Who we are

Our website address is: https://functionalskillsuk.co.uk.

What personal data we collect and why we collect it


When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.


If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms


If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.


Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

What data breach procedures we have in place

What third parties we receive data from

What automated decision making and/or profiling we do with user data

Industry regulatory disclosure requirements

Swim UK Data Protection Policy/Statement

Functional Skills UK (FSUK) is fully committed to protecting the rights and privacy of individuals, in accordance with the Data Protection Act 1998 and GDPR regulations 2018. Information about our personnel, candidates and other individuals will only be processed in line with established regulations. Personal data will be collected, recorded and used fairly, stored safely and securely and not disclosed to any third party unlawfully. As the lawful and correct treatment of personal information is critical to our successful operations and to maintaining confidence.  FSUK is committed to:

  • Protecting staff and candidates’ personal details, records and assessment outcomes
  • keeping staff and candidates’ and other individuals’ personal data up to date and confidential 
  • maintaining personal data only for the period required
  • Releasing personal data (in any form and by any means) only to authorised individuals/parties.
  • collecting accurate and relevant data only for specified lawful purposes
  • adhering to regulations and related procedures to ensure that all employees who have access to any personal data held by or on behalf of FSUK are fully aware of and abide by their duties under the Data Protection Act 1998 and GDPR regulations 2018.

Candidates are required to report any allegation in relation to the unlawful treatment of personal data via the FSUK candidate complaint procedure. A complaint should be made if candidates feel that records of their personal data have been:

  • lost 
  • obtained through unlawful disclosure or unauthorised access 
  • recorded inaccurately and/or in a misleading manner
  • Provided to a third party without permission.

Where required, FSUK will take appropriate action/corrective measures against unauthorised/unlawful processing, loss, destruction or damage to personal data.

It is ultimately the responsibility of the Centre Manager, to ensure that this policy is published and accessible to all personnel, candidates and any relevant third parties.

This policy applies to staff employed by Functional Skills UK ltd, Gym UK and Pavilion training, Brighton Swimming Centre ltd and Brighton Swimming Centre ltd t/a Brighton Swimming School, Pool to Pier and any other brands adopted by either company.

Functional Skills UK Appeals and Complaints Policy

Appeals and Complaints Policy and Procedure

Policy Statement

Candidates (including Apprentices) accessing our training from any funding pathway have the right to launch a complaint against their Tutor/On Programme Assessor and/or appeal against an assessment decision if they feel that the decision is unfair. Functional Skills UK (FSUK) will treat all complaints fairly and without prejudice. In return we expect that any candidate launching a complaint will also treat our staff dealing with your complaint with the same courtesy, respect and fairness


If a candidate wishes to make a complaint about a course, a tutor or a facility then in the first instance FSUK Centre Managers should be made aware in writing, either via email or post:

Charlie Dew and Luke Hardy

Swim UK, Skills House, 2 Gordon Mews, Gordon Close, Portslade, BN41 1HU



If you require a reasonable adjustment because you are a disabled person and unable to contact us in writing, please call: 01273 434400.

FSUK management will deal with your service complaint promptly. We will acknowledge receipt of a written complaint within five working days where we have a return address and you can expect to have a full reply within 20 working days. If we do not have all the details required to deal with the complaint, we may contact you and ask you for further information. In a few cases we will not be able to send a full reply within 20 working days of receipt, for example if your complaint is very complex or requires us to liaise with an awarding body. If this happens, we will tell you the reason why and let you know when we will be able to reply in full, keeping you fully informed of progress.

We will not treat you less favourably than anyone else because of your:

  • sex or legal marital or same-sex partnership status: this includes family status, responsibility for dependants, and gender (including gender reassignment, whether proposed, commenced or completed)
    • sexual orientation
    • colour or race: this includes ethnic or national origin or nationality
    • disability
    • religious or political beliefs, or trade union affiliation
    • any other unjustifiable factors, for example language difficulties, age, pregnancy and maternity.

If the resolution we have offered you is unsatisfactory then you will have the option to go to our Managing Director – Paul Smith and explain in writing your reasons – paulsmith@brightonswimmingschool.com

If you are an apprentice with us your complaint will not affect your apprenticeship training or funding.

Confidentiality – All complaints received will be dealt with confidentially and in accordance with the requirements of the Data Protection Act 1998, subject to the need to disclose information as required by statutory authorities, and/or as a result of statutory, legal or parliamentary obligations placed on the Commission.

1 Appeals procedure

If the Candidate feels that they have a justified reason to appeal against the assessment made by their Course Tutor /On programme tutor or the Internal Verifier then the following procedures should be followed:

1.1         A Candidate’s first line of appeal is to their Tutor/On Programme Tutor. It should be made in writing and clearly explain the nature of the appeal. A copy should also be sent to the Centre Managers.

1.2         The Tutor/On Programme Tutor is required to respond to the appeal in writing within 10 working days and a copy be sent out the Centre Coordinator and the Internal Verifier.

1.3         The Course Tutor/On Programme Tutor may either confirm the original assessment or revise it.

1.4         The Candidate can either accept this assessment or proceed with the second line of appeal.

1.5         The Candidate’s second line of appeal is to their Internal Verifier. This again should be made in writing including all relevant details and any supporting evidence. A copy should also be sent to the Centre Managers.

1.6         A panel made up of the Internal Verifier and two Assessors will meet to judge the evidence.

1.7         Within 7 days of the appeal being received the Candidate will be informed in writing of the decision reached.

1.8         The panel will either confirm the original assessment or support the appeal and reach an agreement with the Assessor and Candidate based on the evidence provided. In the unlikely event of a disagreement between the Course Tutor and the Internal Verifier with regard to the assessment the decision of the Internal Verifier will prevail.

1.9 In the event that the Internal Verifier/Panel is unable to make a decision or the candidate still feels that the decision is unfair then the next line of the appeal is to the External Verifier. For the Internal Verifier this must be done in the form of a report for the Candidate this must be done in writing.

1.10       The External verifier may confirm the original assessment, support the appeal on the evidence provided or obtain further advice from the Chief Verifier or such higher bodies as are relevant.

1.11       If a satisfactory conclusion for the Candidate is not reached by this stage then they may:

1.12       Appeal directly to the relevant awarding body, a fee for handling such appeals will be chargeable to the Candidate. This will only be refunded if the appeal is upheld.

1.13       Be required to be reassessed in a specific assessment area or against the total assessment criteria. In this situation a fee equal to that charged by the awarding body will be made to the Candidate.

During the RLSS NPLQ courses candidates are assessed by external assessors, not their course tutor. Therefore, for Pool Lifeguard qualifications in the first instance a complaint needs to be submitted to the Approved Training Centre Co-ordinator. For lifesaving qualifications an appeal needs to be made to RLSS UK Branch Lifesaving Co-ordinator. For further information see Page 9 of the RLSS code of practise (copy kept in FSUK office).

For Active IQ: If an individual wishes to appeal against a decision taken by a centre it must first of all go through the centre’s appeals process before bringing the matter to Active IQ. (Full copy of Active IQ appeals policy kept in FSUK Office)

For Swim England, if an individual wishes to appeal against a decision taken by a centre it must first of all go through the centre’s appeals process before bringing the matter to the Swim England. (Full copy of appeals policy kept in FSUK Office)

Learners enrolled on behalf of Prime Further Education Providers.

Learners enrolled via a funded learning programme on behalf of our Prime Learning Providers detailed below have the right to take any issue up directly with them directly.

Greater Brighton Metropolitan College (MET), 1A Pelham Street, Brighton, BN1 4FA              01273 667788

Skills Training UK, 12th Floor, York House, Empire Way, Wembley, HA9 0PA

Tel: 0208 7958222

Paul Smith is ultimately responsible for ensuring this policy is carried out, that it is fit for the purpose, relevant and complies with legislation.

This policy applies to staff employed by Functional Skills UK ltd t/a Swim UK, Gym UK and Pavilion training, Brighton Swimming Centre ltd and Brighton Swimming Centre ltd t/a Brighton Swimming School, Pool to Pier and any other brands adopted by either company.

Gender Equality and Equal Opportunities Policy and Implementation Plan

As a training provider we have this policy in place to:

  • Help embed ‘Due regard’ to the Public-Sector Equality Duty/Equality Act 2010 into programme delivery; and
  • Help meet EU structural fund regulations to promote gender equality and equal opportunities

Policy Statement:

The senior management of Functional Skills UK (FSUK) are committed to providing working and learning opportunities for all.

  • By eliminating unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act;
  • Advance equality of opportunity between people who share a protected characteristic and those who do not;
  • Foster good relations between people who share a protected characteristic and those who do not.

We recognise the importance of the Equality Act 2010 and come under the scope of the Public-Sector Equality Duty (see policy folder for copy). We strive to achieve an inclusive culture of excellence without prejudice, bullying, harassment and discrimination of any type.  

Paul Smith MD is ultimately responsible for ensuring this policy is carried out, that it is fit for the purpose, relevant and complies with legislation.

This policy covers staff and participants alike.

This policy covers the nine protected characteristics of the Equality Act 2010 (Age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation).

Our aim is to ensure that all employees, job applicants and learners are given equal opportunities and that our organisation is representative of all sections of society. Every employee and learner will be respected and valued and able to give their best as a result.


  1. All employees, whether they are Full-time, Part-time or temporary, will be treated fairly and with   respect. When Functional Skills UK selects candidates for employment, promotion, training or any other benefit it will be on the basis of their ability. All employees will be given help and encouragement to develop their full potential and utilise their unique talents. Therefore, the skills and resources of our organisation will be fully utilised and we will maximise the efficiency of our workforce.  
  2. All employees will be given help and encouragement to develop their full potential and utilise their unique talents. Therefore, ensuring our whole workforce is as efficient as possible.
  3.  FSUK will not tolerate any form of intimidation, bullying or harassment in the workplace, and will discipline those that breach this policy.
  4. FSUK will make training, development and progression opportunities available to all staff.
  5. FSUK believe in promoting equality in the workplace, this is good management practise and makes business sense.
  6. We will encourage anyone who feels they have been subject to discrimination to raise their concerns so we can intervene.
  7. During staff induction, new members of staff are asked to read our policies and sign to say they understand and agree.


  1. All candidates will be asked if they require additional support, have learning difficulties, cultural      requirements, medical conditions or special needs at the beginning of their programme in order to identify where we can assist them. Additionally, their Induction for their Apprenticeship or any other learning will be assessed to assist in identifying any requirements. All learners will undertake Initial assessment in English and maths at induction. All FSUK tutors will be informed of any areas of concerns identified.

If required ALN support will be provided. FSUK will inform the relevant awarding bodies to ensure that additional support can be offered during assessments.

  • Personal information on candidates will be treated as confidential and any information held on computer will be subject to the Data Protection Act.
  • During Induction all learners are taken through a presentation of what they can expect from us and what we expect from them during their time with us and our values. Within this we talk ask learners to:

Please look out for each other, treat others with respect and tolerance, regardless of background or beliefs.

Understand the importance of respect for everyone.

Understand the importance of listening to what everyone has to say, whether you agree or not.

Achieve your potential, challenge, develop, inspire and stretch yourself.

  • All learners are given our policies at induction so we can be transparent in our commitment to Equality and Equal Opportunities.
  • Learners leave induction fully aware that they should expect to be taught in an environment where their contributions are recognised and valued, and also that FSUK do not tolerate any form of intimidation, bullying, or harassment.

The rights, responsibilities and duties of employees and candidates:

               It is the right of all employees and candidates to work and train without being discriminated or prejudiced against, bullied or harassed.

               It is the responsibility of all employees and candidates to ensure that they do not contravene equal opportunities legislation by discriminating, bullying or harassing anyone. 

               It is the duty of all employees and candidates to report any discrimination, prejudice, bullying, harassment or unfair treatment that is happening during work or learning.  This should, in the first instance be reported to a line manager; if it is not resolved it should be reported to Paul Smith. 

               Breaches of the Equal Opportunities Policy are regarded as breaches of discipline and as such are subject to disciplinary procedures.  Complaints of any kind relating to the equality of opportunity may be taken through the grievance procedure for staff or candidates.

               Allegations of breaches of equal opportunities for staff or learners will be answered by Paul Smith within 5 working days of the complaint being made.  Where, due to the nature of the complaint this is not possible an initial response explaining that it is being investigated will be sent out with 5 working days.

              If the complainant is satisfied with the response and following action, then no further action will be taken.

              If the complainant is not satisfied with the response then Paul Smith will take further action, it may be that he has to go through disciplinary process, or acquire additional support or guidance from external agencies.

Learners enrolled on behalf of Prime Further Education Providers.

Learners enrolled via a funded learning programme on behalf of our Prime Learning Providers detailed below have the right to take any issue up directly with them directly.

Greater Brighton Metropolitan College, 1A Pelham Street, Brighton, BN1 4FA. Tel: 01273 667788

Skills Training UK

12th Floor, York House, Empire Way, Wembley, HA9 0PA

Tel: 0208 7958222

Implementation Plan

To maintain steps already taken:

Equality and Diversity is a standard agenda item for weekly meetings held with all core staff, and Standardisation meetings held with all tutors/assessors.

Policies are reviewed annually

Senior staff member oversees Equality and Diversity and has specialist training which they cascade throughout the organisation.

During Inductions for staff and learner’s policies are distributed. Staff have to sign to agree to adhere to the policies and Apprentices have to sign their Apprenticeship Agreement.

All current staff have undertaken NCFE Equality, Diversity and Inclusion module.

Advertising job vacancies across many areas via Love Local Jobs and Indeed.

To help monitor our effectiveness with staff, after annual Staff Appraisals staff are asked to complete a Staff Evaluation which includes:

Do you think our policies and practices are effective?

Staff undertake regular training and CPDs in qualifications such as Safeguarding and Prevents and Understanding Autism. This ensures we are informed and have enough awareness to offer equal opportunities.

Data: Via our online CRM system we can monitor and identify any underrepresentation.

Weekly analytics reports of our website and social media campaigns mean we can monitor certain characteristics of our users.           

This policy applies to staff employed by Functional Skills UK ltd t/a Swim UK, Gym UK and Pavilion training, Brighton Swimming Centre ltd and Brighton Swimming Centre ltd t/a Brighton Swimming School, Pool to Pier and any other brands adopted by either company. This policy and procedure will be reviewed annually to ensure that it remains fit for the purpose, suitable and complies with legislation.

Prevent Policy

A Prevent policy includes all members of staff and learners. A Safeguarding policy covers Under 19’s and vulnerable adults. Functional Skills UK (FSUK) have a legal responsibility to have due regard to the need to prevent people from being drawn into terrorism.

To reduce the risks of terrorism we need not only to stop the terrorist attacks but also to prevent people becoming terrorists. There isn’t a single profile of someone who may be at risk of being drawn into terrorism. People who are vulnerable to becoming involved in terrorism can be any age, from any group, faith, ethnicity or background. If you read the information below and believe you, or someone you know is at risk of being drawn into extremism or radicalised then please follow the reporting channels within this policy. FSUK staff have had training and can help.

There are many factors associated with a person who becomes or could become vulnerable to being drawn into terrorism:

  • Peer pressure
  • Influence from other people
  • The Internet
  • Bullying
  • Crime and Anti-social behaviour
  • Family tensions
  • Race or hate crime victim
  • Lack of self-esteem or identity
  • Personal or political grievances
  • Personal hardships – poverty, disadvantage and social exclusion
  • Traumatic events, global, national or personal

There are many signs that a person is being drawn into terrorism, this is not an exhaustive list:

  • Withdrawn
  • Visual changes in appearance
  • Learning/speaking a different language
  • Avoiding eye contact
  • Defensive body language
  • Attitude
  • Decline in attendance

Definition of extremism

Extremism as is defined in law as: vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.

(Counter-terrorism and Security Act 2015)

Examples of extremism:

  • White supremacists
  • Anti-Semitism
  • Holocaust denial
  • Race and religion hatred
  • Homophobia

Definition of radicalisation

Radicalisation is a process by which an individual or group comes to adopt increasingly extreme political, social, or religious ideals and aspirations that reject or undermine the status quo or reject and/or undermine contemporary ideas and expressions of freedom of choice. For example, radicalism can originate from a broad social consensus against progressive changes in society. Radicalisation can be both violent and nonviolent, although most academic literature focuses on radicalisation into violent extremism. There are multiple pathways that constitute the process of radicalisation, which can be independent but are usually mutually reinforcing.

The Governments strategy for countering international terrorism is called CONTEST.


Prevent strategy is one of the 4 strategies – Their aim of Prevent is to stop people becoming or supporting terrorists, by challenging the spread of terrorist ideology, supporting vulnerable individuals, and working in key sectors and institutions. This is a proactive strategy to mitigate risk.

Channel is a key element of the Prevent strategy, it is a multi-agency approach to protect people at risk from radicalisation. Channel is about Safeguarding children and adults from being drawn into committing terrorist–related activity. It is about early intervention to protect and divert people away from the risk they face before illegality occurs. Channel assess vulnerability separately around three dimensions:

  • Engagement with a group, cause or ideology
  • Intent to cause harm; and
  • Capability to cause harm

Referral – when a person is identified a referral is made to Channel police practitioner

Preliminary assessment – Vulnerability assessment

Multi-Agency Panel – Safeguarding and promoting the welfare and vulnerable children and adults is the responsibility of all statutory partners

Support – If the person is suitable for help through the channel process support packages and interventions will be put in place.

The remaining three strategies are:

Pursue: Aims to disrupt and stop terrorist attacks, wherever possible by prosecuting those who have engaged in terrorist related activity. Active Investigation stage and intel-gathering.

Protect: Aims to strengthen our protection against a terrorist attack in the UK or against our interests overseas and reduce our vulnerability.

Prepare:  Aims to mitigate the impact of a terrorist attack where that attack cannot be stopped.

(ref: http://www.preventforfeandtraining.org.uk/get-training)

At FSUK, we are committed to keeping our staff and tutors aware so they can safeguard our learners. All staff and tutors will be asked to undergo prevent training (Foundation Learning, online module).  Tutors will be asked to complete the Practitioners module and staff will be asked to complete the Support Staff module. Welfare officers and managers will be asked to complete the Leaders and manager’s module.

Safeguarding concern

We must use our professional judgement to decide what a safeguarding concern is. When referring an individual. Two things that will always be a Safeguarding concern and should be reported are:

  • Evidence of sharing extremism websites
  • Evidence of homophobia/ religious prejudice  

Who to report to:

Staff and all learners (including apprentices) are expected to report any concerns to the designated Safeguarding/Prevent officer (Luke Hardy and Charlie Dew).



01273 434400 – option 2

Apprentices should understand that they have our support if they have concerns regarding their workplace and should follow the same reporting procedures.

As with Safeguarding concerns an incident report form will be completed by the member of staff/learner who has reported the concern.

Incidents are logged on a spreadsheet on a password protected spreadsheet. Only Safeguarding and Welfare Officers have access to this spreadsheet.

FSUK designated Safeguarding/Prevents officer will then conduct an investigation and, if necessary, consult the relevant agency. 

Individuals do not need to give their consent for referral to the prevent team or co-ordinator.

  • If the local prevent team/co-ordinator decide the individual is vulnerable, then they will refer them to Channel.
  • A Channel panel will then decide if a referral is necessary. If it is then a tailored programme of support will be organised.
  • Individuals (or parents if the individual is under 19) must give consent to engaging in the channel programme.
  • Not every Prevent referral is a Channel referral.
  • Channel process will not be highlighted through the DBS.

At the point of referral to an external agency or closing the incident the spreadsheet is updated and a date of sign off agreed. Any evidence from the incident is kept in a secured file.

British values are key in helping us tackle terrorism. FSUK keep these at the heart of all we do.

What are British Values?

British values are defined as “democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs”; institutions are expected to encourage students to respect other people with particular regard to the protected characteristics set out in the Equality Act 2010.

Staff should exemplify British Values through their personal behaviour and in interaction with students and colleagues.

Further information:



http://www.preventforfeandtraining.org.uk/ There are lots of useful resources on this website

See also: FSUK Safeguarding policy.

This policy applies to staff employed by Functional Skills UK ltd, Gym UK and Pavilion training, Brighton Swimming Centre ltd and Brighton Swimming Centre ltd t/a Brighton Swimming School, Pool to Pier and any other brands adopted by either company.


Vulnerable Adults and Child Protection Policy


A General Policy Statement

B Designated Staff with Responsibility for Child Protection

C Dealing with Disclosure of Abuse and Procedure for Reporting Concerns

D Reporting and Dealing with Allegations of Abuse against Members of Staff

E Recruitment and Selection Procedures

A Policy Statement

Functional Skills UK (FSUK) has a responsibility towards safeguarding and promoting the welfare of young people receiving education and training with us. Safeguarding and promoting the welfare of children is defined for the purposes of this guidance as: 

• protecting children from maltreatment • preventing impairment of children’s health or development • ensuring that children grow up in circumstances consistent with the provision of safe and effective care • taking action to enable all children to have the best outcomes.

Throughout these policies and procedures, reference is made to “young people”. This term is used to mean “those under the age of 18”.  However, FSUK also recognizes that some adults with learning difficulties and any adults who are vulnerable in any manner whatsoever, are to be protected within this policy.  The term “young people” refers to all the above within this policy.

The procedures will be applied to allegations of abuse and the protection of vulnerable adults.

We must wherever possible strive to:

  • Provide a safe environment for young people to learn in
  • Identify young people who are suffering, or likely to suffer, significant harm, and
  • Takes appropriate action to see that such young people are kept safe, both at home and whilst attending our courses.
  • Report immediately to MET GB College/Skills Training UK Training Academy any concerns we have regarding any of their learners.

In pursuit of these aims, FSUK will approve and review policies and procedures with the aim of:

  • Raising awareness of issues relating to the welfare of young people and the promotion of a safe environment for young people learning with our organisation.
  • Aiding the identification of young people at risk of significant harm, and providing procedures for reporting concerns
  • Establishing procedures for reporting and dealing with allegations of abuse against members of staff
  • The safe recruitment of staff
  • FSUK will refer concerns that a young person might be at risk of significant harm to social services and the police where relevant.
  • We promote our policy by directing all learners during inductions to our website where our policies are held. We give out wallet sized cards to all learners with clear details of where they are held on the website, along with contact details for head office.
  • Tutors cover Safeguarding during courses, it forms part of their checklist of teaching topics.

Covid 19 Online Teaching

Since March 2020 our delivery has been primarily online. Remote learning must hold Safeguarding in the same regard as classroom-based teaching. Please take these points into consideration when teaching:

  1. If recording videos or livestreaming lessons, make sure to film in a neutral area where nothing personal or inappropriate can be seen or heard in the background. Zoom does have a virtual background option that you can use.
  2. If communicating with students online, make sure the platform you are using is suitable for their age group. Also check the privacy settings.
  3. FSUK have accounts for online platforms for you to use. Teachers should avoid using personal accounts. This also applies to communication via email.
  4. FSUK have set out clearly when it is and isn’t appropriate to contact learners at home. See Tutors/Assessors code of conduct.
  5. Talk to learners regularly about the benefits and risks of the online world and give them space to ask questions.
  6. Tell children and young people where they can go if they are worried about anything or need to talk to someone if FSUK is closed.

If adults are worried about children (under 18) they can get advice – 0808 800 5000 or help@nspcc.org.uk

Childline – 0800 1111 – via childline.org.uk you can email or start a live chat

FSUK recognise the following as definitions of abuse:


Indicators of abuse and neglect

All school and college staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another. Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children. Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone. Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education.


Neglect is the persistent or severe failure to meet a young person’s basic physical and/or psychological needs. It will result in serious impairment of the child’s health or development. Any child may benefit from early help, but all staff should be particularly alert to the potential need for early help for a child who: • is disabled and has specific additional needs • has special educational needs (whether or not they have a statutory Education, Health and Care Plan) • is a young carer • is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement and association with organised crime groups • is

frequently missing/goes missing from care or from home • is at risk of modern slavery, trafficking or exploitation • is at risk of being radicalised or exploited • is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse • is misusing drugs or alcohol themselves. Knowing what to look for is vital to the early identification of abuse and neglect. If staff are unsure, they should always speak to the designated safeguarding lead (or deputy). 

Sexual Abuse – Whilst not intended to be an exhaustive list, sexual harassment can include:

Sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names;  • sexual “jokes” or taunting;  • physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (schools and colleges should be considering when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature; and  • online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include: • non-consensual sharing of sexual images and videos;  • sexualised online bullying;   • unwanted sexual comments and messages, including, on social media; and • sexual exploitation; coercion and threats The response to a report of sexual violence or sexual harassment The initial response to a report from a child is important. It is essential that all victims are reassured


Bullying can take many forms and may include threatening, inappropriate or abusive statements, made on social networks or via the internet in general.


The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation: technology often provides the platform that facilitates harm. An effective approach to online safety empowers a school or college to protect and educate the whole school or college community in their use of technology and establishes mechanisms to identify, intervene in, and escalate any incident where appropriate.

The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk: 

• content: being exposed to illegal, inappropriate or harmful material; for example pornography, fake news, racist or radical and extremist views; • contact: being subjected to harmful online interaction with other users; for example commercial advertising as well as adults posing as children or young adults; and • conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example making, sending and receiving explicit images, or online bullying.

See FSUK website hub for organisations and resources that can help keep children safe online.

B Designated Staff with Responsibility for Child Protection

Both Functional Skills UK and Brighton Swimming Centre have named Safeguarding personnel, their contact details are displayed in all training rooms and areas accessible to learners and staff. Named personnel undertake refresher training annually either at workshops (Time to Listen), online (Hi-Speed Training). FSUK are committed to achieving all that this policy sets out.

All have received training in child protection issues.

The designated senior member of staff is responsible for:

  • Overseeing the referral of cases of suspected abuse or allegations
  • Providing advice and support to other staff on issues relating to child protection
  • Maintaining a proper record of any child protection referral, complaint or concern (even where that concern does not lead to a referral)
  • Ensuring that parents of young people within FSUK are aware of our child protection policy
  • Liaising with appropriate agencies
  • Liaising with employers, colleges and training organisations that we deal with.
  • Ensuring that relevant staff receive basic training in child protection issues and are aware of FSUKs child protection procedures.

C Dealing with Disclosure of Abuse and Procedure for Reporting Concerns

If a young person tells a member of staff about possible abuse:

· Listen carefully and stay calm.

· Do not interview the young person, but question normally and without pressure, to be sure that you understand what the child is telling you.

· Do not put words into the young person’s mouth.

· Reassure the young person that by telling you, they have done the right thing.

· Inform the young person that you must pass the information on, but that only those that need to know about it will be told. Inform them of to whom you will report the matter.

· Make a detailed note of the date, time, place, what the young person said, did and your questions by completing the incident report form.

Staff should not investigate concerns or allegations themselves but should report them immediately to the Designated Person. The designated person will request an incident report form is completed. These forms are located in Head Office or alternatively can be emailed.

Incidents are logged on a password protected spreadsheet. Only Safeguarding and Welfare Officers have access to this spreadsheet.

If the learner is a learner of one of our funding providers –GBMET/Skills Training UK we should inform them immediately via their safeguarding officer and follow their procedures.

MET College has the following document for reference “safeguarding young people and vulnerable adults at MET College”. MET College Safeguarding staff poster are also displayed in all classrooms alongside FSUK posters.

FSUK designated Safeguarding Officer/s will then conduct an investigation and, if necessary, consult the relevant agency. Agencies are listed at the end of this policy.

At the point of referral to an external agency or closing the incident off the spreadsheet is updated and a date of sign off agreed. Any evidence from the incident is kept in a secured file.

D Reporting and Dealing with Allegations of Abuse against Members of Staff

The procedures apply to all staff, whether teaching, administrative, management or support, as well as to volunteers.

1 Introduction

1.1 In rare instances, staff of education institutions has been found responsible for child abuse. Because of their frequent contact with young people, staff may have allegations of child abuse made against them. FSUK recognises that an allegation of child abuse made against a member of staff may be made for a variety of reasons and that the facts of the allegation may or may not be true. It is imperative that those dealing with an allegation maintain an open mind and that investigations are thorough and not subject to delay.

1.2 FSUK recognises that the Children Act 1989 states that the welfare of the child is the paramount concern. It is also recognized that hasty or ill-informed decisions about a member of staff can irreparably damage an individual’s reputation, confidence and career. Therefore, those dealing with such allegations within FSUK will do so with sensitivity and will act in a careful, measured way.

If staff have safeguarding concerns, or an allegation is made about another member of staff (including volunteers) posing a risk of harm to children, then: 

• this should be referred to the management or MD; • where there are concerns/allegations about those people, then Brighton Swimming Centre management should be notified.

2 Receiving an Allegation from a Child

2.1 A member of staff who receives an allegation about another member of staff from a young person should follow the guidelines for dealing with disclosure

2.2 The allegation should be reported immediately to the Managing Director, unless the MD is the person against whom the allegation is made, in which case the report should be made to the Manager of FSUK. Allegations against staff must be referred to LADO (Local Authority Designated Officer).

2.2.1 Obtain written details of the allegation from the person who received it, that are signed and dated. The written details should be countersigned and dated by the MD (or designated person).

2.2.2 Record information about times, dates, locations and names of potential witnesses.

3 Initial Assessment by The MD (or designated person)

3.1 The MD (or designated person) should make an initial assessment of the allegation. Where the allegation is either a potential criminal act or indicates that the child has suffered, is suffering or is likely to suffer significant harm, the matter should be reported immediately to the appropriate authority.

3.2 It is important that the MD (or designated person) does not investigate the allegation. The initial assessment should be based on the information received and is a decision whether or not the allegation warrants further investigation.

3.3 Other potential outcomes are:

3.3.1 The allegation represents inappropriate behavior or poor practice by the member of staff and is neither potentially a crime nor a cause of significant harm to the young person. The matter should be addressed in accordance with FSUK disciplinary procedures.

3.3.2 The allegation can be shown to be false because the facts alleged could not possibly be true.

4 Enquiries and Investigations

4.1 Child protection enquiries by social services or the police are not to be confused with internal, disciplinary enquiries by FSUK. FSUK may be able to use the outcome of external agency enquiries as part of its own procedures. The child protection agencies, including the police, have no power to direct FSUK to act in a particular way; however, FSUK should assist the agencies with their enquiries.

4.2 FSUK shall hold in abeyance its own internal enquiries while the formal police or social services investigations proceed; to do otherwise may prejudice the investigation. Any internal enquiries shall conform to the existing staff disciplinary procedures.

4.3 If there is an investigation by an external agency, for example the police, the MD or designated person should normally be involved in, and contribute to, the inter-agency strategy discussions. The MD (or designated person) is responsible for ensuring that FSUK gives every assistance with the agency’s enquiries. He/she will ensure that appropriate confidentiality is maintained in connection with the enquiries, in the interests of the member of staff about whom the allegation is made.

4.4 Subject to objections from the police or other investigating agency, the MD (or designated person) shall:

4.4.1 Inform the young person or parent/carer making the allegation that the investigation is taking place and what the likely process will involve.

4.4.2 Ensure that the parents/carers of the young person making the allegation have been informed that the allegation has been made and what the likely process will involve.

4.4.3 Inform the member of staff against whom the allegation was made of the fact that the investigation is taking place and what the likely process will involve.

4.5 The MD (or designated person) shall keep a written record of the action taken in connection with the allegation.

5 Suspension of Staff

5.1 Suspension should not be automatic. In respect of staff other than the principal, suspension can only be carried out by the MD.

5.2 Suspension may be considered at any stage of the investigation. It is a neutral, not a disciplinary, act and shall be on full pay. Consideration should be given to alternatives: e.g. paid leave of absence; agreement to refrain from attending work; change of, or withdrawal from, specified duties.

5.3 Suspension should only occur for a good reason. For example:

5.3.1 Where a young person is at risk.

5.3.2 Where the allegations are potentially sufficiently serious to justify dismissal on the grounds of gross misconduct.

5.3.3 Where necessary for the good and efficient conduct of the investigation.

5.4 If suspension is being considered, the member of staff should be encouraged to seek advice, for example from a trade union.

5.5 Prior to making the decision to suspend, the MD should interview the member of staff.

5.6 During the interview, the member of staff should be given as much information as possible, the reasons for any proposed suspension, provided that doing so would not interfere with the investigation into the allegation. The interview is not intended to establish the member of staff’s innocence or guilt, but given the opportunity for the member of staff to make representations about possible suspension. The member of staff should be given the opportunity to consider any information given to him/her at the meeting and prepare a response, although that adjournment may be brief.

5.8 If the MD considers that suspension is necessary, the member of staff shall be informed that he/she is suspended from duty. Written confirmation of the suspension, with reasons, shall be dispatched as soon as possible and ideally within one working day.

5.9 Where a member of staff is suspended, the MD should address the following issues:

5.9.4 The parents/carers of the young person making the allegation should be informed of the suspension. They should be asked to treat the information as confidential. Consideration should be given to informing the child making the allegation of the suspension

5.12 The suspension should remain under review in accordance with FSUK disciplinary procedures.