a national framework of standards and good practice and outcomes in Adult protection (ADASS 2006). This policy states our approach to preventing and responding to safeguarding issues. 

INTRODUCTION 

Digital Native fully recognises its statutory and moral duty to promote the safety and welfare of those apprentices who are under the age of 18 years and those adult learners who are deemed to be vulnerable; however; Digital Native has a moral duty and is committed to the safeguarding of all learners regardless of their age and vulnerability. 

This policy has been developed in accordance with the principles established by the: 

• Children Acts 1989 and 2004; 

• the Education Act 2011, and in line with the government publication: 

• ‘Keeping Children Safe in Education 2023’ the statutory guidance. (Final version for 2024 pending) 

• The Local Safeguarding Children Board (LSCB) procedures. 

All staff should ensure that they have read and understood the associated policies to support the effective implementation of the safeguarding policy and procedures. 

SCOPE 

This policy and its procedures will apply to: 

• The Board of directors 

• The Governance board 

• Employees of Digital Native 

• Apprentices 

• Contractors 

• Employers providing an apprenticeship 

• All other users of Digital Native 

• All Digital Native activities 

The Policy and Procedures will apply at all times when Digital Native is providing services or activities that come under the responsibility of the organisation. 

COMMUNICATION AND DISSEMINATION OF THE POLICY 

Digital Native recognises that safeguarding and promoting the welfare of its apprentices is everyone’s responsibility. Everyone who comes into contact with an apprentice and their families, carers and employers has a role to play in safeguarding. The safeguarding policy is shared with all staff, apprentices and employers on an annual basis and as and when any in-year updates are made aligned to legislation changes. 

The policy, its purpose and reporting procedures will be reinforced via team and employer meetings, staff training, learning resources and literature. Additional support and guidance will be provided to ensure that any apprentice with a learning difficulty or language barrier can access the policy, its aims and supporting literature. 

All staff have read and confirmed their understanding of the Keeping Children Safe in Education 2023 

SAFER RECRUITMENT AND TRAINING FOR STAFF 

When recruiting new members of staff, Digital Native follows the government guidance “Safeguarding Children: Safer Recruitment in Education” and Safer Recruitment principles and pays due regard to the Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012. 

Digital Native adapts the guidelines within the Baseline Security Standard (BPSS) for all appointments and ensures that the relevant staff member uses the DBS checking service to assess applicants’ sustainability for positions of trust. The company also compiles fully with the Code of Practice and aims to treat all applicants for positions fairly. DBS checks are undertaken in line with government guidance and current legislation, alongside appropriate references being obtained and ensuring qualifications are verified. Safer Recruitment training has been undertaken by senior members of staff who conduct recruitment activities in accordance with statutory guidance. 

Newly appointed staff will have a job role induction to include a robust introduction into the safeguarding of children, young people and adults at risk policy and procedures. This includes mandatory reading of internal and external policies and e-learning modules. 

DEFINITIONS 

Although legislation is specifically related to children and vulnerable adults as defined below, Digital Native is committed to the safeguarding of all apprentices and the term apprentice is used throughout this policy. 

Child – In terms of this policy, a child is defined as anyone who has not reached their 18th birthday. 

Vulnerable Adults – In terms of this policy, a vulnerable adult is defined as a person aged 18 years or over and who is or may be in need of community care services by reason of mental or other disability, age or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation. This may include a person who has a learning difficulty, a physical or sensory disability or a mental illness. 

Definition of Safeguarding: Safeguarding and promoting the welfare of learners is defined in ‘Working Together to Safeguard Children (2023)’ as: 

• Protecting children from maltreatment whether that is within or outside the home including online 

• Providing help and support to meet the needs of children as soon as problems emerge 

• Preventing impairment of children’s mental and physical health or development 

• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care 

• Promoting the upbringing of children with their birth parents or otherwise their family network through a kinship care agreement whenever possible and where this is in the best interest of the children. 

• Taking action to enable all children to have the best outcomes in line with the outcomes set out in the  Children’s Social Care National Framework 

Note: Apprentices with additional needs and/or disabilities can face further safeguarding challenges. It is essential that these apprentices are given the support and guidance to remove barriers. 

SAFEGUARDING ACTIONS MAY BE NEEDED TO PROTECT APPRENTICES FROM THE FOLLOWING: 

• Physical abuse 

• Emotional abuse 

• Sexual abuse 

• Neglect 

• Bullying including cyberbullying 

• Child missing from education 

• Child missing from home or care 

• Child sexual exploitation (CSE) 

• Domestic violence 

• Drugs 

• Fabricated or induced illness 

• Faith abuse 

• Female genital mutilation (FGM) 

• Forced marriage 

• Gangs and youth violence 

• Gender-based violence / violence against women and girls (VAWG) 

• Mental health 

• Private fostering 

• Preventing radicalisation 

• Relationship abuse 

• Sexting 

• Trafficking 

• Sexual Violence 

• Sexual Harassment 

Staff need to have an awareness of the different types of safeguarding issues and explanations and definitions (Appendix c). Staff should also be aware that behaviours linked to, for example, drug taking, alcohol; abuse, truanting and sexting also put apprentices in danger. 

Digital Native take their safeguarding responsibilities very seriously and as such will not tolerate any forms of abuse, bullying or harassment. 

LOOKED AFTER CHILDREN 

All staff need to be aware of issues around safeguarding looked after children. The most common reason for young people becoming looked after is as a result of abuse and/or neglect. 

APPRENTICES WITH SPECIAL EDUCATIONAL NEEDS AND DISABILITIES 

All staff need to be aware that additional barriers can exist when recognising abuse and neglect in apprentices with special educational needs (SEN) and disabilities.
This can include: 

• Assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the apprentice’s disability without further exploration. 

• Apprentices with SEN and disabilities can be disproportionally impacted by issues such as bullying without outwardly showing any signs. 

• Communication barriers and difficulties in overcoming these barriers. 

• Staff should refer to the apprentice’s education, health care plan (HCP). This will provide additional guidance specific to the apprentice’s support needs. 

• Digital Native recognises that safeguarding is not just about protecting apprentices from deliberate harm, neglect and failure to act. It relates to the broader aspects of care and education and the following procedures should be read in conjunction with this policy: 

• Health and Safety Policy 

• Safer Recruitment Policy and Guidelines 

• Learner Behaviour Policy 

• External Speakers and Events Policy 

PROCEDURE FOR STAFF 

If Digital Native staff have concerns about a apprentice: 

• If staff members have any concerns about a apprentice, this must be referred to the Designated Safeguarding Lead, to agree a course of action. Options can include referral to specialist services or early help services. Digital Native recognises its role in identifying apprentices who may benefit from early help and providing support as soon as a problem emerges in a apprentice’s life.  Providing early help is more effective in promoting the welfare of young people than reacting later. Staff may be required to support other agencies and professionals in an early help assessment and share information support early identification and assessment. The DSL will be required to report a referral immediately to the local safeguarding authority. 

• If early help is appropriate, the Designated Safeguarding Lead (DSL) will support the staff member to liaise with external agencies. The apprentice should then be monitored and if the situation does not appear to be improving, a referral will be made by the Designated Safeguarding Lead to the Local Authority Designated Officer (LADO) or Local Safeguarding Board to ensure the apprentice’s situation improves. 

• Prevent related concerns should also be escalated to the designated safeguarding lead immediately who will refer to the regional Prevent Coordinator for advice and guidance. 

If Digital Native staff believe an apprentice is in immediate danger or at risk of harm:
This immediate concern must be reported to the Designated Safeguarding Lead and if an apprentice is in immediate danger or is at risk of harm, a referral will be made to the Local Authority Designated Officer (LADO), Safeguarding Board or to the police immediately. 

Staff responsibilities or 5Rs are summarised as: 

1. Recognise 

1. Respond 

1. Record 

1. Report 

1. Refer 

IF AN APPRENTICE MAKES A DISCLOSURE TO A MEMBER OF STAFF 

• If a apprentice makes a disclosure to a member of staff, the apprentice should be acknowledged, taken seriously and listened to. 

• As soon as it becomes clear that the apprentice is talking about a safeguarding issue, you need to gently stop them and inform them that you have a legal obligation to pass this information on to a Designated Safeguarding Lead. You cannot promise confidentiality to the apprentice. Reassure the apprentice but tell them that a record of information given will be made. 

• It is important not to ask too many questions as you must not under any circumstances investigate any accusations. 

• Allow the apprentice to freely recall significant events, keeping questions to the absolute minimum necessary to ensure a clear and accurate understanding of what has been said. Record the factual details of what has been told to you using the Safeguarding Disclosure Form. Concern / Disclosure Form (Appendix A). Contact the Designated Safeguarding Lead immediately to explain the situation and pass on the written notes. The Designated Safeguarding Lead will outline the action that he/she has to take so that you can explain this to the apprentice. It may be appropriate for the Designated Safeguarding Lead to meet the apprentice. You must not take any further action yourself. This includes contacting parents/carers or outside agencies. The DSL will be required to report a referral immediately to the local safeguarding authority. 

MEMBER OF STAFF RECEIVES INFORMATION ABOUT AN APPRENTICE FROM ANOTHER PERSON 

If a member of staff receives information about an apprentice, which suggests that there is a safeguarding issue or that this is likely, this must be recorded on the Safeguarding Concern / Disclosure Form and reported immediately to the Designated Safeguarding Lead. Digital Native has a duty to refer these concerns to the Local Authority Children’s Social Care Office for the area in which the apprentice lives or to the police if the learner is in immediate danger. 

IF A MEMBER OF STAFF SUSPECTS AN APPRENTICE HAS A SAFEGUARDING CONCERN 

If a member of staff suspects that a apprentice is at risk from a safeguarding issue, they must discuss these concerns with the Designated Safeguarding Lead and not take any independent action. The concerns must be recorded on the Safeguarding Concern / Disclosure form. 

All contact with outside agencies over issues of safeguarding must be approved by the Designated Safeguarding Lead. The Designated Safeguarding Lead will decide whether to make  a referral to children’s social care, Local Safeguarding Board or Local Authority Designated Officer (LADO). 

Local authorities, with the help of other organisations as appropriate, have a duty to make enquires under section 47 of the Children Act 1989 if they have reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm. Such enquiries enable them to decide whether they should take any action to safeguard and promote the child’s welfare and must be initiated where there are concerns about maltreatment, including all forms of abuse and neglect, female genital mutilation or other so called honour based violence, and extra-familial threats like radicalisation and sexual exploitation. 

Parents / carers have the right to be informed in respect of any concerns or any action taken to safeguard and promote their welfare, providing this does not compromise the learner’s safety. Keeping Children Safe in Education (2023). 

ALLEGATIONS OF ABUSE MADE AGAINST OTHER YOUNG PEOPLE 

Staff must recognise that young people are capable of abusing their peers and be aware that safeguarding issues can manifest themselves via peer on peer abuse. Peer on peer abuse is abuse young people may experience from their peers (people of their own or similar age) perpetrated by a young person/s (under the age of 18 years)/vulnerable adult/s on young person/s/vulnerable adult/s. 

Staff need to be aware that abuse is abuse and should never be tolerated or passed off as ‘banter’ or ‘part of growing up’. Digital Native will take any concerns of this nature very seriously and concerns should be raised in the same way as any other concerns, directly to their coach or to the Safeguarding Team. 

Peer on peer abuse can take the form of bullying (including cyber-bullying) sexting and any other form of sexual or physical abuse. Gender based issues can also occur for example girls being sexually touched/ assaulted or boys being subject to initiation/hazing type violence. 

VISITORS 

All official visitors to Digital Native premises are required to report to the main reception on arrival and sign in. Visitors are issued with a visitor pass which must always be worn and visible. Visitors are asked to wait in reception until they are collected by a member of staff. Visitors are not permitted to enter access-controlled areas unless accompanied by a member of staff. 

Guest Speakers will be subject to the guest speaker policy vetting procedure. 

All centres must carry out appropriate checks on the material that is being presented prior to a guest speaker event. The relevant checks must be made against all guest speakers before any event is approved. Guest speakers are not permitted to work alone with any apprentices and will always be accompanied by a coach. The Guest Speaker approval form must be completed prior to the event and shared with the DSL. 

APPRENTICES WORK SETTINGS 

Digital Native has a responsibility to ensure the health, safety and welfare of all apprentices undertaking apprenticeships with employers. 

Digital Native will ensure that employers are aware of this policy and their responsibilities for compliance in relation to Safeguarding and the Prevent duty for any apprentice who is placed with them and that arrangements are in place to ensure that an apprentice’s wellbeing is safeguarded. 

APPRENTICES WITH CRIMINAL CONVICTIONS 

Digital Native is committed to the fair treatment of all apprentices and welcomes applications from a wide range of individuals, including those with criminal convictions. Digital Native is committed to the equality of opportunity and selects individuals based on their skills, qualifications and experience and not on their background or personal circumstances. Having a criminal conviction will not necessarily prevent someone from studying at Digital Native. 

Digital Native is mindful, however, of the duty of care it owes to its apprentices, staff and the wider community to act reasonably to protect their health, safety and welfare. 

As a consequence, Digital Native requires all applicants to disclose any criminal convictions on application and re-enrolment. 

If a criminal conviction is disclosed or otherwise brought to our attention, Digital Native will work with that person to determine the level of risk posed by the conviction to both the individual and/or to others. 

The individual will be required to complete a safeguarding risk assessment, providing Digital Native with further information about the offence and contact details for any relevant third party e.g. a Probation Officer. 

The information given on the Disclosure Form will then be used to assess whether there is any risk posed should the individual enrol on a course at Digital Native. An interview must take place with the Designated Safeguarding Lead to enrolment to approve the application and sign the enrolment form. Where medium/high risk has been identified, this will be referred to the board of directors and enrolment deferred until a decision is reached. 

CONCERNS ABOUT A STAFF MEMBER 

A low-level concern is any concern that an adult has acted in a way that:
• is inconsistent with the staff code of conduct, including inappropriate conduct outside of work
• does not meet the allegations threshold or is not considered serious enough to refer to the local authority designated officer (LADO).
Examples of low-level concerns could include being
• over friendly with apprentices
• having favourites
• taking photographs of apprentices on their mobile phone
• engaging with an apprentice on a one-to-one in a secluded area or behind a closed door
• using inappropriate sexualised, intimidating or offensive language. 

Low-level concerns should be reported to the DSL or a director. If there are concerns about a DSL, these should be reported to the directors and the governance board.
The DSL will record all low-level concerns. Records should include the details of the concern, how the concern arose and the actions taken. 

On receipt of an allegation that is not a low-level concern, Digital Native’s Disciplinary Procedures relating to allegations of abuse will be followed.
• Suspension on full pay while the issue is investigated. We will take a sensible approach
• Consult our HR advisor or local safeguarding board for advice
• In everyone’s interests, aim for a swift but thorough investigation
• Maintain confidentiality
• Should the employee leave the organisation, the investigation continues to its conclusion as though they were still in employment. 

Additionally, the governance board will be notified if the allegations relate to any of the directors of Digital Native and the above procedure will be followed. 

CONCERNS ABOUT SAFEGUARDING PRACTICES 

All staff should feel able to raise concerns about poor or unsafe practice and potential failures in Digital Native’s safeguarding practices and that such concerns would be taken seriously by the Leadership Team. 

If staff members have any concerns about the safeguarding regime, they should raise this initially with their director. If no immediate action is taken, then appropriate Whistleblowing Procedures are in place for such concerns to be raised with additional directors and the governance board. 

Where a staff member feels unable to raise an issue with Digital Native or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them: General guidance can be found at – Advice on whistleblowing. 

The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and Email: help@nspcc.org.uk 

RESPONSIBILITIES 

THE BOARD OF DIRECTORS 

The Board will: 

• Ensure that Digital Native has an effective Safeguarding Policy in place which is updated annually and that Digital Native contributes to inter-agency working in line with statutory guidance ‘Working Together to Safeguard Children 2023’ and ‘Keeping Children Safe in Education 2023’. 

• Ensure that the Safeguarding arrangements take into account the procedures and practice of the local authority as part of the inter-agency safeguarding procedures set up by the Local Safeguarding Children Board (LSCB). 

• Ensure that Digital Native complies with the Prevent Duty as set out in the Prevent Duty Guidance for England and Wales 2023 

• Ensure that the policies and procedures in place enable appropriate action to be taken in a timely manner to safeguard and promote apprentice welfare. 

• Appoint a Board Member with responsibility for Safeguarding and Prevent who will liaise with the Designated Safeguarding Lead. 

• Ensure that a Designated Safeguarding Lead is appointed to lead on safeguarding, advise/support staff and liaise with the Local Authority and other agencies. He/she will have status/authority to carry out the role e.g. commit resources to safeguarding and direct staff as appropriate. 

• Give scrutiny to regular reports which will provide detail on the numbers and types of safeguarding incidents and concerns which have arisen 

• Ensure that any deficiencies or weaknesses in safeguarding arrangements are remedied without delay. 

• Ensure that a member of the Governance Board is nominated to liaise with the designated officer for the relevant local authority and partner agencies in the event of a safeguarding allegation being made against the board of directors 

THE OPERATIONS DIRECTOR 

The Quality Director has the overall responsibility for and oversight of Safeguarding within Digital Native and will ensure through the Digital Native Management and Leadership Team that: 

• Safeguarding policies and procedures and any linked Safeguarding polices are fully implemented and followed by all staff. 

• All staff feel able to raise concerns about poor or unsafe practice regarding apprentices and that concerns will be addressed sensitively and in a timely and appropriate manner. 

• Policy / procedures are available to parents / carers and employers on request. 

THE DESIGNATED SAFEGUARDING LEAD (DSL) 

The Designated Safeguarding Lead/s will: 

• Ensure that the Safeguarding Policy, including Prevent, is reviewed annually and the procedures and implementation are reviewed regularly by the Personal Development, Welfare and Behaviour Action Group and the Board. 

• Ensure that the Safeguarding Policy is made public and that parents/carers and employers are aware of the fact that referrals about suspected abuse or neglect may be made and the role of Digital Native in this. 

• Provide an Annual Safeguarding report for the Board, detailing any changes to the policy and procedures; training undertaken by self, staff with specific responsibility and all other staff and Board members and number and type of incidents/cases. 

• Ensure the quality assurance of the provision of safeguarding information, advice and guidance and procedures. 

• Ensure there is liaison with employers providing Apprenticeships to ensure proper safeguarding arrangements are in place. 

• Act as a source of support, advice and expertise to staff on matters of safety and safeguarding and, when deciding to make a referral, by liaising with relevant agencies. 

• Keep detailed, accurate, confidential and secure written records of concerns, disclosures and referrals. Ensure all such records are kept confidentially and securely. 

• Liaise with the Safeguarding Team / any other relevant staff to inform of any issues/ongoing investigations via the Safeguarding Operations Group. 

• Ensure the Safeguarding Team acts as a key point of referral for apprentices/ staff /parents / carers/employers, offer advice, assess information promptly, take action or refer on to the Designated Safeguarding Lead so that Digital Native can respond swiftly and appropriately to all concerns referrals and disclosures. 

• Have access to resources and attend any relevant or refresher training courses at least every two years. 

• Ensure that a member of the Safeguarding Team attends case conferences, core groups, or other multi-agency planning meetings, contributes to assessments, and provides a report. 

 

SEXUAL HARASSMENT AND ABUSE POLICY

Digital Native (UK) Ltd is committed to providing a safe environment for all its apprentices and staff free from discrimination on any ground and from harassment at work including sexual harassment.
We will operate a zero-tolerance policy for any form of sexual harassment, treat all incidents seriously and promptly investigate all allegations of sexual harassment.
Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from their training programme or employment.
All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.

Definition of sexual harassment

Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated.
It includes situations which create an environment which is hostile, intimidating or humiliating for the recipient.
Sexual harassment may be physical, verbal and non-verbal.

Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

• Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
• Physical violence, including sexual assault
• The use of threats or rewards to gain sexual favour
• Comments on an individual’s appearance, age, private life, etc.
• Sexual comments, stories and jokes
• Sexual advances
• Repeated and unwanted social invitations for dates or physical intimacy
• Insults based on sex
• Sending sexually explicit messages (by phone or email or social media)
• Display of sexually explicit or suggestive material
• Sexually suggestive gestures
• Wolf-whistling

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. We recognise that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.
We recognise that sexual harassment can be a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and staff member or trainer and apprentice. All sexual harassment is prohibited whether it takes place within our training environment or outside, including at social events or training sessions.

Peer on peer abuse (child on child) (Reference to Keeping Children Safe in education Part One)

1. 1. All staff should be aware that children can abuse other children (often referred to as peer on peer abuse). And that it can happen both inside and outside of the apprenticeship and online. It is important that all staff recognise the indicators and signs of peer on peer abuse and know how to identify it and respond to reports.
   2. All staff should understand, that even if there are no reports into Digital Native, it does not mean it is not happening, it may be the case that it is just not being reported. As such it is important if staff have any concerns regarding peer on peer abuse they should speak to their designated safeguarding lead.
   3. It is essential that all staff understand the importance of challenging inappropriate behaviours between peers, many of which are listed below, that are actually abusive in nature. Downplaying certain behaviours, for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of growing up” or “boys being boys” can lead to a culture of unacceptable behaviours, an unsafe environment for children and in worst case scenarios a culture that normalises abuse leading to children accepting it as normal and not coming forward to report it.
   4. Peer on peer abuse is most likely to include, but may not be limited to:
      • bullying (including cyberbullying, prejudice-based and discriminatory bullying);
      • abuse in intimate personal relationships between peers;
      • physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise
        causing physical harm (this may include an online element which facilitates,
        threatens and/or encourages physical abuse);
      • sexual violence, such as rape, assault by penetration and sexual assault; (this
        may include an online element which facilitates, threatens and/or encourages sexual violence);
      • sexual harassment,9 such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse;
      • causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party;
      • consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery);
      • upskirting,11 which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm; and
      • initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).
      • All staff should be clear as to Digital Native’s policy and procedures with regard to peer on peer abuse and the important role they have to play in preventing it and responding where they believe a child may be at risk from it.

   What will happen following a complaint of sexual harassment

   Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome.
   We recognise that it may not be possible for the victim to inform the alleged harasser. If a victim cannot directly approach an alleged harasser, he/she can approach the Designated Safeguarding Lead or any staff member.

   When a staff member receives a complaint of sexual harassment, he/she will

   • reassure the victim that the complaint will be taken seriously
   • record the dates, times and facts of the incident(s)
   • ascertain the views of the victim as to what outcome he/she wants
   • ensure that the victim understands the company’s procedures for dealing with the complaint
   • discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally may still result in pursuing a formal complaint if he/she is not satisfied with the outcome

   We will identify specific staff and provide them with special training to enable them to assist victims of sexual harassment. This will be the DSL at Digital Native who will liaise with specialist organisations.

   Support

   We recognise that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. We understand the need to support victims in making complaints.
   If the victim wishes to deal with the matter informally, the person receiving the complaint will give an opportunity to the alleged harasser to respond to the complaint and ensure that the alleged harasser understands the complaints mechanism.
   Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or
   Refer the matter to the Designated Safeguarding Lead who will ensure that a confidential record is kept of what happens.
   Ensure that the above is done speedily and within one day of the complaint being made.
   If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

   Sanctions and disciplinary measures

   Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

   • verbal or written warning
   • suspension
   • dismissal

   The above sanctions adhere to staff members at Digital Native. If there is not a satisfactory outcome in the apprentice’s workplace, Digital Native will pursue this with the employer alongside the employer’s internal policies to resolve.
   Furthermore, Digital Native, in consultation with the apprentice, can move the apprentice to a different employer if not resolved to the apprentice’s satisfaction and the request is made by the apprentice.
   The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence or actual abuse, will result in the immediate dismissal of the harasser.

   Implementation of this policy

   We will ensure that this policy is widely disseminated. It will be included in apprentice induction policies, staff code of conduct policy and on our website. We also inform our employers about this policy.
   All apprentices and staff will be trained on the implementation of this policy as part of their induction into the company.
   We will ensure frequent updating of apprentices and staff on the implementation of this policy.
   It is the responsibility of every manager to ensure that all his/her employees are aware of the policy.
   Digital Native recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective. Data will include reports of low-level concerns.
   Our governance board will receive regular reports on the effectiveness of this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis as a minimum.
   As a result of this report, Digital Native will evaluate the effectiveness of this policy and make any changes needed.