Safeguarding Policy — Children and Adults at Risk
Bearing Safety & Security Limited
Applies to: UK Ready, all phases
Last updated: 30 July 2026 · v1.0
Review date: 30 July 2027
Designated Safeguarding Lead:
Tom Frearson
1. Our commitment
Bearing exists to make students safer. That obligation starts with the students in our own programme.
Every young person who attends UK Ready has the right to be safe, to be treated with respect, and to be listened to. We accept that responsibility in full, and we accept that safeguarding always comes before commercial or operational convenience.
This policy sets out how we meet that responsibility. It applies to every person delivering or supporting UK Ready — founder, facilitators, associates, contractors and administrative support — with no exceptions and no discretion.
The principles are simple:
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Safeguarding is everyone's responsibility, not only the Designated Safeguarding Lead's
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The welfare of the child comes first
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A concern is acted on, not weighed up privately
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If in doubt, we report
2. Scope
This policy covers:
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Children — any student under the age of 18. Most UK Ready students are adults. A minority arrive at 16 or 17: undergraduate entrants from school systems that finish earlier than the UK's, students who turn 18 during their first term, and students entering through foundation, pathway and pre-sessional English routes
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Adults at risk — any student aged 18 or over who may be unable to protect themselves from harm or exploitation
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All programme phases — the online modules in Phase 1, the practical day in Phase 2, and all contact before, between and after them
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All settings — a partner institution's premises, a hired venue, and the public areas used for the situational awareness exercise
Both frameworks operate side by side. Because most students are adults, adult safeguarding is not a secondary consideration in this policy — it carries equal weight, with its own referral route at section 10.
Date of birth is captured at booking for every student, so the age profile of a cohort is known before delivery rather than on the day.
It applies to all Bearing personnel and to anyone acting on Bearing's behalf.
3. Statutory framework
Bearing is not a school or a college, and is not a statutory safeguarding partner. We are an independent training provider working with children, and we align our practice with the statutory framework that governs the sector we work in.
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Working Together to Safeguard Children (DfE, March 2026) — applies to organisations whose work affects the welfare of children, including independent and voluntary sector providers. This is the framework we operate under
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Keeping Children Safe in Education (DfE, 2026, in force from 1 September 2026) — binds schools and colleges in England rather than Bearing. We align our practice with it, because our partner institutions are held to it and because it is the recognised standard
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Children Act 1989 and Children Act 2004
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Care Act 2014 — adult safeguarding, for students aged 18 and over
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Mental Capacity Act 2005 — capacity and consent in adult safeguarding decisions
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Safeguarding Vulnerable Groups Act 2006, as amended — DBS and regulated activity
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Equality Act 2010
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UK GDPR and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025
Where a cohort is delivered outside England, we follow the relevant national procedures for Scotland, Wales or Northern Ireland, and record the applicable local referral route in the cohort file before delivery.
4. The Designated Safeguarding Lead
The Designated Safeguarding Lead (DSL) for Bearing is Tom Frearson, founder and director.
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Email: contact@bearinguk.com
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Telephone: +44 (0) 20 8064 1044
The DSL holds Designated Safeguarding Lead (Level 3) training and Level 3 Safeguarding Adults training, both CPD accredited and City & Guilds Assured, completing before the delivery of the first cohort and renewed every two years, in line with Keeping Children Safe in Education.
The DSL role at Bearing covers both children's and adult safeguarding. There is no separate statutory designated role for adults in a training provider of this kind, so both sit with the same named person, held to Level 3 in each.
The DSL's responsibilities:
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Holding overall accountability for safeguarding across UK Ready
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Receiving all safeguarding concerns and disclosures reported by facilitators
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Deciding on referral and making it
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Liaising with the safeguarding lead at each partner institution
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Maintaining safeguarding records
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Ensuring every facilitator is trained, checked and inducted before delivery
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Reviewing this policy annually and after any safeguarding incident
Deputy DSL. A Deputy DSL will be appointed as the delivery team grows, and named in this policy at that point. Until then, where the DSL is unavailable or where a concern involves the DSL, the routes in section 10 apply and are used directly.
Partner institution safeguarding lead. Before any cohort runs, the named safeguarding lead at the partner institution is recorded in the cohort file, with direct contact details. Concerns about a student placed by that institution are shared with them alongside any statutory referral.
5. Safer recruitment and facilitator standard
No one delivers UK Ready without meeting the full standard.
Every facilitator holds:
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An enhanced DBS check including the children's barred list, verified by the DSL before first delivery and renewed every three years
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A teaching qualification at Level 3 or above in Education and Training
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A background in military service, law enforcement, emergency medicine or professional security
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The Level 3 Award in the Delivery of Conflict Management Training, held by the facilitator leading the avoidance, de-escalation and escape session
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First Response Emergency Care Level 3 (FREC 3) or above
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CPD accredited and City & Guilds Assured Level 2 certificated training in safeguarding children, and in safeguarding adults, both completed before first delivery and renewed every three years, alongside DBS re-check and first aid requalification
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An annual safeguarding update, briefed and recorded by the DSL
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Assessment and shadow observation on UK Ready content before leading a cohort
Before appointment we take up two references, verify identity and right to work, check qualification certificates directly, and account for any gaps in employment history.
Mental health first aid content is designed and quality-assured by a holder of the Level 3 Award in Supervising First Aid for Mental Health. Every facilitator is trained and assessed on that content at induction and delivers it only within the framework set for it.
DBS certificates, qualification records and training dates are held on file and made available to a partner institution on request
6. Two-adult standard
Every UK Ready cohort is delivered by a pair of facilitators. Both hold enhanced DBS checks including the children's barred list. Both hold FREC 3 or above.
The pair delivers the day together. First aid, mental health first aid, conflict de- escalation, personal protection and the live scenarios are all delivered with both facilitators present.
A single facilitator does not deliver a cohort. If one facilitator becomes unavailable, the delivery is rescheduled.
No facilitator conducts a private one-to-one meeting with a student. Where a student needs to speak to a facilitator, the conversation takes place in an open area, in sight of others, with the second facilitator aware it is happening.
7. Situational awareness exercise — off-site protocol
The situational awareness exercise is the only part of the day where the cohort splits. Two groups of up to eight students, one facilitator each, working in the local public area. Because it is off-premises and each facilitator operates without their partner in immediate view, it carries its own controls.
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Minimum group size of three students. A facilitator is never alone with one or two students. If numbers fall for any reason, the groups merge and the exercise continues as one
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Both facilitators hold FREC 3 or above, so each group has full emergency first aid cover throughout
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Continuous communication. Both facilitators are contactable by mobile at all times, with an agreed recall signal, a named rendezvous point and a fixed regroup time set before departure
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Headcounts are taken and recorded at each waypoint, at the rendezvous, and on return to the venue
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Written route risk assessment. Every route is recced in advance and a written risk assessment held on file. It is provided to the partner institution on request, and reviewed before each delivery at a new venue
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No student leaves a group alone. A student who needs to withdraw is accompanied back to the venue, or the group returns together
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No private one-to-one conversation during the exercise. Anything a student raises is acknowledged, kept in sight of the group, and followed up properly at the venue with both facilitators aware
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Specific consent. Parental or guardian consent for the off-site component is obtained separately from general attendance consent for any student under 18, and describes the exercise plainly — a supervised group exercise in a public area, accompanied by a qualified facilitator at all times
There is no statutory adult-to-student ratio for this age group off-site in England. The ratio of one facilitator to a maximum of eight students is set and justified by the written risk assessment at point 5.
8. Practical content — consent and boundaries
UK Ready does not teach physical restraint, self-defence techniques or contact drills. Avoidance, de-escalation and escape are taught as a decision framework, without physical technique instruction.
Two parts of the day still involve physical activity: hands-on emergency first aid, where students practise choking response in pairs, and the off-site situational awareness exercise.
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The purpose and nature of any physical element is explained before it starts
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Participation is voluntary. A student may decline any physical element, at any point, without giving a reason and without consequence to their certification
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Students practise with each other, in pairs they are comfortable with, in the open room and in sight of both facilitators
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Where a facilitator demonstrates, it is demonstrated on the other facilitator or on a manikin wherever possible
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Where physical contact with a student is unavoidable for safe demonstration, it is explained first, consent is asked for, it is kept to the minimum needed, and it takes place in full view of the room and the second facilitator
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Nothing is taught by surprise, under pressure, or as a test
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For a student under 18, parental or guardian consent to the practical content is obtained at booking, and the content is described plainly
Facilitators do not use physical contact to discipline, restrain or manage behaviour.
9. Handling a disclosure
UK Ready covers mental health, harassment, fraud, and personal safety. Students disclose. We plan for it rather than react to it.
Facilitators support and signpost. Facilitators do not counsel, investigate or diagnose.
If a student discloses:
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Listen. Let them speak. Do not interrupt, lead, or ask probing questions. Never ask a question that suggests an answer
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Do not promise confidentiality. Say early and plainly that you may need to pass this on to keep them safe, and that you will tell them who you are telling
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Reassure. They were right to speak. It is not their fault
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Stay within role. Do not offer an opinion on what happened, and do not undertake to resolve it
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Signpost. Provide the routes already built into the curriculum — 999, 101, 111, the institution's welfare and safeguarding team, their GP, and the relevant national helplines
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Record. Write it up the same day, in the student's own words as far as possible, with date, time, place, who was present, what was said, and what action was taken. Record fact, not interpretation
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Report to the DSL. Same day. Immediately by telephone where there is a risk of immediate harm
A facilitator does not decide whether a concern is serious enough to pass on. That judgement sits with the DSL.
Where the student is an adult. An adult with mental capacity decides for themselves what happens next. Their wishes lead, and we do not make a safeguarding referral against those wishes unless someone else is at risk, a criminal offence needs reporting, or there is reason to believe they lack capacity to make the decision. The concern is still reported to the DSL and recorded either way. The DSL decides what follows.
Where a disclosure indicates immediate risk to life, the facilitator calls 999 first and informs the DSL immediately afterwards.
Delivery continues where it is safe and appropriate to do so. Where it is not, the session pauses and the second facilitator holds the room.
10. Referral routes
The DSL makes the referral. The DSL does not investigate.
Situation
Route
Immediate risk to life or safety
A child is at risk of, or is suffering, significant harm
A concern about a student aged 18 or over who may be at risk
Non-emergency police matter
An allegation or concern about a facilitator, contractor or the DSL
A concern about a student placed by a partner institution
Radicalisation or extremism concern
Advice where the position is unclear
999
Children's services in the local authority where the student is living, same day. Escalate to 999 where the risk is immediate
Adult social care in the relevant local authority, same day
101
Local Authority Designated Officer (LADO) in the relevant local authority, within one working day
The named institutional safeguarding lead, alongside any statutory referral. Never instead of one
Local authority Prevent lead, or the police Prevent line
NSPCC Helpline, 0808 800 5000, help@nspcc.org.uk
The DSL records the referral, the time it was made, who received it, and the outcome.
A concern involving the DSL. Where an allegation or concern relates to the DSL, it is not reported to the DSL. It is reported directly to the LADO in the relevant local authority, and to the safeguarding lead at the partner institution. Any facilitator, student or parent may take this route, and no one is required to raise it internally first.
Referral routes and contact details for each local authority are recorded in the cohort file before delivery.
11. Information sharing
Data protection law is not a barrier to sharing information in order to keep a child safe. Working Together to Safeguard Children 2026 is explicit on this point.
For an adult at risk, the position differs. Sharing is normally done with the adult's consent, under the Making Safeguarding Personal approach — the adult is involved in decisions about their own safety rather than having them made for them. We share without consent only where someone else is at risk, where a criminal offence needs reporting, where the adult lacks capacity to decide, or where the law requires it. The reason is recorded.
We share what is necessary, with those who need it, without delay.
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We seek consent to share where it is safe and appropriate to do so
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We share without consent where seeking it would place a child at risk, obstruct a criminal investigation, or cause unjustified delay
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We record the reason for the decision either way
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We share on a need-to-know basis, and no wider
Safeguarding records are held separately from general programme records, with access restricted to the DSL. Retention periods are set out in our Privacy Policy.
12. Code of conduct
Every person delivering or supporting UK Ready:
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Treats every student with respect, and does not single out, humiliate or shout at a student
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Does not meet a student privately or one-to-one
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Does not contact a student through personal telephone, personal email or personal social media. All contact goes through Bearing channels
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Does not give a student a lift or transport them alone
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Does not give or accept gifts, money or personal favours
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Does not form a romantic or sexual relationship with a student, regardless of the student's age
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Does not attend delivery under the influence of alcohol or drugs
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Does not photograph or film a student except on Bearing equipment, with consent recorded, and for a stated purpose
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Reports their own conduct where a situation could be misread, rather than waiting to be asked
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Challenges the conduct of a colleague where the standard slips, and reports it
Low-level concerns. A concern that falls short of an allegation is still reported to the DSL and recorded. Patterns matter, and they only become visible if the small things are written down.
13. Online safety — Phase 1
Phase 1 is delivered through a course platform with no student-to-student messaging and no direct messaging between facilitators and students.
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All communication with a student under 18 is copied to the parent, guardian or purchasing institution
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Personal safety plans submitted for review are read by the DSL or a named facilitator, and a plan that discloses a concern is escalated under section 9
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Facilitators do not accept or initiate social media contact with a student
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Where online content raises a safeguarding concern, the same referral routes apply
14. Students under 18 — additional arrangements
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A place is booked and paid for by a parent, guardian or institution
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Written parental or guardian consent is obtained before attendance, covering the physical content, the off-site exercise, emergency treatment, and health information
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Where a student has a UK guardian arrangement, the guardian's details are recorded alongside the parent's and the guardian is treated as the first point of contact in the UK
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Emergency contact details are held for every student and carried by both facilitators on the delivery day
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Arrival and departure arrangements are confirmed in advance. A student under 18 is not left unaccompanied at the venue before or after the session
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Where a cohort is mixed, the arrangements for under-18s apply to the whole cohort. We do not run two standards in one room
15. Training and review
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Every facilitator completes CPD accredited and City & Guilds Assured Level 2 training in safeguarding children and in safeguarding adults before first delivery, both renewed every three years. The children's training is current with Keeping Children Safe in Education 2026
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Every facilitator completes an annual safeguarding update, briefed and recorded by the DSL
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Every facilitator is briefed on this policy at induction and signs to confirm they have read and understood it
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The DSL holds and renews Level 3 training in both children's and adult safeguarding every two years, in line with Keeping Children Safe in Education
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Prevent awareness training is completed by all facilitators
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This policy is reviewed annually, and immediately following any safeguarding incident, any change in the statutory framework, or any change in the delivery model
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The review is recorded, with the version number and date updated at the head of this document
A short public Safeguarding Statement appears on bearinguk.com. This full policy is available on request to any parent, student, partner institution or education agent.
16. Key contacts
Designated Safeguarding Lead
Emergency services
Police, non-emergency
NHS, non-emergency
NSPCC Helpline
Childline
Local authority children's services
Local Authority Designated Officer (LADO)
Partner institution safeguarding lead
999
101
111
0808 800 5000 · help@nspcc.org.uk
0800 1111
Recorded in the cohort file before delivery
Recorded in the cohort file before delivery
Recorded in the cohort file before delivery
Bearing Safety & Security Limited · Company number 17354268 · 124 City Road, London EC1V 2NX
Safeguarding Policy · Know your bearing