When we start thinking about how many policies and procedures there are within our settings we can start to feel overwhelmed with it all. We may question how many we actually need, what must we have to be compliant and whether we really require a particular policy and/or a procedure.
I sometimes find that providers have too many documents in place. Some are repetitive and not needed.
The main starting question should be 'What do I, as a provider, need to have in place to meet the legislative requirements?' It is helpful to remember that policies and procedures serve different purposes and have different messages. The guidance I provided in Nursery World back in 2006 still holds good:
'Policies reflect the rules governing the implementation of the setting's processes.
Most policies are developed to reflect local, national and international Government requirements. For instance, they need to cover health and safety at work and equality of opportunities.
'Procedures, however, represent an implementation of the policy. In other words, procedures are the actions that staff should take. For example, the actions to be taken in the case of an accident or a safeguarding incident. Therefore, in terms of good practice, policies and procedures should be separate documents.'
Remembering this we can, if necessary, devise specific policies and procedures as separate documents and/or have them combined. But the important point to remember is to clearly state in the document what you are indeed referring to.
I believe that every setting, and childminder, should have written policies and procedures in place. Although childminders are not required to have policies and procedures actually written down, I would strongly recommend that they have written policies and procedures in place as a way of protecting themselves, the children, parents, any assistants and their family members.
I have acted as an expert witness and I have to stress how important it is to have written documents in place, especially the ones that demonstrate how you meet the requirements of registration.
Written policies and procedures can be used as a reference point to clarify that systems are in place if an issue, incident and/or accident were to occur. I am pleased to say that the majority of childminders I work with do have written policies and procedures in place, as they recognise their importance in complementing and enhancing their practice.
When writing a document of such importance as a policy and/or procedure, you need:
Name of your setting and logo if you have one:
This is important as it gives a sense of ownership. (I have seen documents stating the name of another setting and/or the name of the organisation/company that the provider has purchased/acquired the policies and procedures from.)
State your intention and objective:
What does the document intend to do and what are the key objectives of the documents?
Audience:
Who is the document for? Is it for parents, staff or stakeholders, or a general document? Once we clarify who our audience is it helps us to frame the document.
Body:
Include the steps to the procedure or the pointers of the policies.
Links to other legislation:
As we know, there are other legislative requirements that settings need to adhere to, such as the Health and Safety at Work Act 1974 and The Equality Act 2010. It may be helpful to cross reference to the relevant legislation.
Contact details:
Include contact details of, for instance, senior management personnel - full names, email address, the address where they are based and a telephone number. For certain documents this is a must.
Images:
Do you need to include any drawings or photographs to illustrate your points?
Date:
Documents need to be dated. I have seen policies and procedures dated ten years ago and one, recently, even making reference to the National Standards.
Signed and name of person or persons signing:
This is important, as it gives the document real authorisation. The documents should be signed by a key person in the senior management team. Even if they haven't written the document, they should still sign.
Date of review:
You need to state a date that the document will be reviewed. This should ideally be every year and/or when there is a change in legalisation or guidance.
So what policies and procedures do we need to have in place? My thoughts are that we need to make sure we understand what is needed within the EYFS 2012 and Ofsted's childcare factsheet Records, Policies and Notification Requirements of the Early Years Register. In this factsheet Ofsted has clearly stated what a setting needs to have place in order to meet the requirements of registration.
With this in mind, for the remainder of this article and the next few articles, I am going to give an overview as to what needs to be included within the policies and procedures that are needed to meet legislative requirements:
Safeguarding and child protection policy and procedure
There must be a policy and procedure for safeguarding and child protection. I would also suggest that to support this there should be an audit in place. The audit should cover:
- Who the lead person and deputy is within the setting for safeguarding and child protection
- Training that they have had
- Appropriate training and guidance for staff
- Current contact for the lead person with the local authority
- Whether all staff been issued with the summary Department of Health guide to practitioners What To Do If You're Worried a Child is Being Abused
- How you inform volunteers and agency staff of your policy
- Importantly, do staff fully understand your whistle-blowing policy and procedure? (You may wish to include your whistle-blowing policy and procedure in your safeguarding policy and procedure.)
- State the types of behaviour staff may display that would be a cause of concern
- Effective procedures in place for safer recruitment
- Statements about safe environment, protection behaviours, bullying, personal safety and racial awareness
- Whether staff have an awareness of the impact of domestic violence on children
- Staff's understanding of the four main areas of abuse: sexual, physical, neglect and emotional.
This needs to be the glue that 'sticks' everything together in terms of your commitment to protecting and safeguarding children.
You need to have clear steps in place if an allegation is made against a member of staff, and there needs to be links to your human resources systems as well.
You should be clear that under no circumstances would you ever let a staff member 'go', thinking that they are no longer your responsibility. Your duty should be safeguarding and protecting every child in or out of your setting.
Clarity around the use of mobile phones and cameras is needed. Of course, some settings only have a mobile phone as their main telephone. We increasingly use cameras and other devices to record children's achievements, take photographs and share with parents. The issue is not the equipment but staff's professional use of equipment, linking to confidentiality and keeping children safe.
Some settings ask staff to leave their own personal phones in the staff room or office and tell parents and visitors that no mobile phones are to be used within the setting.
You also need to be clear within the documents how you create a culture of keeping children safe and protected; this also links to your attitudes and behaviour of your staff team.
Only when we have a real and honest comment to safeguarding are we in a position to safeguard children.
Laura Henry is managing director of Childcare Consultancy
FURTHER READING:
- Ofsted: Records, Policies and Notification Requirements of the Early Years Register
- Plymouth Review: Serious Case Review into Abuse at Little Ted's Nursery
- EYFS: 2012