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When a school updates its safeguarding policy for KCSIE 2026, does it award itself an unofficial badge of readiness?
Most organisations will have downloaded the latest guidance, updated their policies, circulated the links and asked staff to confirm that they have read everything.
All these steps are very necessary, but do they make an organisation ready when a real safeguarding concern appears on a busy Monday morning?
The question therefore is: do these steps demonstrate how staff will respond to a concern?
KCSIE 2026 comes into force on 1 September 2026. It applies to schools and colleges in England and sets out the legal duties they must follow to safeguard and promote the welfare of children.
I expect most education employers will meet the deadline. Will this extend to operational detail? The information may be received but not fully understood, training may be completed but not applied, or a familiar person may have had a role change without anyone reconsidering the checks.
The policy may comply with the guidance even when parts of the process fail in practice.
Here are five checks I would use to find out whether that ‘unofficial badge of readiness’ has actually been earned.
TL;DR
- Updating the policy is a start; but staff using it in practice is litmus test for implementation.
- All staff now work from the same Part One safeguarding expectations.
- Recruitment teams and application packs need to reflect the latest safer recruitment guidance.
- Changes to regulated activity may create new barred-list checking duties for some existing volunteers.
- Safeguarding continues after appointment. A completed recruitment file is not a permanent judgement about a person.
1. Can your staff explain what they would do?
One of the most noticeable changes in KCSIE 2026 is the removal of the shorter version of Part One previously found in Annex A.
The Department for Education has said:
…governing bodies and proprietors should ensure that all staff, including those who do not work directly with children, read Part One. Copies of relevant policies and Part One should also be provided at induction.
There will be a temptation to treat distribution as job done.
An email receipt will tell you that a document arrived at its destination. Even better, a signed declaration will confirm receipt and pinky promise that it has been read. Unfortunately, neither will give any real confidence that a person would know what to do if a child disclosed something concerning tomorrow morning.
We are all human, and we are all busy, so to cut through things, I would ask a small sample of staff to explain:
- what they would recognise as a concern;
- who they would report it to;
- what they would do if the DSL were unavailable;
- where they would record the information;
- what they must not promise a child.
Be sure to include temporary, administrative, facilities and support staff.
It’s important that safeguarding information does not depend on job title or how often someone works directly with children.
If people need to search for the policy before they can describe the first step, there’s probably still work to do.
2. Has the policy changed the way people work?
Most education employers will have updated their safeguarding documents for September. The next check is whether each change has made its way into induction, training, reporting and oversight.
KCSIE places responsibility on governing bodies and proprietors to ensure that policies, procedures and training are effective and comply with the law. There can be a fair few layers between the governing body and the person receiving a disclosure on Monday morning. Each layer needs to pass on the same clear instruction.
An accurate policy achieves little when staff cannot apply it.
I would start with the reporting route. Is it visible, easy to understand and available when the usual contact is absent? A staff behaviour policy may be complete but missing from induction. Refresher training may cover every headline change without checking whether anyone can use it.
Again, we are all human, and we are all busy, but take time to follow the chain:
- induction materials;
- staff training and refresher schedules;
- low-level concern and allegation procedures;
- escalation routes;
- record keeping;
- governor or proprietor oversight;
- the visibility and availability of the DSL team.
Then look closely at the handovers. This is usually where a clear process becomes less clear.
Who owns the follow-up? Who notices expired training? Who reaches agency and temporary staff? Who connects information held by different people or in different systems?
Schools already have quite enough administration. The point of this review is to find where a reasonable policy could fail under pressure, then fix that point before someone has to rely on it.
3. Is safer recruitment operating as one system?
I treat safer recruitment as a chain of decisions. It begins with the advert and continues well beyond someone’s first day. When those decisions are handled as separate administrative jobs, important context can be skimmed over.
KCSIE 2026 says that governing bodies and proprietors should ensure those involved in recruiting and employing people to work with children receive appropriate safer recruitment training. At a minimum, that training should cover Part Three of the guidance.
The guidance also says that application packs should contain, or link to, the organisation’s child protection policy and practices and its policy on employing ex-offenders.
These details influence who applies, how suitability is assessed and whether the final decision can be defended later.
I would check who is really involved in shortlisting and interviewing, rather than who the process says should be involved.
- Is their safer recruitment training current and evidenced?
- Do the links in the application pack still work?
- Are gaps and discrepancies explored consistently?
- Would the rationale for a difficult decision make sense to someone reviewing it six months later?
Fragmentation tends to create a particular risk. One person advertises the role, another shortlists, someone else checks documents, and the final judgement lives in an email thread. Every box may have been completed while nobody had a clear view of the whole case.
A sound process brings the evidence together and records where human judgement was applied. If nobody can reconstruct the decision, the recruitment record is incomplete.
4. Have you checked every type of worker against the right requirement?
Familiarity can make an earlier checking decision feel more reliable than it is. The person may be the same; their duties, access or legal position may have changed.
Education workforces include permanent employees, volunteers, contractors, agency staff and self-employed specialists. Some people also move between duties over time. The correct check depends on the work they now do and whether it falls within the relevant legal definitions.
KCSIE 2026 includes changes linked to the Crime and Policing Act 2026. Where an existing volunteer will enter regulated activity from 1 September 2026 because of those changes, the school or college must check that person’s children’s barred-list status by obtaining the appropriate enhanced DBS check with barred-list information.
That creates an immediate job for education employers: identify which existing volunteers are affected.
Review:
- volunteers whose duties may now amount to regulated activity;
- self-employed people and the level of DBS check available for their work;
- agency and supply arrangements;
- contractors and visitors;
- anyone whose role, frequency of work or level of access has changed.
Pay particular attention to the people everyone already knows. Familiarity can discourage a fresh assessment, even when the role has changed substantially.
Length of service does not confirm that the current check remains appropriate. Remember, people change, circumstances change…
Where the position is unclear, verify the role and the required check before acting. An earlier decision is evidence of what was considered then; it should not be treated as an automatic answer now.
5. What happens after someone starts work?
I come back to this point repeatedly because it is tempting for the recruitment team to create a sense of finality.
The right DBS checks form one part of safer recruitment, but the employer’s safeguarding responsibility does actually continue after someone begins work.
A pre-employment check records information available at a point in time. It cannot provide a permanent conclusion about suitability or future behaviour.
Organisations still need clear ways to recognise, report, record and act on concerns involving existing staff and volunteers. Staff should know how to raise a concern about another adult. Leaders should understand their legal reporting duties. Low-level concerns should be considered consistently and fairly, including whether separate observations begin to form a pattern.
I would stress test five things:
- Can staff explain how to raise a concern about another adult?
- Are low-level concerns recorded and reviewed for patterns?
- Is information stored securely and shared only where appropriate?
- Are decisions and their rationale documented?
- Is risk reconsidered when someone’s role or access changes?
Compliance tick boxes are very good at showing that a required step took place. What we really need to know is whether the overall system is protecting children right now.
As employers need evidence of both:
- the checks completed before appointment, and
- the way concerns are handled afterwards.
KCSIE 2026 requires attention throughout the year
The start of the academic year gives education employers a hard stop. Please try not to let it become the only point at which readiness is tested.
Once every planned update has been completed, poke around and see where the process could still fail.
Look for specific gaps:
- information distributed but not understood,
- training completed but not applied,
- a volunteer whose duties have changed, or
- a recruitment decision supported by evidence scattered across several systems.
Use these checks during induction, when roles change and at sensible points throughout the year. Make sure someone owns the evidence, the exceptions and the follow-up. Otherwise, small gaps tend to remain loose ends until a real concern exposes them.
If the review identifies uncertainty around screening, safer recruitment or the consistency of your checks, speak to people who work with these risks every day. Safehire.ai can help education employers understand where another layer of visibility or verification may be useful, while keeping judgement with people.
I would finish with one practical test. Ask five members of staff what they would do if a safeguarding concern arose tomorrow. Would their answers match your policy?
The differences between those answers will show you where the policy has not yet translated into practice. Good luck!
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