•On keeping children safe in education statutory guidance The draft Department for Education guidance on keeping children safe in schools acknowledges the importance of addressing child protection and online safety. However, it does not go far enough in recognising the training needs of staff in schools as it relates to the Internet and social networking sites; especially as new websites and social media platforms are constantly developing. Recommendation: The new statutory guidance on Keeping Children Safe in Schools should include a section on identifying and responding to online sexual harassment and bullying. The guidance should also include a requirement for safeguarding leads to receive regular training on online safety. •On initial teacher training (ITT) Staff in schools should receive initial and continuous development training on peer on peer child sexual abuse and exploitation, the emotional impact it has on a child, and how to work with and support victims of child sexual abuse and exploitation. More specifically, training for staff working in schools should ensure that terminology of consent is shared. The Government last updated the ITT Teacher’s Standards in 2012. This should be updated to include a definition of both sex discrimination and harassment and approaches to addressing them within school settings. All services should be adequately resourced to respond effectively to children who display indicators of sexual abuse and exploitation, and ensure that they can provide consistent support for young people. •Addressing bullying Our Good Childhood Report 2015 found that England ranked bottom for a number of aspects of children’s wellbeing, including those relating to school life, bullying and, especially for teenage girls, feelings about themselves, compared with the 14 countries involved in the international study on children’s well-being. The research showed the profound impact bullying can have on children’s lives, with children in England who were bullied frequently being six times more likely to have low well-being than children who have not been bullied. This is damaging children’s well-being and affecting their mental health. We need to urgently find a way to make young people feel happier about their lives to avoid storing up problems for the future. Learning from The Children’s Society’s subjective well-being programme demonstrates that good mental health is about more than just dealing with mental health problems when they occur. It is also about promoting positive mental health through driving high levels of subjective well-being. The Government should use some of the additional CAMHS investment to provide programmes to promote positive mental health and well-being – particularly targeting particular groups of children (such as those affected by bullying and living outside of the family) for whom levels of well-being are known to be lower. Recommendation: We believe schools are the ideal places to start identifying and meeting the mental health and emotional needs of pupils at an early stage. That’s why we are asking Government to ring-fence investment in this area, and why we hope to use our experience and expertise to prevent children’s mental health problems having lasting effects. •Embedding equality in schools It is crucial that any action that both the Government and schools take in addressing sexual harassment incorporates the principles set out in the Equality Act 2010 . The Department for Education’s Departmental guidance on the Equality Act 2010 outlines some examples of sex discrimination but we believe that further guidance is needed on all forms of sex discrimination, both direct and indirect, as well as on harassment, including sexual harassment in schools. Unacceptable sexualised expectations and behaviour, particularly towards girls, is going largely unseen, unheard and unchallenged increasing the risk of harassment and exploitation. We know that this is the case in the local neighbourhoods of young people we consult with, but also within the school environment. Recommendations: •There should be a duty on schools to embed the Equality Act in their school policies. •The requirements under the Act should also be a priority within school governance and accountability structures.

Despite updates to the key statutory guidance on safeguarding/child protection, ‘Keeping Children Safe in Education’, which incorporate references to “gender-based violence”, we believe this core document still does not comply with the Public Sector Equality Duty nor take into account schools’ obligations under the Human Rights Act. These laws, which clearly apply to schools, require that all reasonable action is taken to protect girls from abuse (which they are known to disproportionately experience), and that reports of abuse must be investigated such that there can be redress and deterrence. This cannot be said to describe the current response to sexual harassment in schools, and arguably neither describes the response to serious sexual assaults. Elsewhere in Government, the cross-governmental strategy A Call to End Violence Against Women and Girls, is very clear that gender-based violence is disproportionately experienced by women and girls but ‘KCSE’ has not incorporated this, and does not say that school teachers and leaders should seek to address this in order to conform with the law. Because KCSE neglects to state the disproportionality of gender-based abuse, there is no guarantee that this knowledge be interpreted either in the Teachers’ Standards document or in actual in-school teacher training. Any survey of NQTs with regard to their knowledge of sexual harassment and assaults and appropriate responses is likely to show this. School Governors are similarly inducted into their role holding to account good policy and practice on safeguarding with this key document; it is likely that a survey of their knowledge would find they are similarly unaware of levels of sexual harassment nor of the proper responses. In the absence of clear naming of and policy towards this behavior, attitudes which either minimize or make excuses for harassment and sometimes abuse can creep in. The current system was in force when schools ‘turned a blind eye’ to widescale child sexual exploitation in Rotherham (the Jay report noted that girls were picked up by older men from school), and while we continue to have confusion over proper policy towards ‘sexting’ and online abuse. It is clearly not empowering school leaders and teachers to act. The new Ofsted Inspections Framework, which instructs inspectors to monitor racist, disability and homophobic bullying, fails to address sexist/gender-based abuse (which, again, for many girls intersects with other forms of abuse). It also sits uncomfortably alongside the Preventing and Tackling Bullying guidance which, while it references the legal obligations of the Equality Act, provides no framework for monitoring equality issues and instructs schools to “exercise their own judgment” with regards to the recording of bullying incidents (even acknowledging that some schools “do not want to keep written records"), making it very difficult to monitor schools’ performance on bullying and compliance with legal obligations. The Committee should note that in the University setting, where institutions are working with adults, such an approach is changing, many UK universities are moving towards specific monitoring of sexual harassment and assaults, and the Taskforce on sexual harassment and assaults in universities which will report this Autumn is likely to recommend such monitoring for universal adoption. Finally, while the regulator Ofsted is a critical actor in the creation of better, safer schools where all children can thrive, we repeat that we strongly believe it is not adequate to appoint Oftsed as the key driver here. Sexual harassment and abuse are so endemic that urgent and radical new drives from the centre, comparable to physical health and safety requirements or health obligations, are required.

Keeping Children Safe in Education: statutory guidance (points 7-8) 3.This statutory guidance fails to mention a whole school approach to tackling violence against women and girls and keeping children safe in schools, something recognised as a key method of sustainably tackling sexual harassment in schools, and advocated by the End Violence Against Women Coalition (EVAW). Teacher Training (points 9-10) 4.Point 9 of the government submission makes clear that schools are responsible for ensuring their staff undertake safeguarding training to help them respond appropriately to incidents of sexual harassment. Girlguiding would be keen to see the Government take leadership on this issue and encourage schools to ensure staff learn how to tackle sexual harassment issues specifically, to show schools that this is a priority. 5.The Department for Education response referring to the Initial Teacher Training (ITT) courses doesn’t show that direct consideration of sexual harassment is included. This doesn’t equip teachers with the required skills to deal with the specifics of sexual harassment in schools. Bullying (points 15-18) 6.It is heartening to hear that the government expects schools to take a strong stand against all forms of bullying and cyberbullying, which can include sexual harassment and violence. Girlguiding would like to see specific mention of gendered sexual bullying added to bullying guidance and that Ofsted, in addition to looking at racist, disability, homophobic bullying and others, also look at gendered bullying and harassment during its inspections.