Harmful Sexual Behaviour Policy

Prostart Policy on Harmful Sexual Behaviour

Statement of Intent

Prostart has a zero-tolerance approach to any harmful sexual behaviour involving children/young people and acknowledges that it could be occurring in our community. Prostart is proactive in its approach to assessing prevalence, responding to incidents and challenging and changing behaviour. This policy applies to all governors, staff and apprentices/learners. 

Schools and colleges have a statutory duty to safeguarding the children in their setting. We work together to foster an environment that creates healthy relationships for children and young people. 

Our approach encourages healthy relationships and works to prevent harmful sexual behaviour and peer on peer abuse child on child abuse. We provide high quality education within our training to reduce the likelihood of the situations occurring. 

We recognise that harmful sexual behaviour is harmful to both the young person affected by the behaviours and the young person who displayed the behaviour and provide ongoing support for all involved.  

Our approach is to treat everything as a safeguarding incident in the first instance – we distinguish between behaviours that are exploratory and part of healthy age and ability appropriate development and those that may be harmful. 

Prostart provide regular opportunities for staff to understand what harmful sexual behaviours might look like and what they should do in the event of a report. We do this by providing training and regular updates where possible. 

We use our training sessions and progress reviews to help educate students about these issues as well as regularly remind and promote reporting routes within Prostart to ensure they know what to do should an incident occur.  

Related Policies

  • POL04_Safeguarding and Child Protection Policy
  • POL04a Anti-Bullying Policy
  • POL09_Whistleblowing 
  • HR 23 -Code of Conduct and Supervision of Staff Policy
  • POL16_Online safety Policy
  • POL15 Acceptable Use Agreements 
  • POL14 Social Media Policy

Leaders and Designated Safeguarding Leads (DSLs)

Our leaders and DSLs have ultimate responsibility in dealing with all incidents of harmful sexual behaviour, including online.  It is the expectation that all incidents of harmful sexual behaviour/sexual violence and harassment are reported to Prostart in line with safeguarding and child protection procedures. We ensure that our DSLs and their deputies receive appropriate training so that they are confident in safeguarding processes. They know when it is necessary to escalate and have information on what national specialist support is available to support all children involved in harmful sexual behaviour and are confident as to how to access this support when required. 

Our DSLs and their deputies have an in-depth working knowledge of key documentation, particularly KCSIE 2022. We ensure that they receive appropriate specialist training, commensurate with their role, and provide ongoing training for all staff.  

It is the role of school leaders and DSLs to ensure that all staff and Governors/Senior Leadership Team receive training specific to harmful sexual behaviour and that it is included as part of induction. 


It is the responsibility of all staff to have read and understood this policy and associated policies. All staff must report any incidents or suspected incidents of harmful sexual behaviour in line with Prostart policy and ensure they are informed of the outcome. It is expected that all staff will challenge any harmful sexual language or inappropriate behaviour. Staff have a duty to ensure that the Prostart environment is one which is safe, and which supports apprentices and learners to understand safe and healthy relationships and appropriate behaviour.

Governors/Senior Leadership Team

We ensure our governors/ senior leadership team receive appropriate training about what harmful sexual behaviour is, when it can pose a risk to children and how to keep children safe.  Our  governors/ senior leadership team receive regular training and updates, both in terms of what sexualised behaviour is, but also how to effectively support establishments and their stakeholders whilst holding provision to account.   

As part of the Safeguarding report, our governors/ senior management team have the opportunity to monitor and evaluate the approach to harmful sexual behaviour to ensure it is adequate and effective. This includes evaluation of the curriculum and feedback. It is the responsibility of the governors/ senior management team to ensure that risks relating to these issues are identified, that a number of reporting routes are available, and that risks are effectively mitigated.  

Apprentices and Learners

All apprentices and learners have the right to learn in a safe, healthy and respectful learning environment.  Our apprentices and learners benefit from a broad and balanced curriculum.  Our learners are encouraged to report any harmful sexual behaviour, even if they are not directly involved.  All learners will be listened to if they make a disclosure and will be treated sensitively – whilst we cannot guarantee confidentiality, their requests will be considered when supporting them. 


We work hard to engage parents and carers by: 

  • Engagement in enrolment/ providing course information at the start
  • Sharing newsletters  
  • Sharing information online e.g., website, social media 

Our parents and carers are made aware of how and when to report any concerns to Prostart, that all incidents will be handled with care and sensitivity, and that it may sometimes be necessary to involve other agencies.  

Vulnerable Groups 

We recognise that, nationally, vulnerable learners may be more likely to be at risk of experiencing HSB. These include: 

  • A young person with additional needs and disabilities
  • A young person living with domestic abuse
  • A young person who is at risk of/suffering significant harm
  • A young person who is at risk of/or has been exploited or at risk of exploited (CRE, CSE)
  • A care experienced child
  • A young person who goes missing or is missing education
  • A young person who identify as, or are perceived as, LGBTQI+ and/or any of the other protected characteristics
  • A young person displaying HSB have often experienced their own abuse and trauma. We work to ensure that any vulnerable learner is offered appropriate support, both within and outside school, sometimes via specialist agencies


Through the provision of good quality training and support, we strive to foster in our DSLs, and their deputies, a good understanding of HSB. This will form part of their safeguarding training. Supporting them in planning preventative education and measures, drafting and implementing an effective Safeguarding and child protection policy and incorporating the approach to sexual violence and sexual harassment into the whole Prostart approach to safeguarding. The training includes:

  • Whole staff training 
  • Online Safeguarding training

Our training strategy supports staff to respond effectively to different types of harassment and sexual misconduct incidents. An assessment of the training needs of all staff will be undertaken regularly and will form the basis of our training strategy. This strategy will be reviewed and evaluated on a regular basis to ensure it is fit for purpose. 

Training will be made available on an ongoing basis for all staff and students to raise awareness of harassment and sexual misconduct with the purpose of preventing incidents and encouraging reporting where they do occur. 

Helpful links

Child Exploitation and Online Protection command

CEOP is a law enforcement agency which aims to keep children and young people safe from sexual exploitation and abuse. Online sexual abuse can be reported on their website and a report made to one of their Child Protection Advisors. 


provides a helpline for professionals at 0808 800 5000 and help@nspcc.org.uk. The helpline provides expert advice and support for school and college staff, and will be especially useful for the designated safeguarding lead (and their deputies). 

Specialist Sexual Violence Sector Organisations

You can access support from specialist sexual violence sector organisations such as Rape Crisis or The Survivors Trust.  

The Anti-Bullying Alliance has developed guidance for schools about Sexual and sexist bullying. 

The UK Safer Internet Centre

Provides an online safety helpline for professionals at 0344 381 4772 and mailto:helpline@saferinternet.org.uk. The helpline provides expert advice and support for school and college staff regarding online safety issues. 

Internet Watch Foundation

If the incident/report you are dealing with involves sexual images or videos that have been made and circulated online, the victim can be supported to get the images removed by the Internet Watch Foundation (IWF). 

Childline/IWF Report Remove

is a free tool that allows children to report nude or sexual images and/or videos of themselves that they think might have been shared online. 

UKCIS Sharing Nudes and Semi-nudes Advice

Advice for education settings working with children and young people on responding to reports of children sharing non-consensual nude and semi-nude images and/or videos (also known as sexting and youth produced sexual imagery).  


from NCA-CEOP provides support for the children’s workforce, parents and carers on staying safe online.

The Centre of Expertise on Child Sexual Abuse

has developed a range of helpful resources to identify and respond to child sexual abuse, including a guide for professionals supporting children following incidents of HSB

Lucy Faithfull Foundation

is a UK-wide charity dedicated solely to preventing child sexual abuse. They work to prevent abuse from happening in the first place by working with all those affected including adult male and female abusers

Marie Collins Foundation

Support people to recover from technology assisted sexual abuse in childhood. We do this directly by supporting individuals and their families, and indirectly through advocacy and education.

NSPCC National Clinical and Assessment Service

(NCATS)  a national service that offers assessment, treatment, consultation and training for and about children and young people where there are concerns about harmful sexual behaviour 

Project deSHAME from Childnet

Provides useful research, advice and resources regarding online sexual harassment. 


Prostart’s educational approach seeks to develop knowledge and understanding of healthy, problematic or sexually harmful behaviours, and empowers young people to make healthy, informed decisions.  Prostart’s approach is delivered predominantly through the curriculum for Traineeship learners and through discussion at Progress Reviews with Apprentices.

Our approach is given the time it deserves and is authentic i.e., based on current issues nationally, locally and within our setting. It is shaped and evaluated by our apprentices and learners to ensure that it is dynamic, evolving and based on need.  We do this through:  

  • Staff consultation 
  • Staff training 

Resources are discussed and developed by the Equality and Diversity Team using a range of resources available online and through CPD activity.

In line with good practice, we have created child-friendly versions of key safeguarding policies, produced which are regularly evaluated.  List those that are available below. 

Safety Starts Here Position Statement


Our systems are well promoted in order to be easily understood and easily accessible for children and young people to confidently report abuse, knowing their concerns will be treated seriously.  All reports will be dealt with swiftly and sensitively and outcomes shared where appropriate. 

Prostart’s Safeguarding and Child Protection Policy includes a list of established organisations we already have links to . 

We also recognise that incidents will not always be reported directly to us, therefore we also train staff to recognise and spot signs of harmful sexual behaviour.  

Responding to an Incident or Disclosure 

We recognise the importance of distinguishing between healthy, problematic and harmful sexual behaviour. Our response is always based on sound safeguarding principles and follows Prostart safeguarding processes.  It is considered appropriate and puts the apprentice/learner at the centre of all decisions made.  

See Safeguarding and Child Protection Policy

Prostart will always adopt a multi-agency approach and seek external support and guidance, in line with school policy, if deemed necessary.  This may include: 

CAMHS, Police etc  See Annex 1 Sexual Violence and Harassment Flowchart

Risk Assessment

Prostart may deem it necessary to complete a harmful sexual behaviour risk assessment as part of the response to any reported incidents.  The purpose of the risk assessment is the protect and support all those involved by identifying potential risk, both in and out of Prostart (e.g., public transport, after school clubs etc) and by clearly describing the strategies put in place to mitigate such risk.   

The risk assessment will be completed following a meeting with all professionals working with the learner, as well as parents or carers. Where appropriate, the apprentices/learners involved will also be asked to contribute.   

The risk assessment will be shared will all staff who work with the learner, as well as parents and carers.  It will respond to any changes in behaviour and will be regularly updated and evaluated to assess impact.  

Our template risk assessment can be found Staff Shared/ Quality/ Safeguarding/Prostart Forms

Appendix 1 Cyberbullying and Sexting

What is online abuse?

Child abuse in all its forms is increasingly occurring online. The Internet and its range of content and services can be accessed through an ever developing variety of devices including PCs, laptops, mobile/smart phones, tablets, games consoles.

The Internet has, in particular, become a significant tool in the distribution of child abuse images.

Internet chat rooms and social networking sites can all be used as a means of contacting children with a view to grooming them for inappropriate or abusive relationships. This may include requests to make and transmit indecent images of themselves, or to perform sexual acts live online or to give their mobile phone number and other personal information.

The Serious Crime Act (2015) has introduced an offence of sexual communication with a child. This applies to an adult who communicates with a child and the communication is sexual or if it is intended to elicit from the child a communication which is sexual and the adult reasonably believes the child to be under 16 years of age. The act also amended the Sex Offences Act 2003 so it is now an offence for an adult to arrange to meet with someone under 16, for the purposes of committing a relevant offence, having communicated with them on just one occasion

Crime recording

When the police are notified about youth-produced sexual imagery, they must record this as a crime. The incident is listed as a crime, and the young person is the suspect. This is, however, not the same as a criminal record.

Every crime reported to the police must have an outcome code. The NPCC, Home Office and the DBS have agreed a new outcome code for youth-produced sexual imagery.

Outcome 21: This outcome code allows the police discretion not to take further action if it is not in the public interest, even though there is enough evidence to prosecute.

Using this outcome code is likely to mean the offence would not appear on a future Enhanced DBS check, although not impossible, as that disclosure is a risk-based decision. Organisations can be assured that the police have the discretion they need not to adversely impact young people in the future.

Online bullying or cyber bullying

Children can engage in, or be a target of, bullying using a range of methods including text, phones or social network sites to reach their target. Mobile camera phones are also used to capture violent assaults of other children for circulation. This form of bullying is a growing problem in schools and other settings. It should be taken seriously by any practitioner who becomes aware of it. Harassment by use of ICT is a criminal offence and if necessary concerns should be reported to the police.

Youth produced sexual imagery ‘sexting’

Youth produced sexual imagery also known as ‘sexting’ describes the use of technology to share sexual images (photos and videos) which young people, or another young person, have created themselves. Young people are not always aware that sharing images in this way is illegal. The widespread use of smart phones has made the practice much more common. It is a crime to take, make, permit to take, distribute, show, possess, possess with intent to distribute, or to advertise indecent photographs or pseudo-photographs of any person below the age of 18.

The National Police Chiefs Council (NPCC), working in partnership with a wide range of schools, local authorities, polices forces and organisations including the Disclosure and Barring Service, the Internet Watch Foundation, the UK Council for Child Internet Safety, DfE and teaching unions have published guidance for schools and education establishments in England. 

S‌exting in Schools and Colleges: responding to incidents and safeguarding young people (2016) UKCCIS – offers practical advice about: 

  • responding to disclosures
  • handling devices and imagery
  • risk assessing situations
  • involving other agencies, including escalation to the police and Children’s Social Care
  • recording incidents
  • involving parents
  • preventative education 

Handling incidents

  • Refer to the designated safeguarding lead
  • DSL meets with the young people involved
  • Do not view the image unless it is avoidable
  • Discuss with parents, unless there is an issue where that’s not possible
  • Any concern the young person is at risk of harm, contact social care or the police

Always refer to the police or social care if incident involves:

  • an adult
  • coercion, blackmail, or grooming
  • concerns about capacity to consent, [e.g., SEN]
  • images show atypical sexual behavior for the child’s developmental stage
  • violent acts are depicted
  • image shows sex acts and includes a child under 13
  • a young person at risk of immediate harm as a result of the disclosure (for example, self-harm or suicide)

Assessing the risks once the images have been shared

  • Has it been shared with the knowledge of the young person?
  • Are adults involved in the sharing?
  • Was there pressure to make the image?
  • What is the impact on those involved?
  • Does the child or children have additional vulnerabilities?
  • Has the child taken part in producing sexual imagery before?

Viewing images

  • Avoid viewing youth-produced sexual imagery. Instead, respond to what you have been told the image contains.
  • If it is felt necessary to view, discuss with the head teacher first.
  • Never copy, print, or share the image (it’s illegal)
  • View with another member of staff present
  • Record the fact that the images were videoed along with reasons and who was present. Sign and date.

Deleting images (from devices and social media)

If the organisation has decided that involving other agencies is not necessary, consideration should be given to deleting the images.

It is recommended that pupils are asked to delete the images themselves and confirm they have done so. This should be recorded, signed, and dated.

Any refusal to delete the images should be treated seriously, reminding the pupil that possession is unlawful.

Appendix 2 Sexual Violence and Harassment Flowchart

Appendix 3 Other Support Services/ Contacts

Harmful Sexual Behaviour Support Service | SWGfL

It’s available Monday to Friday 8am to 8pm on 0344 225 0623, or hsbsupport@swgfl.org.uk.

Report Harmful Content – We Help You Remove Content

Cyber Security | East Midlands Cyber Secure | England

Action Fraud

Also see Prostart’s Hot Topics Padlet Hot Topic – Safeguarding: Sexual Abuse, Harms and Harassment (padlet.com)

Appendix 4 Legislative Background and Context

In the Sexual Offences Act 2003, the term Harmful Sexual Behaviour (HSB) covers a wide range of behaviours. HSB can occur online, offline or in a blend of both environments. The term HSB is widely acknowledged in child protection and should be treated in this context. 

“Child-on-child” has evolved from the term “peer-on-peer” in recognition that age and development is a factor in making decisions about behaviour. A significant age difference between the children involved in an incident may lead to a decision about the behaviour being harmful or not. For example, this could be an older child’s behaviour towards a pre-pubescent child, or a younger child’s behaviour towards an older child with learning difficulties. It is important that designated safeguarding leads (DSL) know what is and is not HSB. 

DSLs should be involved in planning the curriculum for HSB, planning preventative actions and ensuring a whole-school culture that tackles HSB, alongside all other forms of abuse and harassment. This template policy provides a basis for an effective approach to managing sexual violence and harassment.   

Harmful sexual behaviours can be self-directed, for example, using highly sexualised language, persistent private and or public masturbation, prolifically watching or searching for pornographic content/ age-inappropriate materials. To understand more about the range of behaviours that should be recognised as harmful, please refer to the NSPCC Harmful sexual behaviour framework

What is Sexual Violence?

The following are sexual offences under the Sexual Offences Act 2003: 


A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents. 

Assault by Penetration

A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents. 

Sexual Assault

A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents. (NOTE- Schools and colleges should be aware that sexual assault covers a very wide range of behaviour so a single act of kissing someone without consent or touching someone’s bottom/breasts/genitalia without consent, can still constitute sexual assault.) 

Causing someone to engage in sexual activity without consent

A person (A) commits an offence if: s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not consent to engage in the activity, and A does not reasonably believe that B consents. (NOTE – this could include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.) 

What is Sexual Harassment? 

Part 5 in the Keeping children safe in education statutory guidance (2022) states:  

When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline and both inside and outside of school/college. When we reference sexual harassment, we do so in the context of child-on-child sexual harassment. Sexual harassment is likely to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. 

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

  • Sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names 
  • Sexual “jokes” or taunting 
  • Physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (schools and colleges should make clear that when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature; and 
  • Online sexual harassment may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include: 
  • Consensual and non-consensual sharing of nude and semi-nude images and/or videos. Taking and sharing nude photographs of U18s is a criminal offence.  
  • Sharing of unwanted explicit content 
  • Upskirting (this is a criminal offence) 
  • Sexualised online bullying 
  • Unwanted sexual comments and messages, including, on social media 
  • Sexual exploitation; coercion and threats

It is important that schools and colleges consider sexual harassment in broad terms. Sexual harassment (as set out above) creates a culture that, if not challenged, can normalise inappropriate behaviours and provide an environment that may lead to sexual violence. 

V2 January 24