Safeguarding & KCSIE: What’s changed and what should we do about it?

Written by: Elizabeth Rose | Published:
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Every September the statutory safeguarding guidance Keeping Children Safe in Education is updated. Expert Elizabeth Rose looks at the key updates this year and the implications for those working in schools

The latest version of Keeping Children Safe in Education (KCSIE) was released in the summer term and updated again over the summer break before coming into force on September 1 (DfE, 2021a).

The overarching theme that runs throughout the updates is the need to continually strengthen the culture of safeguarding in schools and to empower everyone to play their part in keeping children safe.

There are substantial, helpful changes to the document in a range of areas, as well as smaller tweaks and rewording throughout.

The document contains a table that briefly lists the updates, and I would suggest you go through it and highlight the new content to refer back to later during self-review.

However, there are three main areas that will require very careful consideration to make sure your policy – and crucially, your practice – have developed in line with the updated guidance.

1, Online safety

Online safety has been a major concern for safeguarding leads for some time, but the focus has become more intense following Covid-19 and the heavy reliance on technology during lockdowns.

KCSIE has been updated to reflect the growing issue of staying safe online and a comprehensive section has been added to Part 2. Key points for consideration include:

  • The school’s approach to online safety must be reflected in the child protection policy – including the policy on the use of mobile phones and smart technology.
  • All staff must undergo online safety training on induction.
  • The designated safeguarding lead (and deputies) must undertake online safety training.
  • Schools must take a “whole-school approach” to online safety – feeding into the wider culture of safeguarding. This includes (but is not limited to) planning the curriculum, teacher training, the role and responsibilities of the designated safeguarding lead, and any parental engagement.
  • Filters and monitors need to be in place and effective, and schools should consider their e-security measures.
  • It is a good idea to review annually your approach to online safety in order to ensure that it is relevant and up-to-date.

It is also important that we do not forget remote learning. This is something that is here to stay and should continue to be referenced in your policy and training.

2, Peer-on-peer abuse

The sections supporting schools in minimising and responding to peer-on-peer abuse have been strengthened. The definition of peer-on-peer abuse has been updated and is more detailed and diverse than it was before, with new terminology (such as “sharing of nudes”).

There are clear requirements on what your policy should contain, set out as a prescriptive list, and Part 5 – Child-on-child sexual violence and harassment – has been developed to provide clearer information and direction.

This should all be read alongside the guidance document Sexual violence and sexual harassment between children in schools and colleges (DfE, 2021b). The key messages to take from these updates for your whole-staff training are:

  • Assume that peer-on-peer abuse (particularly sexual harassment and violence) is happening, even if there are no reports.
  • Schools have a responsibility to respond to peer-on-peer abuse that happens outside of school and/or online, as well as incidents happening on-site.
  • Staff must understand how to challenge inappropriate behaviour and why they should.
  • We should never downplay incidents, or make young people feel that they are creating a problem by reporting abuse, sexual violence, or sexual harassment.
  • We must listen to the child’s voice when responding to any disclosures or concerns, including peer-on-peer abuse, and take their wishes into account.

All staff must be made aware of the school policy and procedures for minimising and responding to peer-on-peer abuse and I would strongly suggest dedicating time throughout the year to re-visit this topic in staff training.

PODCAST: Elizabeth Rose recently took part in an in-depth episode of the SecEd Podcast – Headteacher Update's sister magazine – focused on how schools must respond to the Ofsted review into sexual harassment and peer-on-peer abuse. Listen to this episode here:

3, Low-level concerns

The third change I would like to draw your attention to is in Part 4. As a result of feedback during the consultation, the Department for Education (DfE) has included more detail around responding to “low-level concerns”, which are concerns that do not meet the harms threshold.

Low-level concerns are not insignificant – a teacher having favourites for example, or a member of staff using inappropriate sexualised language – and still need to be reported, recorded, and dealt with appropriately.

Essentially, the core message of this section is to promote a safer culture – linking closely to safer working practice guidelines – and ensure that a thorough safeguarding response is embedded within the wider response to staff breaking the code of conduct. Key action points include:

  • Schools should promote an open and transparent culture and deal with all concerns and/or allegations promptly.
  • The policy on low-level concerns should be outlined in the school safeguarding policies and the staff code of conduct. This should include what a low-level concern is, the importance of sharing concerns, and what the purpose of the policy is (see Eastman et al, 2020).
  • Schools should train staff to understand what appropriate behaviour is and empower them to report any concerns to the appropriate person.
  • Schools must address any inappropriate behaviour at the earliest stage to prevent escalation or future harm.
  • It is important to review systems and the school culture as part of the response to low-level concerns, in case it is failing to prevent, or is facilitating, inappropriate behaviour.

The guidance now includes clear points on how to respond and record any low-level concerns, to further support the school response.

In summary

There are many guides available that discuss and support us in understanding the updates, but there is no substitute for reading, re-reading, and re-referring to the guidance itself.

It is absolutely essential that governors (or the equivalent), all senior leaders (including designated safeguarding leads, of course) and deputy designated safeguarding leads know and feel confident with this guidance.

Other staff need to read selected sections, but it is important that they know where to find this document so that they can also use it effectively and refer to it when needed.

Safeguarding, now more than ever, needs to underpin everything you do as a school and must thread through all aspects of school life. As you can see from the discussion here, it is not sufficient to mention this guidance once a year anymore (and many – including myself – would argue that it never was) and the updates and the subsequent procedural changes must be reflected on, implemented, and embedded with regular staff training and on-going self-reflection.

  • Elizabeth Rose is an independent safeguarding consultant and the director of So Safeguarding. She has worked in education for more than 15 years and is a former secondary designated safeguarding lead and local authority safeguarding in education advisor. Visit or follow her @sosafeguarding. Find her previous articles for Headteacher Update via

Further information & references

  • DfE: Keeping Children Safe in Education, last updated September 2021a:
  • DfE: Sexual violence and sexual harassment between children in schools and colleges, September 2021b:
  • DfE: Searching, screening and confiscation at school, last updated January 2018:
  • Eastman et al: Developing and implementing a low-level concerns policy: A guide for organisations which work with children, Farrer & Co, January 2020:
  • Ofsted: Review of sexual abuse in schools and colleges, June 2021:
  • Rose: Safeguarding & sexual abuse: Key changes from September, SecEd, August 2021:
  • SecEd Podcast: Effective safeguarding practice in schools, April 2021:
  • SecEd Podcast: Everyone’s Invited and Safeguarding in Schools, September 2021:

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