Policies and Procedures

Behaviour Management Policy

Policy Statement

Different Minds is committed to promoting positive behaviour, emotional wellbeing, and inclusion for all children. We recognise that disabled children may communicate their needs through behaviour and that such behaviour must be understood in context. Our approach meets EYFS and Ofsted expectations by being consistent, developmentally appropriate, and inclusive.

Legal and Regulatory Framework

This policy reflects the EYFS Statutory Framework, Children Act 1989 & 2004, Equality Act 2010, SEND Code of Practice (2015), Human Rights Act 1998, and Ofsted guidance on behaviour and safeguarding.

Reasonable Adjustments (Ofsted-Aligned)

In line with the Equality Act 2010, Different Minds makes reasonable adjustments to ensure disabled children are not placed at a substantial disadvantage. Adjustments may include adapting routines, environments, expectations, communication methods, and behaviour strategies. Ofsted expects providers to demonstrate how they remove barriers to learning and participation; therefore, reasonable adjustments are planned, recorded, reviewed, and embedded into daily practice.

Positive Behaviour Strategies

Staff use predictable routines, visual timetables, alternative communication systems, sensory regulation strategies, positive reinforcement, emotion coaching, and environmental adaptations to promote positive behaviour.

Managing Behaviour and De-escalation

Staff use calm, consistent, and low-arousal approaches. Physical intervention is not used as a behaviour management technique and will only be considered as a last resort to prevent serious harm, in line with training, risk assessments, and legal guidance.

Unacceptable Practices

Physical punishment, humiliation, intimidation, shouting, or the withdrawal of basic needs are strictly prohibited.

Partnership with Parents and Professionals

Parents/carers are involved in planning and reviewing behaviour strategies. External professionals may be consulted where appropriate.

Staff Training and Recording

All staff receive training in behaviour support, SEND, safeguarding, and EYFS requirements. Significant incidents are recorded and reviewed to inform ongoing support.

Communication and Accessibility Policy

1. Policy Statement

Different Minds is committed to ensuring that all children, families, staff, and professionals are able to communicate effectively and access our services without barriers.

As a specialist provision supporting children and young people with Special Educational Needs and Disabilities (SEND), we recognise that communication and accessibility needs vary significantly. We are committed to creating an inclusive environment where every individual feels heard, understood, respected, and valued.

2. Purpose

This policy aims to:
• Promote inclusive communication practices
• Remove or reduce barriers to participation
• Ensure reasonable adjustments are made
• Support children with a wide range of communication needs
• Provide accessible information to families and professionals
• Meet our responsibilities under the Equality Act 2010

3. Scope

This policy applies to:
• All children and young people attending the setting
• Parents, carers and family members
• Staff members and volunteers
• External professionals and visitors

4. Understanding Communication Needs

We support children with a wide range of communication profiles, including but not limited to:
• Autism Spectrum Condition (ASC)
• Speech, Language and Communication Needs (SLCN)
• Non-verbal or minimally verbal communication
• Social communication differences
• Learning disabilities
• Sensory processing differences
• English as an Additional Language (EAL)

Each child’s communication needs will be identified through initial registration, parent consultation, review of EHCPs or professional reports (where applicable), ongoing observation and regular communication with families.

5. Communication Approaches Used

Different Minds adopts a total communication approach. Depending on individual need, this may include:
• Visual timetables
• Now and Next boards
• PECS (Picture Exchange Communication System)
• Symbol-supported communication
• Social stories
• Communication boards
• Assistive technology (where appropriate)
• Simplified language and processing time
• Sensory communication supports

Staff are trained to adapt their communication style to meet each child’s needs.

6. Accessibility of the Environment

We aim to ensure our environment is physically and sensory accessible by:
• Providing clear signage with visual symbols
• Maintaining uncluttered spaces
• Offering quiet or low-stimulation areas
• Making reasonable physical adjustments where required
• Considering lighting, noise levels and sensory triggers

Risk assessments will consider individual accessibility requirements.

7. Accessibility of Information

We ensure information is accessible by:
• Providing documents in clear, plain English
• Offering verbal explanations where needed
• Using visual supports for key information
• Providing large print versions upon request
• Offering meetings to explain policies and procedures
• Using email, phone, or face-to-face communication depending on parent preference

Where required, we will explore translation services or alternative formats.

8. Working with Parents and Carers

We value open and respectful communication with families and will:
• Establish preferred communication methods
• Provide regular updates on children’s progress and wellbeing
• Offer review meetings
• Respond to queries promptly
• Encourage collaborative decision-making
We recognise that parents and carers may also have accessibility needs and will make reasonable adjustments accordingly.

9. Staff Responsibilities

All staff must:
• Treat communication differences with respect
• Adapt their approach to meet individual needs
• Promote inclusion at all times
• Report any barriers to access
• Attend relevant training
• Follow this policy consistently

Management are responsible for ensuring training is provided, monitoring implementation, reviewing reasonable adjustments, and ensuring compliance with equality legislation.

10. Reasonable Adjustments

Where a barrier to communication or access is identified, Different Minds will assess the need, consult with parents/carers and relevant professionals, implement reasonable adjustments, and review effectiveness.

Adjustments may include changes to staffing ratios, environment layout, communication tools, or session structure.

11. Complaints or Concerns

If a parent, carer, or staff member feels that communication or accessibility needs are not being met, they should raise concerns with management in line with the Complaints Policy.

We are committed to resolving concerns quickly, respectfully and transparently.

12. Monitoring and Review

This policy will be reviewed annually or sooner if legislation changes, practice guidance is updated, or significant accessibility issues are identified.

Autism-Specific Induction Training Plan

Topics Covered:
• Understanding Autism and SEND
• Sensory Processing Differences
• Communication Styles and AAC
• Emotional Regulation and Co-Regulation
• Behaviour as Communication
• Reasonable Adjustments (Equality Act 2010)
• Working with Families and Professionals

Training Method:
Observation, mentoring and reflective practice.

Review:
Competency reviewed through supervision.

Equality, Diversity and Inclusion Policy

1. Policy Statement

Different Minds is committed to promoting equality, celebrating diversity, and creating an inclusive environment where all children, families, staff, and visitors feel respected, valued, and supported.

As a specialist childcare provider supporting children and young people with Special Educational Needs and Disabilities (SEND), inclusion is central to everything we do. We are committed to ensuring that no individual is disadvantaged or treated less favourably due to protected characteristics or personal circumstances.

2. Legal Framework

This policy is guided by:
– The Equality Act 2010
– The Children Act 1989 & 2004
– The SEND Code of Practice
– The Human Rights Act 1998
– Working Together to Safeguard Children

Different Minds complies fully with UK equality legislation.

3. Scope

This policy applies to all employees, volunteers, agency staff, children attending the setting, parents and carers, and visitors.

4. Our Commitment

Different Minds will:
– Provide equal access to services
– Promote positive attitudes towards diversity
– Make reasonable adjustments to remove barriers
– Prevent discrimination and harassment
– Provide staff training on equality and inclusion

5. Protected Characteristics

We recognise the following protected characteristics under the Equality Act 2010:
– Age
– Disability
– Gender reassignment
– Marriage and civil partnership
– Pregnancy and maternity
– Race
– Religion or belief
– Sex
– Sexual orientation

6. Inclusion of Children with SEND

As a specialist SEN childcare provider, inclusion is central to our practice. We adapt activities, use person-centred planning, provide differentiated support, and work collaboratively with families and professionals.

7. Recruitment and Employment

Different Minds is committed to fair and inclusive recruitment practices, equal opportunities, and career development based on merit and suitability.

8. Anti-Discrimination and Anti-Harassment

Different Minds has zero tolerance for discrimination, harassment, bullying, or victimisation. All concerns will be investigated promptly in line with disciplinary procedures.

9. Accessibility

We aim to remove barriers to participation by providing accessible communication methods, reasonable physical adjustments, and inclusive resources.

10. Promoting Diversity

We promote diversity through inclusive resources, celebration of different cultures, challenging stereotypes, and encouraging respectful behaviour.

11. Roles and Responsibilities

Director: Ensure implementation and review of this policy.
Staff: Uphold inclusive values and challenge discrimination.
Parents/Carers: Support inclusive values and raise concerns appropriately.

12. Monitoring and Review

This policy will be reviewed annually. Complaints, recruitment data, and service access will be monitored to ensure fairness and continuous improvement.

13. Breaches of Policy

Failure to comply with this policy may result in disciplinary action.

Accident, Incident and First Aid Policy
1. Policy Statement
Different Mind is committed to ensuring the health, safety and welfare of all children, staff, visitors and contractors.
We provide a safe, inclusive and supportive environment tailored to the needs of children with Special Educational Needs and Disabilities (SEND).
We comply with the Health and Safety at Work etc. Act 1974 and all relevant regulations.
2. Responsibilities
The Director/Manager is responsible for:
• Ensuring compliance with health and safety legislation
• Carrying out and reviewing risk assessments
• Maintaining safe premises and equipment
• Ensuring staff training and supervision
All Staff are responsible for:
• Taking reasonable care of their own health and safety
• Reporting hazards or concerns immediately
• Following policies and procedures at all times
3. Risk Assessments
Risk assessments are conducted regularly and reviewed annually or following significant change.
Specific assessments are completed for:
• SEND-specific needs
• Trips and outings
• Behaviour presenting risk
• Manual handling
• Fire safety
4. Fire Safety
Fire risk assessments are carried out and reviewed annually.
Fire drills are conducted regularly and recorded.
Fire exits are clearly marked and kept unobstructed.
5. First Aid and Accidents
At least one paediatric first aid trained member of staff is on site at all times.
Accidents and injuries are recorded and reported to parents/carers.
RIDDOR reporting requirements are followed where applicable.
6. Infection Control
• Regular cleaning schedules
• Handwashing protocols
• Safe nappy changing procedures
• Exclusion periods for infectious illnesses
7. Manual Handling
Staff receive appropriate manual handling training.
Individual moving and handling plans are in place where children require physical support.
8. Visits and Outings
Written risk assessments are completed prior to outings.
Appropriate staff-to-child ratios are maintained.
Emergency contact details are carried at all times.
9. Lockdown and Emergency Procedures
Different Mind recognises the importance of being prepared for emergency situations, including intruders, environmental risks, or incidents in the local area.
Types of Emergency May Include:
• Intruder on site
• Serious incident in the local community
• Environmental hazard (gas leak, severe weather)
• Missing child
Lockdown Procedure:
• The Manager or senior staff member will announce lockdown.
• All children and staff will move to the nearest safe indoor space.
• Doors and windows will be locked and blinds closed where possible.
• Children will be reassured in a calm, age-appropriate manner, taking SEND needs into account.
• Registers will be checked immediately.
• Mobile phones will be used to contact emergency services if required.
• No one will leave the building until it is declared safe.
Emergency Evacuation Procedure:
• On hearing the fire alarm or evacuation instruction, staff will escort children calmly to the designated assembly point.
• SEND-specific evacuation plans (PEEPs) will be followed where applicable.
• Registers will be taken and headcounts completed.
• Parents/carers will be informed as soon as reasonably practicable.
Lockdown drills will be practised periodically and recorded.
10. Monitoring and Review
This policy will be reviewed annually or sooner if legislation changes or following a serious incident.

Health and Safety Policy
1. Policy Statement
Different Minds is committed to ensuring the health, safety, and welfare of all children, staff, and visitors. We aim to prevent accidents and incidents wherever possible and ensure that effective procedures are in place to respond appropriately when they occur.
2. First Aid Provision
• At least one qualified Paediatric First Aider will be on site at all times.
• First aid kits are checked regularly and replenished as required.
• Emergency contact details and medical information are securely maintained.
• Staff receive training relevant to supporting children with SEND.
3. Accident and Incident Procedure
• The child/person will be assessed immediately.
• Appropriate first aid will be administered.
• Parents/carers will be informed as soon as possible.
• Emergency services will be contacted where required.
• All accidents and incidents will be recorded on the same day.
4. Head Injuries
All head injuries will be reported to parents/carers immediately. Children will be monitored and parents provided with written guidance on symptoms to observe.
5. RIDDOR Reporting
Different Minds complies with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013.

The Director will report to the Health and Safety Executive (HSE) where required, including:
• Death or specified serious injuries.
• Injuries resulting in hospital treatment.
• Over-seven-day staff incapacitation.
• Dangerous occurrences (near misses with serious potential harm).

Records of any RIDDOR report will be securely maintained.
6. Monitoring and Review
Accidents and incidents will be reviewed regularly to identify patterns and implement preventative measures. This policy will be reviewed annually.

Code of Conduct Policy
1. Policy Statement
Different Minds is committed to providing a safe, nurturing, inclusive, and professional environment for all children, families, staff, and visitors. As a specialist provider supporting children and young people with Special Educational Needs and Disabilities (SEND), we recognise our enhanced duty of care.
This Code of Conduct sets out the professional standards, behaviours, and expectations required of all employees, volunteers, students, agency staff, contractors, and management working at Different Minds.
This policy should be read in conjunction with the company’s Safeguarding, Health & Safety, Equality, Diversity & Inclusion, Data Protection, and Whistleblowing policies.
 
2. Scope
This policy applies to:
All permanent and temporary employees
Volunteers and students
Agency and contracted staff
Directors and management
Failure to adhere to this Code of Conduct may result in disciplinary action, up to and including dismissal.
 
3. Core Principles
All staff at Different Minds must:
Prioritise the welfare and safety of children at all times
Treat all children with dignity, respect, and compassion
Promote inclusion and celebrate diversity
Maintain professional boundaries
Act with integrity and honesty
Work collaboratively with colleagues and families
Uphold confidentiality
Promote a positive reputation of Different Minds
 
4. Professional Behaviour Standards
Follow safeguarding procedures at all times and immediately report concerns to the Designated Safeguarding Lead (DSL).
Maintain clear professional boundaries and avoid favouritism.
Respect and inclusion must underpin all interactions with children, families, and colleagues.
Handle confidential information in accordance with GDPR and company policy.
Use appropriate physical contact in line with care plans and safeguarding guidance.
Follow digital safety guidance and never use personal devices to photograph children.
 
5. Health and Safety Responsibilities
Follow risk assessments and safety procedures
Report hazards, accidents, and near misses
Participate in required training
Maintain safe supervision ratios
Follow emergency, lockdown, and evacuation procedures
 
6. Relationships with Parents and Carers
Maintain professional relationships
Avoid over-familiarity
Provide accurate and honest information
Escalate complaints or concerns to management
 
7. Breaches of the Code
Breaches of this Code of Conduct may result in informal or formal disciplinary action, suspension, dismissal, or referral to external authorities where appropriate.

Ofsted Disclosure Statement

Different Minds provides specialist childcare and support for children and young people with special educational needs and disabilities (SEND), including those over the age of eight. Due to the age range of the children we support, we are not currently required to be Ofsted registered, although we are in the process of applying for voluntary registration.

However, we are committed to maintaining the highest standards of care, safety, and professionalism. We are therefore in the process of undertaking voluntary registration with Ofsted, demonstrating our dedication to quality assurance, safeguarding, and continuous improvement.

All staff at Different Minds hold enhanced DBS checks and are suitably qualified and experienced in working with children and young people, including those with special educational needs. Our management team holds all relevant health and safety and first aid qualifications, ensuring a safe, supportive, and well-managed environment for every child in our care.

Safeguarding, wellbeing, and best practice are at the heart of everything we do at Different Minds, and families can be confident that we operate to robust policies and procedures that meet and exceed industry expectations.

Food Allergen Policy

1. Policy Statement

Different Minds Yorkshire Ltd is committed to providing a safe, inclusive, and healthy environment for all children. This includes ensuring that food provided is safe for consumption by children with allergies or intolerances. We recognise that allergic reactions can be life-threatening and treat the management of food allergens with the utmost seriousness.

2. Legal Framework

This policy is based on the following legislation and guidance:
– The Food Information Regulations 2014
– Food Safety Act 1990
– EU Food Information for Consumers Regulation (No. 1169/2011)
– The Children Act 1989 and 2004
– Early Years Foundation Stage (EYFS) Statutory Framework

3. Aims and Objectives

– To ensure all staff are aware of and comply with food allergen procedures.
– To prevent exposure of children to known allergens.
– To maintain clear and accurate allergen information for all meals and snacks provided.
– To communicate openly with parents/carers about dietary needs and allergen management.

4. Identifying Allergens

– Parents/carers must inform the setting of any known allergies or intolerances upon registration.
– A detailed Allergy and Dietary Requirement Form will be completed for each child.
– The information will be shared with all staff, displayed discreetly in food preparation areas, and updated regularly.

5. Food Preparation and Handling

– All kitchen and childcare staff will receive allergen awareness training.
– All allergen information for meals will be clearly documented and accessible.
– Cross-contamination will be prevented by:
  – Using separate utensils and preparation areas where necessary.
  – Cleaning all surfaces and equipment thoroughly before and after food preparation.
  – Storing allergen-free foods separately from those containing allergens.
– No food will be served unless staff are confident it is safe for each child.

6. Meal Planning and Communication

– Weekly menus will identify potential allergens using the 14 major allergens as defined by law (e.g., milk, eggs, nuts, etc.).
– Parents will be consulted before introducing new menu items.
– All outside food providers or caterers must provide allergen information and comply with this policy.

7. Emergency Procedures

– Staff are trained to recognise the signs of an allergic reaction and respond promptly.
– An Individual Healthcare Plan (IHP) will be created for any child with a severe allergy, including emergency contact details and action steps.
– Emergency medication (e.g., epinephrine auto-injectors) will be stored in an accessible, clearly labelled area.
– In the event of an allergic reaction:
  1. Administer emergency medication as per IHP.
  2. Call 999 immediately.
  3. Contact parents/carers.
  4. Complete an incident report.

8. Staff Training and Responsibilities

– All staff will receive training in allergen management, food hygiene, and first aid (including anaphylaxis response).
– The Manager is responsible for ensuring all allergy information is up-to-date and communicated effectively.
– The Cook/Kitchen Staff are responsible for safe preparation and accurate labelling of food.

9. Monitoring and Review

This policy will be reviewed annually or following any incident involving an allergen. Feedback from parents, staff, and external agencies will inform policy updates.

COVID-19 & Infectious Diseases Policy

1. Policy Statement

Different Minds is committed to providing a safe, healthy, and inclusive environment for all children, staff, families, and visitors. We recognise our duty to minimise the risk of COVID-19 and other infectious diseases while ensuring reasonable adjustments for children with autism and SEND.

2. Scope

This policy applies to all children attending Different Minds, all employees, volunteers, students, contractors, parents, carers, and visitors.

3. Legal Framework

This policy is informed by the Health and Safety at Work Act 1974, the Early Years Foundation Stage (EYFS) Framework, UK Health Security Agency (UKHSA) guidance, Public Health England (or successor bodies), and the Equality Act 2010.

4. General Infection Prevention Measures

Handwashing is promoted regularly using visual supports and social stories. High-touch surfaces and toys are cleaned frequently. Rooms are well ventilated where possible.

5. COVID-19 Specific Measures

Symptoms include high temperature, persistent cough, loss of taste or smell, and flu-like symptoms. If symptoms develop in the setting, parents or carers will be contacted immediately, and the child will be supported calmly until collection.

6. Other Infectious Diseases

This policy applies to illnesses such as norovirus, influenza, hand, foot and mouth disease, measles, and chickenpox. Recommended exclusion periods will be followed in line with UKHSA guidance.

7. Inclusion and SEND Considerations

Reasonable adjustments will be made for children with sensory sensitivities, anxiety, or difficulty tolerating changes. Visual aids and individual support will be provided.

8. Staff Responsibilities

Staff must follow infection control procedures, report symptoms promptly, and not attend work when unwell.

9. Parent and Carer Responsibilities

Parents and carers must keep children at home when unwell and inform the setting of infectious diseases.

10. PPE

Appropriate PPE will be used when necessary and explained to children in an age-appropriate and supportive manner.

11. Confidentiality

All health information is treated confidentially in line with GDPR.

12. Monitoring and Review

This policy is reviewed annually and updated in line with government guidance.

Violence at Work Policy

1. Policy Statement

Different Minds Yorkshire is committed to providing a safe, secure and supportive working environment for all employees, volunteers, children, families and visitors. We recognise that working with children with special educational needs may involve behaviours that challenge. Whilst some behaviours may arise from a child’s additional needs, any form of violence, aggression or abuse towards staff is taken seriously and managed appropriately.

2. Definition of Violence at Work

Violence at work includes any incident in which a person is abused, threatened, intimidated or assaulted in circumstances relating to their work. This includes physical assault (hitting, kicking, biting, pushing), verbal abuse (shouting, swearing, threats), emotional or psychological abuse, threatening behaviour, and damage to property.

3. Scope

This policy applies to all employees, agency staff, volunteers, students, directors, contractors and visitors working at or attending Different Minds Yorkshire.

4. Responsibilities

Management are responsible for ensuring risk assessments are in place, staff receive appropriate training, incidents are reviewed, and staff are supported. Employees are responsible for following procedures, using agreed behaviour support strategies, reporting incidents, and maintaining professional conduct.

5. Risk Assessment and Prevention

The centre will carry out individual risk assessments for children where necessary and develop behaviour support plans. Preventative measures include appropriate staffing ratios, environmental adaptations, structured routines, and staff training in de-escalation techniques.

6. Managing Incidents

A positive behaviour support approach is used at all times. De-escalation strategies must be attempted first. Physical intervention will only be used as a last resort to prevent harm, must be reasonable and proportionate, and must be recorded in line with centre procedures.

7. Reporting and Recording

All incidents of violence or aggression must be reported to management and recorded on an incident form. Management will review incidents to identify patterns and implement further control measures where required.

8. Support for Staff

Staff affected by violence at work will be offered appropriate support including first aid, debriefing, supervision, and further training where necessary.

9. Violence from Parents or Visitors

Aggressive or abusive behaviour from parents, carers or visitors will not be tolerated. Management may issue warnings, restrict access to the premises, terminate services in serious cases, or involve external authorities where required.

10. Policy Review

This policy will be reviewed annually or sooner if required following significant incidents or legislative changes.

GDPR & Privacy Policy

1. Policy Statement

Different Minds is committed to protecting the privacy and personal data of children, families, staff, and partners.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

As a provider operating under voluntary Ofsted registration, we ensure that data handling meets both statutory safeguarding expectations and Ofsted requirements.

2. Regulatory Alignment – Voluntary Ofsted Registration

Although Different Minds is voluntarily registered with Ofsted, we follow Ofsted safeguarding and record-keeping standards as best practice.

We maintain accurate records relating to:

  • • Child attendance
  • • Safeguarding concerns
  • • Staff suitability and DBS checks
  • • Complaints and incidents

These records are retained securely and made available to Ofsted upon inspection where legally required.

3. What Information We Collect

We may collect and process the following types of personal data:

  • • Child’s name, date of birth, address and contact details
  • • Parent/carer contact information
  • • Medical information, SEND assessments, EHCP details
  • • Safeguarding and welfare records
  • • Attendance and behavioural records
  • • Staff employment records including DBS information
  • • Financial and invoicing information

4. Lawful Basis for Processing

We process personal data under the following lawful bases:

  • • Consent
  • • Contractual obligation
  • • Legal obligation (including safeguarding duties)
  • • Vital interests
  • • Legitimate interests

Special category data, including health and SEND information, is processed in accordance with Article 9 of UK GDPR.

5. How We Use Information

We use personal data to:

  • • Provide safe and appropriate SEN childcare
  • • Fulfil safeguarding responsibilities
  • • Meet voluntary Ofsted registration requirements
  • • Communicate effectively with parents/carers and professionals
  • • Manage staffing, payroll, and safer recruitment processes

6. Data Sharing

We may share information where lawful and necessary with:

  • • Ofsted (as part of voluntary registration and inspection)
  • • Local Authorities
  • • Health professionals
  • • Safeguarding agencies
  • • Payroll, HR, and accounting providers

Information is shared securely and only where there is a lawful basis.

7. Data Processing Agreement (DPA)

Where Different Minds engages third-party providers to process personal data (e.g., payroll providers, IT systems, cloud storage), a written Data Processing Agreement (DPA) will be in place.

The DPA ensures that processors:

  • • Process data only on documented instructions from Different Minds
  • • Maintain confidentiality
  • • Implement appropriate security measures
  • • Do not engage sub-processors without authorisation
  • • Assist with data subject rights requests
  • • Report data breaches without undue delay
  • • Delete or return data at the end of the contract

All processors are vetted to ensure GDPR compliance.

8. Data Storage and Security

Personal data is stored securely in locked cabinets and/or encrypted password-protected systems.

Access is restricted to authorised personnel only.

We implement appropriate technical and organisational safeguards to prevent unauthorised access, alteration, disclosure, or loss.

9. Data Retention

Records are retained in line with statutory guidance and childcare sector retention schedules.

Safeguarding and Ofsted-related records are retained for the legally required minimum periods.

10. Individual Rights

Under UK GDPR, individuals have the right to:

  • • Access their personal data (Subject Access Request)
  • • Request correction of inaccurate data
  • • Request erasure (where applicable)
  • • Restrict or object to processing
  • • Data portability (where applicable)

Requests must be submitted in writing to the Data Protection Lead.

11. Data Breaches

Any personal data breach will be recorded and investigated.

Where required, breaches will be reported to the Information Commissioner’s Office (ICO) within 72 hours.

Affected individuals will be notified where there is a high risk to their rights and freedoms.

Safeguarding and Child Protection Policy

1. Policy Statement

Different Minds is fully committed to safeguarding and promoting the welfare of all children and young people in our care.

We recognise that children with Special Educational Needs and Disabilities (SEND) are particularly vulnerable to abuse and may face additional barriers to reporting concerns.

We aim to provide a safe, inclusive, and nurturing environment where every child feels secure, respected, listened to, and protected from harm.

2. Legal Framework

This policy is written in line with the following legislation and statutory guidance:

  • • Children Act 1989
  • • Children Act 2004
  • • Working Together to Safeguard Children (latest version)
  • • Keeping Children Safe in Education (best practice principles)
  • • Counter-Terrorism and Security Act 2015 (Prevent Duty)

3. Types of Abuse

  • • Physical Abuse – Deliberately causing physical harm.
  • • Emotional Abuse – Persistent emotional maltreatment.
  • • Sexual Abuse – Forcing or enticing a child to take part in sexual activities.
  • • Neglect – Persistent failure to meet a child’s basic physical and/or psychological needs.

4. Designated Safeguarding Lead (DSL)

Different Minds appoints a Designated Safeguarding Lead (DSL) and a Deputy DSL.

The DSL is responsible for managing safeguarding concerns, liaising with external agencies, maintaining secure records, and ensuring staff receive appropriate safeguarding training.

5. Safer Recruitment

Different Minds follows safer recruitment procedures including:

  • • Enhanced DBS checks
  • • Identity verification
  • • Two professional references
  • • Full employment history checks
  • • Safeguarding-based interview questions

6. Responding to Concerns

If a child discloses abuse, staff must:

  • • Remain calm and listen carefully
  • • Not promise confidentiality
  • • Reassure the child they have done the right thing
  • • Record accurately using the child’s own words
  • • Report immediately to the DSL

If a child is in immediate danger, emergency services (999) must be contacted immediately.

7. Recording and Reporting

All safeguarding concerns must be recorded clearly, dated, signed and stored securely.

Referrals to Children’s Social Care will be made where safeguarding thresholds are met.

8. Allegations Against Staff

Any concerns about a member of staff must be reported immediately to the Director or the Local Authority Designated Officer (LADO).

Staff must not investigate allegations themselves.

9. Online Safety

Different Minds ensures supervised internet access, appropriate filtering systems, and age-appropriate online safety education.

10. Safeguarding Children with SEND

Children with SEND may have communication difficulties and increased vulnerability.

Different Minds ensures:

  • • Clear intimate care plans
  • • Communication support strategies
  • • Promotion of child voice
  • • Clear professional boundaries

Appendix 1 – Prevent Duty (Radicalisation and Extremism)

Different Minds recognises its duty under the Counter-Terrorism and Security Act 2015 to prevent people from being drawn into terrorism.

Radicalisation refers to the process by which a person comes to support extremism and terrorist ideologies.

Extremism is defined as vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs.

Staff Responsibilities:

  • • Be alert to signs of radicalisation or extremist views
  • • Report concerns immediately to the DSL
  • • Complete Prevent awareness training
  • • Promote British values through inclusive practice

Possible indicators of radicalisation may include:

  • • Use of extremist language or symbols
  • • Sudden isolation from peers
  • • Fixation on extremist ideology

Concerns will be managed in line with safeguarding procedures and may be referred to the Channel programme where appropriate.