Purpose: 

The purpose of this statement is to inform everyone connected with BCE of our position with respect to the safeguarding of learners and the Prevent Duty.

Learners includes anyone we’re training and supporting through our programmes including apprentices and adult learners. However, it can include a learner who has not yet started their programme with us, but we are aware of. BCE believe that it is always unacceptable for a learner to experience abuse of any kind and recognises its responsibility to safeguard the welfare of all learners by commitment to practice that protects them, looks to minimise potential harm and keep them safe.

All staff have access to this policy through internal communication tools and are made aware of the policy, how it can be accessed and what it means to them and their role both at initial employment then throughout the year through training (see below for more details).

BCE recognise that:

• The safety and wellbeing of learners is paramount.
• All learners, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm, abuse and radicalisation.
• Working in partnership with learners and with other agencies is essential in promoting a safe environment and the Prevent Duty.

The purpose of the policy and its supporting documents will be to:

• Provide protection for the learners and customers on BCE programmes regarding safeguarding and the Prevent Duty.
• Provide employees with guidance on procedures they should adopt in the event that they suspect a learner may be experiencing, or be at risk of, harm, abuse or radicalisation.
• Ensure all services and staff operate within the required legal framework that surrounds Safeguarding and Prevent including the Prevent Duty Guidance.

The policy applies to all employees, including senior managers and the board, paid employees, volunteers, learners, or anyone representing BCE.

We will seek to safeguard all learners by:

• Valuing them, listening to them, and respecting them
• Effective reporting and recording systems.
• Adopting safeguarding recommendations
• Sharing information about concerns with appropriate authorities, and involving learners and their parents or carers appropriately
• Safer recruitment practices
• Offering welfare support services via links to support in the persons local area • Applying industry best practice
• Having an appropriately trained and skilled Designated Safeguarding Lead and Officer
• Implementing robust IT use and support policies including e-safety measures
• Sharing and promoting our Safeguarding and Prevent Policy to learners including through appropriate induction training to each of our programmes

We are committed to reviewing our policy and practice annually with updates and reviews as and when required in-between this, should legislation and or best practice change during the year,

BACKGROUND AND GENERAL PRINCIPLES

BCE is committed to safeguarding and promoting the wellbeing of learners and expects all learners and employees to share this commitment.

This policy outlines how BCE will meet this commitment and the legal requirements to fulfil its duties. We expect our Delivery Partners to comply with relevant legislation and best practice relating to Safeguarding and Prevent Duty, including protecting learners from radicalising influences.

This Policy supports BCE’s role in safeguarding and Prevent Duty. It states how the organisation will work in conjunction with other agencies to recognise and manage suspicions, allegations and findings of abuse or radicalisation of adults and children at risk which may occur on BCE premises or in their workplace.

WHAT IS SAFEGUARDING?

Safeguarding is intended to keep children and adults at risk safe from a range of potential harm and looks at preventative action, not just reaction. BCE are committed to displaying, promoting and delivering the safeguarding message with its learners and all employers and Delivery Partners. This means promoting the welfare of children and adults and having policies and procedures in place which define how we will seek to protect our learners. Safeguarding defines how we will respond.

Child and Adult at Risk Protection

• Protection from maltreatment (abuse, neglect, exploitation, radicalisation or victimization etc.) where the perpetrator is a member of the wider community, another learner or an employee. Wellbeing support needs
• Preventing the impairment of health and development and the promotion of support for individual needs.
• Enabling young people to have optimum life chances and enter adulthood successfully.
• Helping learners to access the help they need to enable them to achieve their full potential.
• Providing support and guidance linked to mental health issues and risks. This is often via links to the support in their local area.

Who are we safeguarding?

BCE’s safeguarding arrangements are to protect all our learners, employees, and stakeholders:

• ‘Child’ means anyone under the age of 18
• ‘Young person’ means anyone aged 14 to 17
• An adult at risk means a person, aged 18 or over, living in certain situations, detained in custody, supervised in the community or receiving specific services.

BCE are mindful that several other situations may render a person ‘vulnerable’ such as – victims of domestic abuse, migrants, living in a drug-misusing family, living in areas of high crime, being likely to face racism or having caring responsibilities.

What are we safeguarding from?

This is not an exhaustive list and there may be other situations and circumstances that arise.

• Radicalisation and/or extremist behaviour
• Local area or population issues such as gang activity
• Sexual abuse or inappropriate relationships
• Physical and emotional abuse or neglect
• Exploitation including county lines, forced marriage, financial exploitation, child sexual exploitation and up-skirting.
• Child on Child or Peer on peer* abuse, such as sexual harassment (see separate section about this)

*Following the recommendations for Keeping Children Safe in Education we have kept the ‘peer on peer’ terminology alongside the ‘child on child’ terminology

• Extremist terrorist groups or radicalisation
• Domestic abuse
• Bullying including cyber bullying, bullying in the workplace and prejudice-based bullying
• Risks linked to technology and social media, including online bullying, grooming, radicalisation, accessing and generating inappropriate content for example, sexting and revenge porn
• Drug and alcohol misuse
• Racist, disability and homophobic or transphobic abuse
• Gender based violence.
• Modern Slavery
• Accidents (road, home, in the workplace)
• Self-harm
• Suicide and mental health matters
• Fabricated or induced illness
• Unsafe activities and environments including those online or cyber environments.
• Crime
• Honour based violence.
• Unsuitable housing/homelessness
• Female Genital Mutilation
• Breast Ironing

WHAT IS THE PREVENT DUTY?

In 2015 the government published the Prevent Duty guidance as part of their overall counter terrorism strategy.

As a result, BCE recognises their responsibility to have a “due regard to the need to prevent people from being drawn into terrorism” (Counter Terrorism and Security Act 2015) focussing on the 3 key objectives.

• Prevent people from being drawn into terrorism and ensure they are given the appropriate advice and support.
• Respond to the ideological challenge of terrorism and the threat we face from those who promote it
• Work with sectors and institutions where there is a risk of radicalisation we need to address.

The aim of the Prevent Duty is to reduce the threat of terrorism in the UK by stopping people becoming terrorists or supporting it and focuses on the need to prevent people from being drawn into terrorism. BCE understands it has a legal responsibility to fulfil the Prevent Duty Statement.

WHO IS RESPONSIBLE FOR SAFEGUARDING?

The Working Together to Safeguard Children Guidance 2020 states that ‘Whilst it is parents and carers who have primary care for their children, local authorities, working with partner organisations and agencies, have specific duties to safeguard and promote the welfare of all children in their area. The Director of Children’s Services and Lead Member for Children’s Services in local authorities are the key points of professional and political accountability, with responsibility for the effective delivery of these functions.’

In light of this, BCE are committed to supporting all employees to understand the requirements placed upon them by this act. This is done through a variety of ways including information, advice and guidance, mandatory training and support resources.

The Board accepts overall responsibility for Safeguarding and Prevent Duty and as a result is committed to reviewing the BCE policy and practices annually.

The Director with overall responsibility for Safeguarding is Alison Webber Managing Director.

Any concerns about poor practice by the Designated Safeguarding Lead (DSL), or deputy should be referred to the Managing Director.

The Safeguarding and Prevent Policy is actively and positively promoted to all staff, always ensuring commitment from all by:

• Having a clear and accessible policy in place that staff are aware of
• A Designated Safeguarding Lead (DSL) and deputy
• Awareness raising activities by DSL and Deputy including ‘knowing who to contact’ and attending team meetings to promote the effective implementation of the policy
• By having a specific email address to support and aid reporting of safeguarding concerns
• Hot topics of key issues for all learners
• Trend analysis and reporting with monthly updates to the Board.
• Mandatory training for all staff that is renewed annually to keep them up to date and aware of the current risks related to Safeguarding and prevent, how to implement the policy and how to protect learners and employees.

As per statutory guidance within Keeping Children Safe in Education which is updated annually in September, all Senior Leaders, board members and those with responsibility for governance have read in full, understand and follow the legislation.

In addition to this, all employees who come in to contact with learners have read and understood part 1. Evidence of this is stored by the DSL.

CHILD AND ADULT AT RISK PROTECTION

The Designated Safeguarding Lead (DSL) is the ‘Designated Person’ with lead responsibility for safeguarding all learners. The DSL is also supported by a Deputy, both are trained as Designated Safeguarding Leads and have completed training on the Prevent Duty through the Education Training Foundation. Where it is suspected that a learner is experiencing abuse, experiencing mental health concerns, being drawn into radicalisation or has any other wellbeing issue, this should be immediately reported via the dedicated email address, the DSL will triage. BCE is committed to protecting its learners from abuse and continuously improves its systems, processes and policies to reflect this. The DSL also provides generic safeguarding advice and support to other employees and delivery partners and consults with external agencies, including Safeguarding Children Partnerships, Government Prevent coordinators, Safeguarding Adults Partnerships, the Care Quality Commission, Ofsted and the Police.

Training for employees

BCE are committed to preparing its employees on how to recognise abuse or the signs of radicalisation ensuring effective implementation of the policy. All employees are required to undertake a mandatory safeguarding and Prevent Duty training programme this will be delivered during induction to new employees regardless of job role.

It is expected that employees will undertake refresher training every year enabling an up-to date knowledge and awareness of Safeguarding and Prevent Duty as well as how to effectively implement this policy.

Further to mandatory training the DSL is available to offer generic and specific information, advice and guidance to employees around safeguarding and wellbeing matters either by phone or by email.

Safer Recruitment of Employees

In line with Keeping Children Safe in Education September 2023, BCE are committed to safe recruitment for all positions across the business and practices safer recruitment activities throughout the recruitment processes.

It is a criminal offence for barred individuals to work with children or adults at risk in regulated activity and BCE are committed to seeking the relevant DBS check when recruiting to such roles.

The Directors expect all staff to know procedures and implement them as part of their day-to-day work.

At induction all new staff must read all BCE’s policies and sign to confirm that they are read and understood. 

All staff working at BCE are required: –  

• To show proof of identification.
• To complete an enhanced DBS check* – this includes volunteers.
• Each person working at BCE will have a named direct line manager who is fully conversant with the standards of behaviour, expectations, and procedures of the company.

*in exceptional circumstances BCE may commence a Staffs employment prior to receipt of a current DBS. On these occasions a risk assessment will be completed. Risk assessments will only be used as a short term measure and whilst a risk assessment is in place the staff member will have restricted duties.

BCE will update DBS checks every 3 years. DBS check information must be uploaded to Breathe HR and a reminder set for the renewal.

The Directors will be responsible for ensuring the renewal is completed.  

The DSL will be ultimately responsible and will maintain oversight of the DBS renewals and annual updates through a single register, which includes: 

• Employment start date
• Employment status (Contracted/Employed)
• Level and date of DBS check
• DBS certificate number
• Safer recruitment process completed and signed off by DSL or DSO
• Last date of safeguarding training
• Last date of PREVENT training.
• Date of Keeping Children Safe acknowledgement of reading

For staff who have lived overseas the following guidance in this link must be followed: https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants 

Recruitment procedures will include: 
 

• Short listing. 

• Interview using fair processes. 

• Employment history. 

• Evidence of qualifications where relevant. 

• Enhanced DBS checks. 

• Online search

As part of the interview process the interview panel will need to: –

• Implement the interview process with fair techniques and safeguarding procedures. 

• Test candidates’ suitability against the post requirements.
• Satisfy themselves that there are no unexplained employment gaps.
• Assess the credibility of references. 


It is recognised that to enable employees to meet their safeguarding and Prevent responsibilities they may, at times themselves, require additional support.

BCE operate an open-door policy and whilst the first port of call is always the line manager. Employees may wish to seek additional personal support from Senior Managers and Directors.

Specific advice on safeguarding and wellbeing issues can be sought from the Designated Safeguarding Lead.

INFORMATION AND SUPPORT FOR LEARNERS

All learners will receive Safeguarding and Prevent Duty information during their induction and initial meeting, including information within the learner handbook. BCE explains how to raise, record, monitor and track investigations or concerns. Their BCE main contact has the responsibility to ensure that they understand how safeguarding, and confidentiality operates within BCE as a part of the induction process.

All learners and apprentices will receive safeguarding training embedded into their delivery programme- highlighting the importance of raising any concerns,

Learners and apprentices are provided with key contact information for the DSL and safeguarding reporting line during their induction and this is revisited throughout their programmes. If concerns are raised in the workplace, the assessor is informed, and safeguarding reporting procedure is followed.

Delivery staff provide learners and apprentices regular updates and training, including sources of support in relation to Hot topics. This is provided through delivery, update communications and newsletters and E-portfolio resource sharing (see Appendix 2)

When raising a concern learners can expect that they will be treated sensitively and with dignity should a safeguarding incident or concern occur. BCE requires its employees to treat such matters confidentially, notifying colleagues only on a ‘need to know’ basis.

Sharing of Information

BCE work to the following Confidentiality Statement with our learners; “It is important that you feel safe and confident to discuss any issues that you may have with a member of the BCE team. For this reason, any information that you share will not be discussed outside of the employees who can directly help and support you, unless you tell us that either you or others are at risk of harm. In such cases we may have to share this information with external agencies such as Safeguarding Children and Adults Partnerships, the Care Quality Commission, Ofsted or the Police. This will only be passed on with your knowledge.

REACTING TO SAFEGUARDING OR PREVENT DISCLOSURE OR INCIDENTS BCE have adopted the 5R’s (Appendix 1)

• Recognition
• Response
• Reporting
• Recording
• Referral

Any concerns, incidents or disclosures raised by learners or employees should follow these principles and in the first instance immediately be reported to the DSL, using the dedicated email address.

Accusations of abuse

Should an accusation of abuse be aimed at a BCE employee by a learner, this must be reported to the Managing Director, and the DSL. They will decide whether the individual will be suspended pending further enquiry.

An investigation may need to be led by the managing Director and DSL and any findings may need to be given to the relevant authorities, such as the police or Safeguarding children and adults partnerships.

In certain cases, the Disclosure & Barring Service may need to be informed, if an employee is found by the relevant authority to have committed a criminal offence. The DBS would make the decision as to whether the employee should be barred from working with children or adults at risk. Full cooperation will be given by us to any of the aforementioned authorities.

Disclosures

Learners may not feel able to disclose to anyone about what is happening to them for a number of reasons – threats, fear of punishment, guilt, shame, thinking that they will not be listened to or believed and an inability to communicate.

The behaviour and attitude of our employees should be non-judgmental and one of vigilance, openness and confidentiality (within the bounds of child protection law), in order to create a culture consistent with safeguarding practices. Disclosures may also be via the dedicated email address to enable support and guidance to be provided where required.  BCE expects employees to be mindful of the support available to learners and seeks to encourage learners to access this at appropriate times throughout their time with us.

Employees will actively avoid making safeguarding a ‘tick box exercise’.

Risk Assessments

BCE recognise that it is necessary to undertake safeguarding risk assessments and that safeguarding should be considered alongside other standard assessment of risk processes.

At times it will be appropriate to risk assess individual or specific groups of learners. Such circumstances should be advised to the Designated Safeguarding Lead, in advance of the learner commencing, for a risk assessment to be undertaken, mitigations to be agreed, and where necessary, actioned.

INVOLVING EXTERNAL AGENCIES

Referral -The DSL or their Deputy are responsible for referral of incidents or allegations of abuse to Safeguarding Children and Adults Partnerships, the Care Quality Commission, Ofsted, the Disclosure & Barring Service and sometimes the police or in cases of radicalisation to the Channel Programme as appropriate.

The above-mentioned services have the lead role in coordinating the multi-agency approach to safeguard adults and children at risk and may ask for attendance by employees of BCE to POT (Position of Trust) /strategy meetings or for written evidence of incidents.

Reporting to the Police-

BCE will report all incidents involving drugs to the police and seek their advice and possible involvement. The police will always be involved in the disposal of suspected illegal drugs.

BCE will refer to the police incidents of the following type: • assault (whether physical or psychological) • sexual assault and rape • grooming • theft, fraud, or other forms of financial exploitation • certain forms of discrimination, whether on racial or gender grounds

Whether to involve the Police will be a matter for the DSL and Managing Director or, in urgent situations, another member of the Board, if necessary, in consultation with the BCE’s legal representatives

Recording of incidents

All incidents should be fully and accurately recorded as any notes may be used in subsequent court proceedings. Incidents should be recorded and stores where only approved employees can access it.

BEHAVIOURS

Social Media –

BCE recognise that there are notable benefits to using social media as communication and promotional tools as well as potential negative effects in terms of reputation and safeguarding. In order to use social media in a safe and professional way, Social Media guidance will be provided to employees via the Social Media policy. This will provide guidance on how BCE expect them to operate when using social media. Owing to the Safeguarding implications surrounding the misuse of social media formats any activities undertaken outside the boundaries of the guidance will be dealt with as a disciplinary matter.

Weapons and violent behaviour

BCE recognises that there is a possibility that employees, learners, clients or visitors may come into contact with violent or aggressive behaviour and that this contact may lead to personal harm. In such an instance, it is the policy of BCE to support victims and deal with these situations and any consequences with sensitivity and compassion. Occurrences of violent or aggressive behaviour must be reported immediately to the most senior person on site so that the appropriate action can be taken. All incidents will be investigated and treated with the utmost seriousness and may lead to disciplinary action or the involvement of the police.

Safe IT usage

The internet and other digital and information technologies are powerful tools, which open up new opportunities for everyone.  These technologies can stimulate discussion, promote creativity and increase awareness of context to promote effective learning.  Internet use is embedded in the curriculum and is a necessary tool for both learners and staff.   

The use of these exciting and innovative tools in the learning environment and at home has been shown to raise educational standards and promote learner achievement.  However, the use of these new technologies can put learners at risk within and outside the learning environment. 

Some of the dangers they may face include: – 

• Access to illegal, harmful or inappropriate images or other content.
• Unauthorised access to / loss of / sharing of personal information.
• The risk of being subject to grooming by those with whom they make contact on the internet.
• The sharing / distribution of personal images without an individual’s consent or knowledge.
• Inappropriate communication / contact with others, including strangers.
• Cyber-bullying.
• Access to unsuitable video / internet games.
• An inability to evaluate the quality, accuracy and relevance of information on the internet.
• Plagiarism and copyright infringement.
• Illegal downloading of music or video files.
• The potential for excessive use which may impact on the social and emotional development and learning of the young person.

Many of these risks reflect situations in the off-line world and it is essential that this and our E-Safety Policy is used in conjunction with other policies. 

The policy applies to all members of the BCE community (including staff, learners, volunteers, parents/carers, visitors) who have access to and are users of BCE ICT systems, both in and out of BCE buildings 

Learners will be taught about effective use of the internet in research, including the skills of knowledge location, retrieval and evaluation. Learners must not reveal personal details of themselves or others in e-mail communications. 

Employers employing apprentices will be given a copy of our E-safety Policy which they must adhere to unless BCE review their own policy as satisfactory. 

Radicalisation, Extremism & the Prevent Duty

In respect of safeguarding individuals from radicalisation, BCE works to the Prevent Duty element of the Government’s Counter Terrorism Strategy, and where deemed appropriate seeks external support for learners through referrals to the Channel Programme. This programme aims to work with the individual to address their specific vulnerabilities, prevent them becoming further radicalised and possibly entering the criminal justice system because of their actions.

BCE follows all statutory legislative requirements and guidance with regards to the Prevent Duty and ensures all staff have appropriate training and support to be able to protect learners and employees from radicalising influences, ensure learners and employees are resilient to extreme narratives and know how to identify changes in behaviour of learners and employees. It is recognised that radicalisation can occur to an individual from any section of society and is not particular to any racial, ethnic or social group. It is further recognised that in many instances the process of radicalisation is essentially one of grooming by others. Possible signs of radicalisation include an individual:

• becoming increasingly extreme regarding another section of society or government policy
• becoming increasingly intolerant of more moderate views
• expressing a desire/intent to take part in or support extremist activity.
• being observed downloading, viewing or sharing extremist propaganda from the web
• they become withdrawn and focused on one ideology.
• changing their appearance, their health may suffer (including mental ill health) • becoming isolated from family, friends, peers or social groups

The Department for Education have provided Government Prevent Coordinators who operate nationally. The DSL and Deputy are able to contact them for guidance and support if concerns are raised regarding radicalisation and extremism.

A list of the Government coordinators can be found in the Safeguarding folder.

As part of mandatory training, all employees, regardless of role, undertake Government Home Office Prevent training and will refresh this every year in line with guidance.

Safeguarding Deputies must complete Prevent Duty training with the Education Training Foundation

Local Prevent Duty Risk Assessments

To assess the risks across every area where we are working in the UK. The DSL and deputy have links with every Government Prevent Coordinator in each region. This means we have awareness of local risks across each region as we receive regular updates from them directly about risks relating to radicalisation and extremism.

The team also attend the regional Prevent meetings.

Local risk assessments are discussed, and input is gained around risks relating to radicalisation, extremism and welfare or lone working issues they are aware of, and this is fed back to the DSL who then escalates to the BCE employees, learners and delivery partners working in this area.

Making a Channel Referral

When the Safeguarding team are made aware of an issue relating to radicalisation and extremism, they contact the Government Prevent Coordinator in the region where the person lives. They will advise us on the local authority department to contact. Following this contact we are linked to the Special Branch department who is dealing with it. Referrals may be made to the Channel Programme at the relevant local authority or police. This is a confidential, multi- agency safeguarding programme that supports people who are vulnerable to radicalisation.

The programme is about early intervention to protect vulnerable children and adults who might be susceptible to being radicalised, which left unsupported could lead to terrorist related activity.

Removal from programme

For learners, in general this should be seen as a final step only after all other strategies have been applied, or the offence is very serious, such as supplying an illegal drug. If it is a learner who is employed such as an Apprentice, this will be discussed with their employer. If a learner working in our care sectors is found to be guilty of abuse following investigation by the relevant authorities, we would remove them from programme.

GOVERNANCE

BCE board has the overall and final responsibility for this Policy, supported by the Managing Director and DSL who will control the coordination, implementation and monitoring of the Policy throughout the Company. This Policy will be reviewed at least annually by the Managing Director and DSL and approved by the board. The DSL will actively assess any improvements that can be made and propose these changes to the Managing Director.

At the board’s sole discretion, any updates or additional processes may be implemented; these updates or additional processes will be incorporated into this Policy in the annual review period. Updates will be cascaded throughout the Company.

Policy Owner	Kerry Dunnett
Last reviewed	19/10/23
Next review due	18/10/24

Appendix 1 –

The Five R’s

Handling a disclosure from a person under the age of 18.

Recognition

• Recognition covers both disclosures of abuse and your personal concerns
• Disclosure of abuse is likely to be direct.
• A concern that you have may arise from either a conversation or a change in a learner’s behaviour

Response

• Is the learner reporting a concern or a suspicion? Is this a disclosure from an individual alleging abuse to themselves or to another? Find out whether you are dealing with an allegation against a member of staff, a fellow learner, or another person. What, precisely, is alleged to have happened? Detailed clarity is vital. • Remain calm and listen.
• Do not ask leading questions, probe with questions or make judgements about the person or situation
• Inform the person that the concerns must be recorded and passed on to your DSL so that the issue can be dealt with (normal rules for confidentiality do not apply when a child or young person is at risk of harm).

Reassure

Reassure the person that they have done the right thing in telling you and that you will do everything you possibly can to help.

• Do not make unrealistic promises.

Reporting

• If it is a clear case or disclosure of abuse this must be reported via the designated email address
• DO NOT DISCLOSE THIS WITH ANYONE ELSE
• Report any concerns as soon as practicably possible, but before the end of the working day.

Recording

• record precisely what has been alleged/happened – use the exact words of the learner. Your record should use accurate quotation.
• If appropriate, include factual observations.
• Once you have reported concerns using this process it is the DSL’s responsibility to take any further decisions as to the actions which would follow. This may or may not directly involve you.

Referral

• Only the DSL, Deputy or Managing Director can make the decision to refer a complaint or allegation having gathered and examined all relevant information
• Only the DSL or deputy should look into a complaint, allegation or suspicion of abuse. Actions carried out by others could be construed as unjustified interference which could jeopardise an investigation and any possible subsequent court case.
• No BCE employee is in a position to decide whether abuse has taken place

Appendix 2 –

Hot Topics and Newsletters

We changed the way we cover the Hot Topics which are to be used with our learners by our learner facing employees. We have a bank of Hot Topics stored in the Assessor file on the shared Drive, so that learners or assessors can choose one that is relevant or suitable for their learners. Learners then write a learner journal entry about what they learned, what they liked or didn’t like and how they have used the information in there in their own life or their workplace.

Safeguarding & Wellbeing monthly newsletters

We introduced bi-monthly newsletters in November 2023 written by the DSL or deputy. These are emailed to the learners and also discussed between learner and learner facing staff.