OUR POLICIES

POLICIES

Adaptive Provision Limited

Policies & Procedures Handbook

Therapeutic Alternative Provision & School Reintegration Programmes

Director: Nichola Brown

management@adaptiveprovisionlimited.org | 07950 196977

Delivery site: Kings Rise Academy community hub, Birmingham

Re intergration programmes delivered into individual schools

Published: September 2026

These policies are published for parents, carers, commissioning schools, local authorities and Ofsted. They

reflect current statutory guidance including Keeping Children Safe in Education, Working Together to Safeguard

Children, the UK GDPR/Data Protection Act 2018, the Equality Act 2010, and the DfE guidance on alternative

provision. They are reviewed annually or sooner if guidance changes.Contents

1. Safeguarding & Child Protection Policy

2. Behaviour Management Policy

3. Health & Safety Policy

4. First Aid & Medication Policy

5. Attendance, Missing Child & Collection Policy

6. SEND & Additional Needs Policy

7. Equality, Diversity & Inclusion Policy

8. Anti-Bullying Policy

9. Complaints Policy

10. Data Protection & Privacy Policy

11. Online Safety & Acceptable Use Policy

12. Safer Recruitment & Staff Code of Conduct

13. Whistleblowing Policy

14. Photography, Filming & Consent Policy

15. Accessibility Plan

16. Exclusion Policy

17. Educational Visits & Off-Site Activities Policy

18. Intimate Care Policy

19. Curriculum, Assessment & Reporting Policy

20. Relationships & Health Education (PSHE) Policy

21. Staff Appraisal, Supervision & CPD Policy

22. Volunteers & Visitors Policy

23. CCTV & Site Security Policy

24. Records Management & Retention Policy

25. Home-Provision Partnership Agreement

26. Looked After & Previously Looked After Children Policy1. Safeguarding & Child Protection Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited is committed to safeguarding and promoting the welfare of every child

who attends our programmes. Safeguarding is everyone's responsibility, and this commitment sits

above every other consideration in how we plan, staff and run our sessions. This policy is written

with regard to Keeping Children Safe in Education (KCSIE), Working Together to Safeguard Children,

the Children Act 1989 and 2004, and the Prevent Duty (Counter-Terrorism and Security Act 2015),

and applies alongside - and does not replace - the safeguarding policy of any commissioning school.

Where our procedures differ from a school's own, the more stringent standard applies.

Purpose and scope

This policy applies to every child attending our reintegration or therapeutic provision, to every

member of staff, sessional practitioner, volunteer and visitor, and to every location in which

Adaptive Provision Limited delivers a session, including Kings Rise Academy, Birmingham and any

community or outreach setting. It covers physical abuse, emotional abuse, sexual abuse, neglect,

child sexual exploitation, criminal exploitation and county lines, radicalisation, online harm, domestic

abuse witnessed by a child, female genital mutilation, forced marriage, and peer-on-peer abuse.

Designated Safeguarding Lead (DSL) and governance

Nichola Brown is the Designated Safeguarding Lead for all sessions and holds overall accountability

for safeguarding practice, training and record-keeping. A trained Deputy DSL is identified for every

session and is always on site whenever the Director is not present; no session runs without a DSL or

Deputy DSL in the building. Contact details for the DSL and Deputy are displayed prominently at the

venue, included in the induction pack given to every commissioning school, and shared with

parents/carers before a placement begins. The DSL undertakes safeguarding training at least every

two years and Prevent awareness training annually, in line with KCSIE requirements for the role.

Prevention

● A safe, warm and predictable environment is created in every session, recognising that

consistency and relationship reduce vulnerability.

● Children are given age-appropriate opportunities, through our therapeutic curriculum, to

talk about worries, family life and online experiences in a way that surfaces concerns

naturally.

● Staff are trained to recognise the specific vulnerabilities of children attending alternative

provision, including higher risk of exploitation, missing episodes, and mental health need.

● Site security at the venue (signing in/out, visitor badges, supervised access) reduces the risk

of unauthorised contact with children.

Procedure for a disclosure or concern

● The member of staff receiving a disclosure listens carefully, does not promise confidentiality,

asks only open, non-leading questions, and does not investigate.

● Details are recorded in the child's own words, using the body-map/incident form, as soon as

possible and always within the same session day.

● The record is passed to the DSL (or Deputy) immediately, and in any event within 24 hours.

● The DSL decides, using professional judgement and the local authority threshold document,

whether the concern requires an early-help response, a referral to Children's Social Care, or

immediate contact with the police.● Referrals meeting the threshold are made without delay and always within 24 hours of the

concern being raised, using the local authority's MASH/front-door referral route.

● The referring school's designated safeguarding lead is informed at the same time, unless

doing so would place the child at greater risk (for example, where the school itself is

implicated).

● Every referral and its outcome is logged on the child's confidential safeguarding file, held

securely and separately from general session records.

Allegations against staff and low-level concerns

Any allegation or concern about the conduct of a member of staff, sessional practitioner or

volunteer towards a child is reported immediately to the DSL (or, if the allegation concerns the DSL,

to the Local Authority Designated Officer directly) and handled in line with KCSIE Part 4. Low-level

concerns that do not meet the harm threshold - for example, a lapse in professional boundaries - are

still recorded on a confidential low-level concerns log, reviewed by the DSL termly to spot patterns,

and considered as part of that individual's ongoing suitability to work with children.

Information sharing

Relevant safeguarding information is shared with each child's referring school under a written

information-sharing agreement, both at referral (so we understand existing concerns and plans) and

throughout the placement (so the school is kept informed of anything arising). Information is shared

on a need-to-know basis, in line with the principle that safeguarding overrides confidentiality where

a child is at risk of harm.

Training

All staff complete safeguarding training, including Prevent duty awareness, safer recruitment

awareness, and an introduction to the specific risks faced by children in alternative provision, as part

of induction before working unsupervised with children, and refresh this training at least annually.

Records of training completed by each member of staff are held on the single central record.

Monitoring and review

This policy, and our safeguarding practice against it, is reviewed by the DSL at least annually, after

any safeguarding incident, and whenever statutory guidance changes. A summary of safeguarding

activity (anonymised) is shared with commissioning schools termly as part of our quality assurance

to them.2. Behaviour Management Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Our approach is trauma-informed and therapeutic: behaviour is treated as communication of an

unmet need rather than wilful misconduct, and support focuses on regulation, understanding and

relationship-building rather than punitive sanction. This reflects both best practice for children who

have already experienced difficulty in mainstream settings, and the clinical input of our

psychotherapist and CAMHS practitioner. This policy is shared with every commissioning school and

parent/carer before a placement begins, and is written with regard to the DfE guidance 'Behaviour in

Schools' and 'Use of Reasonable Force'.

Underlying principles

● Every child's behaviour is understood in the context of their history, and staff are trained to

look beneath a behaviour for the feeling or need driving it.

● Relationships come before rules: children build trust with a small, consistent staff team

across their placement, which is itself a protective and regulating factor.

● Boundaries are clear, fair, and explained rather than imposed, so children understand the

reasoning behind expectations.

● Success is celebrated visibly and often; our approach is weighted heavily towards positive

reinforcement rather than sanction.

Graduated response

● Stage 1 - Co-regulation: staff use calm tone, proximity, distraction, choice and sensory

strategies to support a child to self-regulate before behaviour escalates.

● Stage 2 - Structured de-escalation: a trained practitioner steps in one-to-one, using a

scripted de-escalation approach, and the child is offered a quiet, safe space to reset.

● Stage 3 - Individual review: where de-escalation strategies are not effective, the incident is

reviewed with the child once calm, and an individual regulation plan is created or updated

with input from the referring school.

● Stage 4 - Physical intervention (last resort only): used solely to prevent injury to the child,

other children, or staff, by staff trained in an accredited positive-handling technique, for the

minimum time necessary, and always recorded on an incident form and reported to

parents/carers and the home school on the same day.

Individual behaviour and regulation plans

Every child referred with a known history of dysregulated behaviour, or who displays this during

their placement, has an individual regulation plan drawn up in consultation with the referring school

and, where relevant, CAMHS. This plan identifies known triggers, early warning signs, and the

specific strategies that work for that child, and is reviewed at the mid-point and end of every 12-

week programme.

Rewards and positive reinforcement

Progress, effort and prosocial behaviour are recognised through verbal praise, a visual reward

system appropriate to the child's age, and regular positive feedback shared with parents/carers and

the referring school, so that achievements made with us are recognised and reinforced back in the

child's home school environment.

Serious or persistent concernsPersistent or serious behavioural concerns are always discussed with the referring school before any

decision is made about a child's continued placement. Adaptive Provision Limited does not

permanently exclude a child without first convening a review meeting involving the school and,

where appropriate, parents/carers, to consider what additional support might make the placement

viable. A fixed-term break from sessions is used only where there is an immediate risk to safety, and

is always time-limited and reviewed.

Recording and reporting

Every behavioural incident above Stage 1 is logged in writing on the day it occurs, including what

happened, the strategies used, and the outcome. Records are reviewed by the Director monthly to

identify patterns across the cohort and inform staff training.3. Health & Safety Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited complies with the Health and Safety at Work etc. Act 1974, the

Management of Health and Safety at Work Regulations 1999, and associated regulations. The

Director holds overall responsibility for health and safety across all delivery sites; a named member

of staff conducts and records a risk assessment before each session and reviews it in real time as the

day progresses.

Roles and responsibilities

● The Director is the appointed Health and Safety Lead, responsible for policy, risk assessment

sign-off, incident review and liaison with Kings Rise Academy, Birmingham's own site

management.

● Every member of staff is responsible for following safe working practices, reporting hazards

immediately, and taking part in fire drills and health and safety training.

● A designated first aider and fire marshal are identified for every session.

Premises and site safety

Sessions run from Kings Rise Academy, Birmingham, whose own fire, premises and evacuation

procedures are followed in full; we hold a copy of the venue's fire risk assessment and public liability

insurance certificate on file. A joint fire drill is completed with venue staff at the start of each term,

and the evacuation route and assembly point are shown to every child on their first day.

Risk assessment

● A generic risk assessment covers the venue, room layout, and standard session activities,

reviewed termly or after any incident.

● A specific risk assessment is completed for any arts-based, physical or sensory activity

involving equipment, materials or movement.

● A dynamic (in-the-moment) risk assessment is carried out continuously by staff during

sessions, particularly around behaviour, group dynamics and any child-specific vulnerability.

● Any off-site element (for example a community visit) has its own written risk assessment,

approved by the Director in advance.

Ratios, supervision and registers

Staff-to-child ratios are set according to the age and needs of the group and never fall below

statutory guidance for the activity being delivered; ratios are increased for children with higher

support needs. A signing-in/out register is kept for all children, staff and visitors on every session

day, and headcounts are taken at the start, after every transition, and at the end of each session.

Incident reporting

Accidents and near-misses are logged in an accident book on the day they occur, parents/carers are

informed the same day, and RIDDOR-reportable incidents are reported to the Health and Safety

Executive within the statutory timescale. Equipment and materials used in sessions are checked for

suitability before use and stored securely between sessions.

Monitoring and review

This policy is reviewed annually by the Director, and the accident/incident log is reviewed termly to

identify any trend requiring a change in practice or additional staff training.4. First Aid & Medication Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

This policy is written with regard to the DfE guidance 'Supporting pupils at school with medical

conditions' and sets out how Adaptive Provision Limited keeps children safe and well during

sessions.

First aid provision

● At least one paediatric first-aid trained member of staff is present at every session, and their

identity is confirmed to parents/carers and the referring school before placement begins.

● A stocked first aid kit, appropriate to the age range and activities of the session, is available

at the venue at all times and checked and restocked termly.

● First aid training is refreshed at the recommended interval (typically every three years) and

recorded on the single central record.

Medical information and medication

● Parents/carers must disclose any medical condition, allergy or medication requirement in

writing before a placement starts, using our medical information form, and this information

is shared with all staff working with that child.

● An individual healthcare plan is created for any child with a significant or ongoing medical

condition, in consultation with parents/carers and, where relevant, health professionals.

● Medication is only administered with prior written parental consent, recorded on a

medication log each time it is given, and stored securely and out of children's reach when

not in use.

● Staff administering medication receive appropriate guidance or training for that specific

medication where needed (for example an epi-pen or inhaler).

Illness, injury and emergencies

Any allergy, injury or illness during a session is recorded on an incident/accident form and

parents/carers are informed the same day. Emergency services are called immediately for any

serious incident, a member of staff accompanies the child if they are taken to hospital, and the

home school is informed as soon as possible afterwards. A child who becomes unwell during a

session is kept comfortable and supervised until collected.5. Attendance, Missing Child & Collection Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Regular attendance is fundamental to the success of our reintegration and therapeutic programmes,

and we work closely with referring schools to promote and monitor it.

Registration and monitoring

● Attendance is registered at the start of every session and shared with the referring school

daily, so that it can be reflected in the child's overall school attendance record.

● Patterns of absence are reviewed weekly by the Director; any unexplained absence is

followed up with the referring school and, where appropriate, the parent/carer, on the same

day.

● Persistent absence is discussed with the referring school as part of the child's placement

review, since it may itself be a safeguarding indicator.

Collection and release of children

Children are only released to a named parent/carer or authorised adult confirmed in writing in

advance. Photographic ID is requested if the collecting adult is not known to staff, and a child is

never released to anyone not on the authorised collection list without direct confirmation from the

parent/carer or referring school.

Missing child procedure

● Staff take a headcount at the start of the session, after every transition between activities,

and at the end of the session.

● If a child cannot be accounted for, staff immediately search the venue and grounds while

maintaining supervision of the rest of the group.

● The DSL is informed immediately, and the parent/carer and referring school are contacted

without delay.

● The police are contacted if the child is not found within a reasonable time, or immediately if

there is any reason to believe the child is at risk.

● A written record of any missing-child incident is completed on the same day and reviewed

with the referring school and, where relevant, the local authority.6. SEND & Additional Needs Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited welcomes children with additional needs, including those with an

Education, Health and Care Plan (EHCP) or SEN Support status, and works with each referring

school's SENCO to understand and meet individual needs. This policy is written with regard to the

SEND Code of Practice 2015.

Identifying and understanding need

● Relevant information (EHCP, SEN Support plan, one-page profile, and any advice from allied

health professionals) is requested from the referring school before placement begins.

● Where a child's need has not been formally identified but emerges during their placement,

this is raised with the referring school's SENCO promptly so that assessment can be

considered.

● Our psychotherapist and CAMHS practitioner contribute clinical insight into presentation

and support strategies where relevant to a child's placement.

Provision and adaptation

● Sessions and activities are adapted to be accessible, drawing on our team's occupational

health and trauma-informed practice background, including sensory adjustments, visual

supports and flexible pacing.

● Group sizes and staff ratios are adjusted where a child's needs require closer support.

● Where a child's needs cannot reasonably be met within our current staffing, expertise or

venue, this is discussed openly and promptly with the referring school before or during

placement, so that alternative support can be arranged.

Review

Progress and any change in need is reviewed with the referring school at the mid-point and end of

each programme, and contributes to any statutory annual review of an EHCP where applicable.7. Equality, Diversity & Inclusion Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited is committed to the Equality Act 2010 and does not discriminate on the

grounds of any protected characteristic, including race, disability, sex, religion or belief, sexual

orientation, gender reassignment, pregnancy or maternity. All children, families and staff are treated

with dignity and respect, and we recognise that many children referred to us have experienced

marginalisation, which informs how sensitively we approach this duty.

Our commitments

● Activities, materials, imagery and language used in sessions are reviewed to ensure they are

inclusive and free from stereotyping.

● Reasonable adjustments are made for disabled children and staff wherever practicable, and

access needs are discussed with families before placement begins.

● Recruitment, training and supervision of staff actively promote equality and challenge

discriminatory attitudes or behaviour.

● Any complaint of discrimination or harassment, from a child, family member or member of

staff, is treated seriously and investigated under our Complaints Policy or, for staff, our

grievance procedure.

● Staff receive equality and diversity training as part of induction and refresh this periodically.

Monitoring

The Director monitors referral, attendance and outcome data by relevant characteristic where

appropriate, to check that our provision is genuinely accessible and effective for every child referred

to us.8. Anti-Bullying Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Bullying of any kind - physical, verbal, emotional, relational or online - is not tolerated. Given the

therapeutic nature of our work, prevention is built into every session through relationship-building,

emotional regulation support, and explicit teaching of respectful behaviour.

Definition

We define bullying as behaviour by an individual or group, usually repeated over time, that

intentionally hurts another child or group either physically or emotionally, and recognise that

children referred to us may have experienced bullying, been involved in bullying others, or both, and

that both require sensitive support.

Prevention and response

● Children are given a clear, age-appropriate explanation of what bullying is and how to report

it at the start of a placement.

● Group composition and seating/activity groupings are planned with known relationships and

histories in mind, to reduce risk.

● Any reported or observed bullying is recorded and addressed the same day, with the child

who was bullied and the child who bullied both supported individually, in line with our

therapeutic approach.

● Parents/carers and the referring school are informed of any bullying incident and the action

taken.

● Repeated or serious bullying is escalated to the DSL and reviewed with the referring school,

and may result in a review of the child's placement in line with our Behaviour Management

Policy.9. Complaints Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

We aim to resolve concerns quickly, fairly and informally wherever possible, and welcome feedback

as a way of improving our provision. Any parent, carer, school, local authority or child may raise a

complaint, and a child may raise a complaint directly with any member of staff, who will support

them to do so.

Stage 1 - Informal resolution

Concerns should be raised in the first instance with the Director, Nichola Brown, by phone (07950

196977) or email (management@adaptiveprovisionlimited.org). We aim to acknowledge within 1

working day and respond within 3 working days. Many concerns are resolved satisfactorily at this

stage through open conversation.

Stage 2 - Formal complaint

If a concern is not resolved informally, it should be put in writing to the Director, setting out what

happened and what outcome is sought. The Director will investigate, which may include speaking to

staff and reviewing session records, and will respond in writing within 10 working days, explaining

the outcome and any action taken.

Stage 3 - Independent escalation

If the complainant remains dissatisfied, the complaint is referred to the referring school and, where

relevant, the local authority commissioning the placement, for independent review. Complaints that

raise a safeguarding concern are handled under our Safeguarding & Child Protection Policy in

parallel, and never delayed pending the complaints process.

Recording

A written record of every complaint, the investigation, and its outcome is kept for at least three

years, and complaints are reviewed termly by the Director to identify any pattern requiring a change

in practice.10. Data Protection & Privacy Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited is the data controller for personal information it holds about children,

families and staff, and complies with the UK GDPR and Data Protection Act 2018.

What we collect and why

We collect only the information needed to plan and deliver safe, effective provision: name, date of

birth, school, emergency contacts, relevant medical and safeguarding information, and

session/progress records. Special category data (such as health or safeguarding information) is

processed only where necessary for safeguarding or the delivery of appropriate support, and with an

appropriate lawful basis under Article 9 UK GDPR.

How we share information

Information is shared with the referring school and, where legally required, with local authorities or

statutory agencies, under written information-sharing agreements. It is never sold, and never used

for marketing without explicit separate consent.

Storage, security and retention

● Digital records are password-protected and access is limited to staff who need it to carry out

their role.

● Paper records containing personal or sensitive information are kept in locked storage at the

venue.

● Records are retained only as long as necessary, in line with the DfE's records retention

guidance for schools and settings, after which they are securely destroyed.

● Safeguarding records are retained for the period required by statutory guidance, held

separately and more securely than general session records.

Rights and breaches

Parents/carers and staff have the right to access, correct or request deletion of their personal data

by contacting the Director, subject to the exemptions that apply to safeguarding and child protection

records. Any data breach is recorded on our breach log and, where required, reported to the

Information Commissioner's Office (ICO) within 72 hours, with affected individuals informed where

there is high risk to their rights and freedoms.11. Online Safety & Acceptable Use Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

This policy is written with regard to KCSIE Part 1 (online safety) and the UK Council for Internet

Safety guidance, and applies to staff, children and any technology used within our provision.

Use of technology in sessions

● Staff and children use technology only for planned, supervised session activities.

● No child is permitted to use personal mobile phones or devices unsupervised during

sessions; phones are stored securely on arrival and returned at the end of the session.

● Any internet-enabled device used in a session is filtered and monitored appropriately for the

age group.

Staff conduct online

Staff do not contact children or families via personal social media accounts, personal phone

numbers, or personal email addresses; all communication is through official channels agreed with

the referring school and family. Staff are expected to maintain appropriate professional boundaries

on their own social media, including privacy settings that prevent contact from children or families.

Education and response

Age-appropriate online safety education, including safe use of social media, is included in sessions

where relevant, drawing on the therapeutic focus of our curriculum. Any online safety concern,

including a disclosure relating to online harm, grooming, or harmful content, is treated as a

safeguarding matter and referred to the DSL immediately, in line with our Safeguarding & Child

Protection Policy.12. Safer Recruitment & Staff Code of Conduct

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

All staff and sessional practitioners (including our psychotherapist and CAMHS practitioner) are

recruited following safer recruitment principles set out in KCSIE Part 3, to ensure everyone working

with our children is safe and suitable to do so.

Pre-employment checks

● Enhanced DBS check (checked against the children's barred list) obtained before any

unsupervised contact with children.

● At least two references obtained and verified in writing, including from the most recent

employer, addressing suitability to work with children specifically.

● Identity and right-to-work checks completed and copies retained.

● Qualifications relevant to role (for example therapeutic, teaching, or first aid qualifications)

verified against original documents.

● Where a gap in employment history is identified, this is explored and recorded as part of the

recruitment process.

● A single central record of all recruitment checks for every staff member and sessional

practitioner is maintained by the Director and made available to commissioning schools,

local authorities and Ofsted on request.

Induction and code of conduct

All new staff complete an induction covering safeguarding, behaviour management, health and

safety, and this code of conduct before working unsupervised with children. All staff sign and agree

to a code of conduct covering professional boundaries, confidentiality, appropriate physical contact,

use of technology, and safeguarding responsibilities, and this is revisited annually.

Supervision

Given the emotionally demanding nature of therapeutic work, all staff receive regular

clinical/reflective supervision, in addition to line management supervision, to support both their

wellbeing and the quality and safety of their practice.13. Whistleblowing Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Any member of staff who has a concern about the conduct of a colleague, or about practice within

Adaptive Provision Limited, is encouraged and supported to raise it without fear of victimisation, in

line with the Public Interest Disclosure Act 1998.

How to raise a concern

Concerns can be raised directly with the Director (management@adaptiveprovisionlimited.org or

07950 196977). Where the concern involves the Director, staff may instead contact the referring

school's designated safeguarding lead, the Local Authority Designated Officer, or the NSPCC

Whistleblowing Advice Line (0800 028 0285).

What happens next

● All concerns are taken seriously, recorded in writing, and investigated promptly and

confidentially.

● The person raising the concern is kept informed of progress, so far as confidentiality allows,

and told the outcome.

● No member of staff is penalised for raising a genuine concern in good faith, even if it later

proves to be unfounded.

● Concerns relating to a child's safety are treated as safeguarding matters first and follow the

Safeguarding & Child Protection Policy in addition to this policy.14. Photography, Filming & Consent Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

We recognise that photographs and recordings of children require particular care, both to protect

their privacy and, given the sensitive circumstances of many referrals, to avoid any risk to their

safety.

● Written parental/carer consent is obtained before any photograph, video or piece of

artwork identifying a child is used for reporting to schools, case studies, or

marketing/website purposes, and consent is specific to the purpose (for example, internal

reporting versus public website use are recorded separately).

● Consent is recorded per child on our consent register and can be withdrawn at any time by

contacting the Director, with immediate effect.

● Images are stored securely and only shared for the purpose consented to; full names are

never published alongside photographs, and no identifying detail (such as school name or

home town) is published without separate explicit consent.

● Staff and visitors may not take personal photographs or recordings of children on personal

devices under any circumstances; only designated devices are used, and images are

transferred and deleted from the device promptly.15. Accessibility Plan

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Adaptive Provision Limited aims to make our provision as physically, curricularly and socially

accessible as possible for disabled children, staff and visitors, in line with our duties under the

Equality Act 2010.

● We work with Kings Rise Academy, Birmingham to confirm step-free access, accessible toilet

facilities, and appropriate room layout before placing a child with a physical disability.

● Curriculum materials and activities are adapted (larger print, simplified instructions,

alternative activities) so that every child can access our therapeutic and academic offer.

● We seek advice from occupational health colleagues, and where needed the referring

school's SENCO, to plan reasonable adjustments in advance of a placement.

● This plan is reviewed annually and whenever a new access need is identified.16. Exclusion Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Because children are referred to us precisely to avoid or repair exclusion from mainstream school,

we take an exceptionally cautious approach to ending a child's placement, and this decision is never

taken by a single member of staff.

● A placement is only ended before its planned completion where there is a serious and

ongoing risk to the safety of the child, other children, or staff that cannot be managed

through our graduated behaviour response.

● Before any decision to end a placement, a review meeting is held with the referring school

and, where appropriate, parents/carers, to explore what additional support could make the

placement viable.

● Any decision to end a placement early is made jointly with the referring school, who retains

responsibility for the child's ongoing education, and is confirmed in writing with reasons

given.

● We do not use exclusion or removal from a session as a routine behaviour sanction.17. Educational Visits & Off-Site Activities Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Where a session includes any element away from our usual venue, this policy ensures the same

standard of safety and safeguarding applies.

● A written risk assessment is completed and approved by the Director before any off-site

activity, covering transport, supervision ratios, and the specific location.

● Written parental/carer consent is obtained in advance for any off-site activity, along with

emergency contact details for that day.

● Staff-to-child ratios for off-site activities are set higher than for on-site sessions, reflecting

the additional risk.

● A first aid kit, mobile phone, and list of attending children and emergency contacts travel

with the group at all times.

● The referring school is informed in advance of any planned off-site activity.18. Intimate Care Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Where a child requires support with intimate care (for example due to age, disability or medical

need), this is provided with dignity, respect and appropriate safeguards.

● Intimate care needs are agreed in writing with parents/carers before placement begins,

including exactly what support is required and by whom.

● Wherever possible, intimate care is provided by a member of staff of the child's choosing,

and never by a lone adult without another adult aware of what is happening and where.

● Any intimate care provided is recorded, including date, time, and staff member involved.

● Any concern arising during intimate care is treated as a safeguarding matter and reported to

the DSL immediately.19. Curriculum, Assessment & Reporting Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Our curriculum combines core academic subjects with daily therapeutic practice, delivered by

qualified practitioners, and is designed collaboratively with psychologists, psychiatrists, trauma-

informed practitioners and occupational health therapists.

● Each child's starting point is assessed at the beginning of their programme, using

information from the referring school alongside our own observation.

● Progress against academic and emotional/behavioural goals is tracked throughout the

programme and reported to the referring school and parents/carers at the mid-point and

end of every placement.

● The curriculum is arts-based and cross-curricular by design, reflecting evidence that creative,

non-didactic approaches best re-engage children who have struggled in a traditional

classroom setting.

● A written report and recommendations for reintegration is provided to the referring school

at the end of every placement.20. Relationships & Health Education (PSHE) Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Where our sessions touch on relationships, health, or wellbeing education, this is delivered age-

appropriately, in a way that is sensitive to each child's individual circumstances and consistent with

the referring school's own PSHE curriculum.

● Content is age- and developmentally-appropriate, and adapted for any child with additional

needs.

● Sessions are delivered by trained practitioners, with therapeutic input where a topic may be

sensitive for a particular child.

● Parents/carers are informed of the broad content covered, and any statutory right to

withdraw a child from non-statutory elements (for example Sex Education, where relevant

to the age group) is honoured in line with DfE guidance.

● Any disclosure arising during this content is treated as a safeguarding matter in line with our

Safeguarding & Child Protection Policy.21. Staff Appraisal, Supervision & CPD Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

High-quality provision depends on a well-supported, well-trained team, and this policy sets out how

staff performance and development are managed.

● Every member of staff has an annual appraisal with the Director, setting objectives linked to

the quality of provision and their own professional development.

● Regular supervision (both line management and, for therapeutic staff, clinical/reflective

supervision) is provided to support wellbeing and practice quality.

● A training needs analysis is completed annually, and staff are supported to access relevant

CPD, including refresher safeguarding, first aid, and positive-handling training within

required timescales.

● Any performance concern is addressed promptly, supportively, and in a way that does not

compromise the safety or wellbeing of children.22. Volunteers & Visitors Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Anyone visiting our sessions, whether a professional visitor, prospective staff member on

observation, or volunteer, is subject to the same safeguarding standards as our staff team.

● All visitors sign in and out, wear visible identification, and are never left alone with a child.

● Any volunteer or regular visitor who will have unsupervised or substantial contact with

children completes the same safer recruitment checks as staff, including an enhanced DBS

check, before doing so.

● One-off professional visitors (for example a school SENCO attending a review meeting) are

asked for photographic ID and are supervised throughout their visit.

● Visitors are briefed on our safeguarding, fire, and behaviour procedures on arrival.23. CCTV & Site Security Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Where CCTV operates at Kings Rise Academy, Birmingham, it is the venue's own system, operated in

line with the venue's policy and the ICO's CCTV code of practice; Adaptive Provision Limited does not

operate additional recording equipment during sessions.

● Signage at the venue makes clear that CCTV is in operation, in line with data protection

requirements.

● Footage is used only for the purpose of site security and safeguarding, and is not routinely

reviewed by Adaptive Provision Limited staff except where relevant to an incident.

● Access to any footage relevant to a safeguarding or health and safety incident is requested

from the venue in writing and handled under our Data Protection & Privacy Policy.

● Site access is controlled at all times: external doors are kept secure during sessions, and

entry is by supervised sign-in only.24. Records Management & Retention Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Good record-keeping underpins safe, effective and accountable practice. This policy sets out how

records are created, stored, and retained or destroyed.

● Session, progress, incident, medical and safeguarding records are created promptly and

accurately, and stored securely in line with our Data Protection & Privacy Policy.

● Safeguarding records are retained for the period specified in statutory guidance and

transferred securely to the child's next school on transition, with confirmation of receipt.

● General educational and administrative records are retained in line with the Information and

Records Management Society's retention schedule for schools.

● Records due for destruction are disposed of securely (confidential shredding for paper,

secure deletion for digital records), and this is logged.25. Home-Provision Partnership Agreement

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

We believe close partnership with parents/carers and the referring school is central to a successful

placement, and this agreement sets out what each party can expect.

Adaptive Provision Limited will:

● Communicate openly and regularly with parents/carers and the referring school about

attendance, progress and any concern.

● Deliver the agreed programme safely, and treat every child with respect, warmth and

consistency.

● Involve parents/carers and the referring school in any decision about a change to a child's

placement.

Parents/carers and the referring school are asked to:

● Share relevant information about the child, including medical, safeguarding and SEND

information, honestly and promptly.

● Support the child to attend regularly and on time, and inform us promptly of any planned or

unplanned absence.

● Engage with review meetings and feedback throughout the placement.26. Looked After & Previously Looked After Children Policy

Owner: Nichola Brown, Director | Reviewed: September 2026 | Next review: September 2027

Children who are looked after, or who have previously been looked after (including through

adoption, special guardianship, or a child arrangements order), often carry additional vulnerability

and require particularly attuned, trauma-informed support - something our clinical model is

specifically designed to provide.

● The Director acts as our named lead for looked after and previously looked after children,

liaising with the child's Virtual School Head, social worker and carer as relevant.

● Relevant background (including a child's Personal Education Plan, where held by the

referring school) is requested and used sensitively to inform how a child is supported, on a

strictly need-to-know basis.

● We recognise the particular importance of stability and consistent relationships for this

group, and prioritise keeping the same key adults working with a looked-after child

throughout their placement wherever possible.

● Any change in a looked-after child's placement, carer, or social worker is reflected promptly

in how we support them, in liaison with the referring school.

For a copy of any policy in full, or to discuss any of the above, please contact Nichola Brown at

management@adaptiveprovisionlimited.o