Samira Sadeghi, Director of Trust Governance, CST
The Academy Trust Governance Code makes clear that the board holds primary responsibility in ensuring everyone’s right to feel safe. That means developing and implementing a safeguarding strategy, recording and managing safeguarding risks, and ensuring staff have sufficient training and understanding to speak up and feel comfortable about raising concerns. And it goes beyond compliance with policies and procedures. It’s a responsibility to promote a culture in which everyone feels safe and respected.
Trusts are the engines of innovation and our safeguarding practice is a shining example of this. There is an abundance of established good practice in trusts, but official guidance still doesn’t recognise the strategic role that trusts play in safeguarding children. Keeping Children Safe in Education and Working Together to Safeguarding Children are both focused almost exclusively on schools and have failed to respond to the emergence of trusts as the responsible body for the majority of schools in England.
This is a missed opportunity.
To fill this gap, we published Safeguarding at scale last year. In it, Dai Durbridge of Browne Jacobson describes how safeguarding at scale is different, requiring more complex leadership and management techniques. He sets out a three-pronged approach, including a leadership structure, clear roles and responsibilities and vertical and horizontal lines of communication. He outlines how safeguarding delivery across the trust might be designed differently in different trusts. And he describes how a solid safeguarding strategy could provide assurance and enable prevention rather than fire-fighting.
One key aspect of a safeguarding strategy is ‘audit and quality assurance’. Yesterday, we launched a consultation with our safeguarding professional community on our draft guidance, Safeguarding peer review. It is a knowledge-building piece that sets out the principles and a proposed framework for effective trust safeguarding audits, representing the product of collective intelligence of a task and finish group comprised of 13 expert colleagues from trusts and the NSPCC. We have intentionally opted for the phrase ‘peer review’ rather than ‘audit’. An ‘audit’ feels done to, not done with, and we know that the most effective and sustainable approach to assurance is a collaborative and developmental one.
Safeguarding governance cannot be a tick box exercise. As we said in Next-gen governance: "[A] solitary focus on the basics – accountability, compliance and avoiding failures – is not sufficient. The path forward demands a more nuanced board leadership style that is comfortable with complexity, agile and evolving governance structures and mechanics, and a shift towards relational approaches that build longer-term resilience. Trust boards themselves must lead the way in envisioning next-gen governance, viewing compliance as the starting point, not the finish line.”
The principles and framework we set out in Safeguarding peer review are founded on the same values and mindsets we described in Next-gen governance:
- Stewardship: Peer reviews that look beyond compliance and towards building a sustainable culture of safeguarding
- Assurance not reassurance: Peer reviews that trust in the professional judgement of our colleagues but simultaneously hold them to account
- Solutions-focus: Peer review findings that are forward-looking, well-evidenced and actionable
- Psychological safety: Peer reviews that encourage openness and a ‘speak up’ culture within the trust
- A relational approach: Peer reviews as a continuous process rather than a standalone event, and one that empowers and develops our colleagues
- Prevention not fire-fighting: Peer reviews that encourage early intervention and proactive risk assessments, to anticipate potential issues and act pre-emptively
- Collaboration and two-way communication: Peer reviews that expect both vertical and horizontal two-way communication in the trust and help identify and share excellent ideas, which leads to constantly improving practice across the trust
- Eliminate duplication and fluffload: Peer reviews, done right, serve as the most important tool in our arsenal to develop and maintain consistently good practice across our trusts. Done wrong, they become unhelpful fluffload.
And local authority audits are not only duplicative, but they also feel like a tick box exercise and safeguarding governance cannot be a tick box exercise. While we are keen to work closely with our local authorities, we also know that having to complete multiple sets of audits is adding to the workload of our already over-worked DSLs, and doesn’t make our children any more safe.
Dai presents a solution in Safeguarding at scale: "Trusts could work together to agree an audit format between them and propose it to the LA as a consistent model for them to adopt across the area." That was the inspiration for this knowledge-building piece.
Our new guidance is designed to demonstrate the thoroughness and professionalism of trust safeguarding peer reviews. Done well, these peer reviews should now serve as sufficient evidence to local authorities that a trust is compliant with all statutory requirements and negate the need for DSLs to complete an entire separate local authority audit that covers exactly the same ground.
We hope our guidance, once published more widely following consultation, will positively impact on safeguarding governance practice not just in trusts, but in the education system more broadly. Together we can work together to drive safeguarding excellence in all schools and keep our children safe and well.
