Key contacts 

District Tuition Business and Safeguarding Lead	Desmond Gallagher d.gallagher@districttuition.com +44 (0) 7784976383
External Support	NSPCC Helpline: 0808 800 5000 Childline: 0800 1111 Education Support Helpline: 0800 562561

 

Purpose and Scope of this Policy

The Safeguarding and Child Protection policy is based on legislation, statutory guidance and policies that seek to protect learners and vulnerable adults. It outlines our position and clarifies the action to ensure that we meet our duties relating to protecting the safety and promoting the well-being of learners. We believe everyone is responsible for promoting the welfare of learners and young people, keeping them safe and practising in a way that protects them.

The welfare of our learners is paramount in all the work we do and in all the decisions we make. Therefore, all learners, regardless of age, disability, gender, race, religion or belief, or sexual orientation, have an equal right to protection from all types of harm and abuse.

Some learners are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues.

This policy applies to all Learners. In addition, it applies to anyone working for or on behalf of District Tuition.

This Policy relates to all situations in both the UK and Internationally. We commit that even where English law and regulation do not apply, we shall operate as if the laws and limitations apply.

Our learners live in various jurisdictions governed by laws and cultural expectations that differ from country to country. Therefore, we welcome the chance to forge an international community and champion the diversity of our learners and tutors.

We expect the behaviour of tutors and learners within our community to be governed by the expectations laid out in our policies, which are informed by British Values and English law.

The term ‘online’ in this document refers to someone using a device to gain access to the internet.

The term ‘parent’ refers to birth parents and other adults in a parenting role, such as stepparents, guardians, carers and adoptive parents.

Our Beliefs

We aim for all learners to have the same opportunity to use and engage with us; therefore, all should have equal protection when doing so. We aim to do all we can to ensure that learners are not at risk of harm. However, we will recognise and take appropriate action when any learner may be at risk of injury.

How We Keep Learners Safe

• You are valuing, listening to and respecting learners.
• We are appointing a nominated Designated Safeguarding Lead.
• We adopt child protection and safeguarding best practices through our policies, procedures and code of conduct for tutors and teachers.
• We are developing and implementing adequate online safety.
• We provide effective management for tutors and teachers through supervision, support, training and quality assurance measures so that all tutors and teachers know about and follow our policies, procedures and codes of conduct confidently and competently.
• Recruiting and selecting tutors and teachers safely, ensuring all necessary checks are made.
• Recording, storing and using information professionally and securely, in line with data protection legislation and guidance.
• Sharing information about safeguarding and good practice.
• Making sure that learners, vulnerable adults and their families know where to go for help if they have a concern by using our safeguarding and child protection procedures to share concerns and relevant information with agencies who need to know and involving learners, vulnerable adults, parents, families and carers 
• Using our procedures to manage any allegations against tutors and teachers appropriately.
• Creating and maintaining an anti-bullying environment and dealing effectively with any bullying.
• Ensuring that we have effective complaints and whistleblowing measures in place.
• Building a safeguarding culture where tutors and teachers, learners, young people and their families treat each other respectfully and are comfortable sharing concerns.

Online Safety

We take a robust approach to online safety to protect and educate learners in the responsible use of technology and establish mechanisms to identify, intervene and escalate any safeguarding concerns. The four primary areas of risk online are content, contact, conduct and commerce.

Content (Learner as a recipient)

• Material that can damage learners, young people or vulnerable adults when it isn’t age-appropriate.
• Sites may show sexual, violent or hate material.
• Sites may promote harmful behaviour.

Content (Learner as a participant)

• This is where adults or peers contact learners to abuse them.
• This is where learners, young people, and vulnerable adults are contacted for exploitation and radicalisation.

Content (Learner as an actor)

• This relates to learners, young people and vulnerable adults’ behaviour online
• This may include bullying and sexting.

Content (Learner as a consumer)

• This includes risks such as online gambling, inappropriate advertising, phishing and or financial scams.
• If we feel learners are at risk, this is reported to the Anti-Phishing Working Groups.

Equality of Safeguarding Provision

Some learners may be at an increased risk of abuse or face additional barriers which make them less likely to disclose abuse. However, we are committed to ensuring that all learners receive equal protection regardless of their circumstances or obstacles. We, therefore, give special consideration to a learner who:

• is disabled or has specific additional needs;
• has special educational needs;
• is a young carer at home;
• shows signs of being drawn into anti-social or criminal behaviour, including gang involvement and association with organised crime groups
• frequently misses education or goes missing from care or home;
• is misusing drugs or alcohol;
• is in a family circumstance presenting challenges, such as substance abuse, adult mental health problems or domestic abuse;
• is showing early signs of abuse and neglect
• is known or believed to have either consensually or non-consensually shared nudes or semi-nude images and/or videos;
• is at risk of modern slavery, trafficking, FGM, sexual exploitation, forced marriage, or being radicalised;
• is or has previously been fostered or looked after outside of their family unit due to government intervention; and/or
• is vulnerable to discrimination and maltreatment based on race, ethnicity, religion, disability or sexuality or who does not have English as a first language.

Definitions

Abuse

• A form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent damage.
• Harm can include ill-treatment that is not physical nor the impact of witnessing the ill-treatment of others. For example, this can be particularly relevant to the effects on children of all forms of domestic abuse.
• Children may be abused in a family or an institutional or community setting by those known to them or, more rarely, by others.
• Abuse can take place wholly online, or technology may be used to facilitate offline abuse.
• Children may be abused by an adult or adult or another learner or learner.

Physical Abuse

• Any form of threatened or actual violence may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child.
• Physical harm may also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness in a child.

Emotional Abuse

• The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s psychological state and emotional development. This may involve:
• conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person;
• not giving the child opportunities to express their views, deliberately silencing them or “making fun” of what they say or how they communicate;
• age or developmentally inappropriate expectations being imposed on children, including interactions that are beyond a child’s developmental capability;
• overprotection and limitation of exploration and learning;
• preventing the child from participating in regular social interaction;
• seeing or hearing the ill-treatment of another person;
• severe bullying (including cyber-bullying);
• causing children to feel frightened or in danger frequently; and/or
• exploitation or corruption of
• Some level of emotional abuse is involved in all types of maltreatment of a learner, although

Sexual Abuse

• Forcing or enticing a child or young person to participate in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve:
• physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing; or
• non-contact activities include involving children in looking at or producing sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline

Neglect

• The persistent failure to meet a child’s basic physical and/or psychological needs likely results in severe impairment of the learner’s health or development.
• Neglect may occur during pregnancy, for example, because of maternal substance
• Once a child is born, neglect may involve a parent or carer failing to:
• provide adequate food, clothing and shelter (including exclusion from home or abandonment);
• protect a child from physical and emotional harm or danger;
• ensure adequate supervision (including the use of inadequate caregivers); and/or
• provide access to appropriate medical care or
• This abuse may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Child on Child Abuse

Child on Child abuse may take different forms, such as:

All concerns relating to Child on Child abuse must be reported to the Designated Safeguarding Lead, who will liaise with internal and external parties to ensure that both the instigator of the abuse and the subject of the abuse are supported.

Children who abuse others may be abuse victims themselves, and the learner protection procedures will be followed for victims and perpetrators. In addition, we will work with others to ensure that victims and perpetrators are supported and protected, especially from bullying and harassment.

We have a zero-tolerance approach to abuse, and it should never be passed off as “banter”, “just laughing”, or “part of growing up”, as this can lead to a culture of unacceptable behaviours and an unsafe environment for learners.

Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)

Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in sexual or criminal activity in exchange for something the victim needs or wants and for the financial advantage or increased status of the perpetrator or facilitator and through violence or the threat of violence. CSE and CCE can affect children regardless of gender and include children who have been moved (commonly referred to as trafficking) for exploitation.

Child Criminal Exploitation (CCE)

Child Criminal Exploitation of children is a form of harm which:

• can affect any child or young person (male or female) under the age of 18 years;
• can affect any vulnerable adult over the age of 18 years;
• can still be exploited even if the activity appears consensual;
• can involve force and enticement-based methods of compliance and is often accompanied by violence or threats of violence; and
• can be perpetrated by individuals or groups, males or females, and young people or adults.

CCE is typified by some power imbalance favouring those perpetrating the exploitation. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors, including:

• gender;
• cognitive ability;
• physical strength;
• status; and
• access to economic or other

It is important to note that the experience of criminally exploited girls can differ greatly from that of boys. It is also important to note that boys and girls being criminally exploited may be at higher risk of sexual exploitation.

Child Sexual Exploitation

• A form of sexual abuse which occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and (b) for the financial advantage of the increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual.
• Child sexual exploitation does not always involve physical It can also occur with technology.
• Child sexual exploitation is a serious crime and can have a long-lasting adverse impact on a child’s physical and emotional health. It may also be linked to child

Domestic Abuse

Domestic abuse can encompass many behaviours and maybe a single incident or pattern. That abuse can be, but is not limited to:

• psychological;
• physical;
• sexual;
• financial; and/or
• emotional.

Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and suffer domestic abuse in their intimate relationships (teenage relationship abuse). All of this can have a detrimental and long-term impact on their health, well-being, development, and learning ability.

Mental Health

• A person’s condition regarding their psychological and emotional well-being.
• It affects how we think, feel, and It also helps determine how we handle stress, relate to others, and make choices.
• Positive mental health allows people to:
  • realise their full potential;
  • cope with the stresses of life;
  • work productively; and
  • make meaningful contributions to their communities.

Serious Violence

The following indicators may signal children are at risk from or are involved with, serious violent crime. These may include:

• increased absence from education;
• a change in friendships or relationships with older individuals or groups;
• a significant decline in performance; and/or
• signs of self-harm, a substantial change in well-being, or signs of assault or unexplained injuries.
• Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk of illegal exploitation.

Honour Based Violence

So-called ‘honour-based’ violence encompasses crimes committed to protect and defend the honour of the family and the community. These crimes should be handled as part of existing safeguarding/child protection structures, policies and procedures. The following practices are illegal in England:

• Female Genital Mutilation: Honour-based violence includes the physical act of Female Genital Mutilation (FGM). This is a form of child abuse and a method of violence against women and girls recognised by UNICEF as an internationally recognised human rights violation. Tutors are alert to the mandatory reporting requirement for suspected cases of FGM in England, Wales and Northern Ireland.
• Forced Marriage: A forced marriage is entered without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter a marriage. Hazards can be physical or emotional and psychological. A lack of free and full consent can be where a person does not consent or cannot (if they have learning disabilities, for example). Forcing a person into a marriage is a crime in the United Kingdom. Tutors can contact the Forced Marriage Unit for advice or information: contact +44 (0)20 7008 0151 or email fmu@fco.gov.uk.

Private Fostering

Private fostering is when a parent decides for their child (under 16 or 18 if they are disabled) to live with someone who isn’t an aunt/uncle, grandparent, brother/ sister or stepparent for longer than 28 days. The person asked to look after the learner is a private foster carer. Education providers have a legal duty to tell the relevant Local Authority if it becomes aware of any private fostering arrangement in the UK or suspects that a child is subject to a private fostering arrangement in the UK. The Local Authority can then check that the child is safe and well looked after and that the accommodation and care are satisfactory.

Looked After child

A looked-after child is a child who is looked after by a local authority, subject to a care order or which is voluntarily accommodated by a local authority, commonly due to abuse or neglect. All tutors should understand how to keep a child looked after safely. When a tutor member is responsible for a looked-after child, they will be provided with the information they need about the learner’s legal status, care arrangements and the level of authority delegated to the cases by the local authority looking after him. The Designated Safeguarding Lead takes the lead on all looked-after learners and, in the UK, will hold details of and liaise with the learner’s social worker.

Signs and Indicators

All tutors should be aware of indicators of abuse and neglect (see below), understanding that learners can be at risk of harm inside and outside of education, inside and outside of the home and online. Exercising professional curiosity and knowing what to look for is vital for the early identification of abuse and neglect so that tutors can identify cases of learners needing help or protection. In addition, all tutors should be aware that abuse, neglect, and safeguarding issues are rarely standalone events and cannot be covered by one definition or label alone. In most cases, multiple issues will overlap with one another.

When identifying abuse, tutors should be mindful of the need to consider the context of the culture, law and guidance of the relevant jurisdiction of the learner. It is essential to consider whether the learner, their family and their society view the behaviour as unacceptable, as this will determine whether the learner views the behaviour as abusive. Tutors should report the behaviour in line with expectations of conduct in the UK. In determining the following steps, the cultural context of the learner or learners involved will always be considered. For situations outside the UK, we bring expert advice to ascertain what is and is not acceptable in the specific country and will consider the potential impact of reporting such concerns concerning the learner and their family.

The tutors are responsible for reporting all worries or concerns over safeguarding and welfare. They are not responsible for investigating or deciding whether a learner has been abused. A learner who is being used or neglected may:

• be reluctant to turn on their webcam;
• have visible bruises, bleeding, burns, fractures or other injuries;
• show signs of pain or discomfort;
• look unkempt and uncared for;
• have difficulty in making or sustaining friendships;
• appear fearful;
• be reckless regarding their own or other’s safety;
• self-harm;
• show signs of not wanting to be at home;
• display a change in behaviour – from quiet to aggressive, or happy-go-lucky to withdrawn;
• challenge authority;
• become disinterested in their education or have significant declines in performance;
• be constantly tired or preoccupied;
• be involved in, or exceptionally knowledgeable about drugs or alcohol; and/or
• display sexual knowledge or behaviour beyond that normally expected for their age.

Tutors or volunteers may also see or hear something in the background when interacting online, which raises concerns. Any concerns should be reported even if there is no conclusive evidence of abuse.

Legal Framework and Related Policies and Procedures

This policy is complementary to several existing policies and practices mentioned below. In general, where any reference is made to the physical world in these documents, this will apply in the same way in the online world or as near to it as is reasonably foreseeable and possible.

• Code of conduct
• Health and safety policy
• Social media safeguarding guidelines
• Information Technology Acceptable Use
• Information Security
• Safer Recruitment Policy & Procedure
• Safeguarding Statement
• Safeguarding Standards

Review Dates

We review our Policy at least every year to ensure that our commitments remain relevant to the nature of operations and practices.

Signature:

Desmond Gallagher, District Tuition Safeguarding Lead        

Date: 1 March 2023

Procedures

Responding to Concerns

We track any concerns reported and use these to help build up a better understanding of learner welfare. We act on identified problems and provide early help to prevent situations from escalating.

 

SERIOUS INCIDENT	SAFEGUARDING CONCERN	WELFARE CONCERN
OVERVIEW An incident which either took place as part of a District Tuition service we deliver online or face to face or in the community, or the family • A learner is at risk of or has experienced significant harm • A crime has been committed • May result in reputational risk to the organisation	OVERVIEW A concern which: • requires learners’ welfare to be monitored • Has been raised by the third-party asking District Tuition to be mindful of needs and provide support	OVERVIEW A concern which: • Can be actioned immediately and requires no ongoing actions • A historic safeguarding concern which has come to our attention through a third party
STEPS TO TAKE • A person identifying incident reports to emergency service if concerned someone is at immediate risk of harm • The incident was reported to the Global safeguarding team immediately • Concern recorded on the Safeguarding form • Global Safeguarding team screens the form to ensure the correct category of concern. • Global Safeguarding team organises internal strategy meetings on the same day as the report made (per profound incident guidance) to collate all information and agree on the next steps, including referrals to external agencies/organisations. • Safeguarding Lead completes Risk Assessment and/or support plan if required. • If an allegation is made against a tutor, the Global safeguarding team coordinates the response. • Global Safeguarding Lead records on incident reporting platforms (for example, CPOMS, PRISM, CONNEXUS) and ensures all fields are complete, actions agreed noted, and all related communication/documents uploaded. • Global Safeguarding Lead instructs on actions required • Record actions are taken, and all related documents are uploaded • The safeguarding team ensures that all follow-up actions completed	STEPS TO TAKE • Concern recorded on Safeguarding report form or ticket • Safeguarding Lead screens form to ensure correct category of concern, ensure no further information required • Safeguarding Lead records on incident reporting platform (for example, CPOMS, PRISM, CONNEXUS) and ensuring all fields are complete and actions agreed noted, and all related communication/documents uploaded • Safeguarding Lead instructs on measures required • Safeguarding Lead completes Risk Assessment and/ or support plan if required. • Incident recording platform is updated to record actions taken, adds any additional communication/ documents. • Safeguarding Lead closes case when concern no longer exists and all actions complete	STEPS TO TAKE • Concern recorded on Safeguarding report form or ticket • Safeguarding Lead screens form to ensure correct category of concern, ensure no further information required • Safeguarding Lead records on incident reporting platform (for example, CPOMS, PRISM, CONNEXUS) and ensures all fields complete and actions agreed noted, and all related communication/documents uploaded • Safeguarding Lead instructs on actions required • Incident recording platform updated to record actions taken, adds any additional communication/ documents • Safeguarding Lead closes case when all actions complete
EXAMPLE INCIDENTS • Death of a Learner, including suicide • Where a learner is alleged to have seriously harmed themselves or another person • Serious concerns that a learner is engaged in extremist behaviour • Serious or protracted bullying, • Serious sexual abuse or harassment • District Tuition tutors, associate or person acting on behalf of District Tuition is alleged to have caused harm, sexual or otherwise to a District Tuition learner/child/ vulnerable adult	EXAMPLE INCIDENTS • Low level mental health (self-managed) • Concerns around changes in appearance • Concerns around changes in and/or inappropriate behaviour • Concerns around changes in communication and/or inappropriate verbal comments • Concerns around digital footprint • Accumulation of low-level concerns	EXAMPLE INCIDENTS • Learner conduct/low level behaviour concerns • Relationship issues with peers • Challenging behaviours with tutors • Concerns around learner which are inconclusive

**Your responde, such as age and of concern, should depend on the learner's vulnerability, such as age and additional support needs.

13

If you suspect that a learner may be at risk but have no ‘real’ evidence, where possible you should allow the learner to talk. It is fine to ask the learner if he or she is okay, or if you can help in any way. Following an initial conversation with the learner, if you remain concerned, you should discuss your concerns with the DSL.

Responding to Immediate Danger

If you believe a learner is in immediate danger or is at risk of harm, you must take appropriate action to address this. This could include:

• Contacting the learner’s leading education provider
• Calling the police or emergency services where the learner is resident 
• Contact Parents (where appropriate and only if this will NOT increase the level of risk)

When reporting any such concern, you should ensure that the external parties, including parents, police, or emergency service agencies, give you feedback on what actions they will take.

After taking initial action, speak to the Designated Safeguarding Lead. A written record of concern should be completed and submitted to the Safeguarding Lead. Any verbal contact with external parties should be followed up in writing within 24 hours; the Safeguarding Lead will liaise with you on this.

Responding to Crimes

If you believe a crime has been committed, you should report this to the Safeguarding Lead, who will escalate further.

Recording Concerns

All concerns and correspondence will be kept in a secure, confidential safeguarding case management system. The learner’s circumstances will be reviewed, and external organisations will be made aware again if in the learner’s best interest. All concerns, discussions, decisions made, and the reasons for those decisions are recorded in writing. We use PRISM online system to keep safeguarding and pastoral records.

Records should include the following:

• The date and time of the incident
• The date and time of the disclosure of the incident
• The date and time the form is being made
• The name, role, and contact details of the person the concern was reported initially to
• The name, role and contact details of the person making the report (if this is not the same person as above)
• The name, age and other relevant information about the learner, young person or vulnerable adult who is the subject of the concern
• The names of all parties involved in the incident, including any witnesses
• What was said and done and by whom
• Any action taken to investigate the matter and any further action taken (such as referrals)
• If appropriate, the reasons why the matter was not referred to statutory agencies

Tutors should only record the facts as the learner presents them; the notes should not reflect the opinion of the note-taker. Tutors should be aware that notes of such reports could become part of an assessment by social care and a criminal investigation.

Tutors can escalate a concern by reporting it directly to the District Tuition’s Director of Safeguarding or the Safeguarding Manager. If, after escalation, they remain concerned, they should inform their concern via one of the following means:

• reporting to Children’s Services or equivalent organisation local to the local authority or region in which the learner is resident; or
• reporting to the NSPCC

If a Learner Makes a Disclosure

It takes courage for someone to disclose that they are being or have been abused. However, all victims must be reassured that they are being taken seriously, regardless of how long it has taken them to come forward and that they will be supported and kept safe.

If a learner talks to you about any risks to their safety or well-being, you should:

• allow them to speak freely and not be afraid of pauses or silences;
• remain calm and avoid overreaction;
• offer reassurance and general words of comfort;
• not ask investigative questions, but relatively prompt, if necessary, with open questions – where, when, what, tell, explain, describe If appropriate, tutors can ask learners if they have been harmed and what the nature of that harm was;
• recognise that trauma can impact memory and so learners may not be able to recall all details or timeline of abuse;
• explain at an appropriate time that, to help, and the information must be passed on to relevant people in positions of responsibility;
• not reprimand the learner for failing to disclose earlier; and
• establish the following steps (agree to talk with the Designated Safeguarding Lead and let the learner know someone will contact them).

After a disclosure, seek support if distressed. The learner should never be given the impression that they are creating a problem by reporting abuse. Nor should a learner ever feel ashamed for making a report. Abuse that occurs online or outside of education should not be downplayed and should be treated equally seriously.

Securing Evidence

If an incident takes place, you have a concern, or disclosure is made, the following files should be secured:

• The recording of any online sessions relating to the concern
• Any written communication related to the incident online (chats, whiteboards )
• A copy of any assessment or exam paper if relates to the concern
• Any emails related to the concern
• Any written reports

These files should be passed to the Designated Safeguarding Lead, who will ensure they are copied onto the learner's child protection file, separate from their academic record.

Supporting our Learners

We recognise that learners who have experienced trauma, have a mental illness or have experienced or are at risk of abuse or neglect can find it challenging to develop a sense of self-worth and may feel helplessness, humiliation, and self-blame. Therefore, our culture, ethos and policies are designed to provide an environment supporting our learners.

Missing Learners

We recognise that a learner going missing from education could indicate abuse or neglect, including sexual and sexual exploitation. Therefore, tutors will respond promptly to absences. Missing is defined as anyone whose whereabouts cannot be established will be considered missing until located and their well-being or otherwise confirmed. Any concerns that a learner needs to be included should be reported to the Safeguarding Lead, who will inform all relevant parties.

Prevent and Radicalisation

We recognise our duty to help prevent young people from being drawn into extremist viewpoints and radicalisation. In the UK, the Prevent Duty is the duty in the Counterterrorism and Security Act 2015 on specified authorities, including providers, to have due regard to the need to prevent people from being drawn into terrorism.

There is no single way of identifying an individual susceptible to radicalisation. Still, there are several early indicators of radicalisation or extremism, which may include:

• showing sympathy for extremist causes;
• glorifying violence, especially to other faiths or cultures;
• making remarks or comments about being at extremist events or rallies;
• evidence of possessing illegal or extremist literature;
• advocating messages from criminal organisations or other extremist groups;
• out of-character changes in dress, behaviour and peer relationships;
• secretive behaviours, including online searches or sharing extremist messages or social profiles;
• intolerance of difference, including faith, culture, gender, race or sexuality;
• artwork or writing that displays extremist themes;
• attempts to impose extremist views or practices on others;
• verbalising anti-Western or anti-British opinions; and
• advocating violence towards

Tutors with concerns about a learner will inform the Designated Safeguarding Lead (DSL) at the earliest opportunity. The Designated Safeguarding Lead (DSL) will then judge the most appropriate action.

For learners in the UK, the Designated Safeguarding Lead (DSL) may make a referral to the Channel programme, which is a programme that focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. For learners overseas, an equivalent organisation may be recognised. We will work more generally to ensure the fundamental British values of democracy, the rule of law, mutual respect and tolerance are celebrated and not undermined.

Non-emergency advice for tutors is available via the DfE’s helpline at +44 (0)20 7340 7264 and by email at counter-extremism@education.gsi.gov.uk

Online Safety

Considering the 4Cs (content, contact, conduct and commerce), we provide a range of interventions to keep learners safe online. For example, we think many learners have unlimited and unrestricted access to the internet via mobile phone networks. This access means some learners could be at risk of sexual harassment and bullying and can control others via their mobile and innovative technology, share indecent images consensually and non-consensually (including via large chat groups) and view and share pornography and other harmful content.

• We communicate the importance of learners being safe online.
• We share what learners are being asked to do online, including the sites they will be asked to access and be clear about whom they will interact with online.
• We ensure appropriate filters and monitoring systems are in place and regularly review their effectiveness.

• Leaders consider the age range of our learners, the number of learners and how often they access the IT system.
• We ensure we have the appropriate security protection procedures to safeguard our systems, tutors and learners. In addition, we review the effectiveness of these procedures periodically to keep up with evolving cybercrime technologies.
• We regularly review our approach to online safety, supported by risk assessments that consider and reflect the risks our learners face.

Anti-Bullying

We will make sure our response to incidents of bullying considers the following:

• research and resources
• the needs of the person displaying bullying behaviour
• needs of any bystanders
• our organisation as a whole.

We seek to prevent bullying through the following:

• Our codes of conduct
• Holding regular discussions with tutors, teachers, learners, young people and families who use our organisation about bullying and how to prevent it
• It provides support and training for all tutors on dealing with all forms of bullying, including racist, sexist, homophobic, transphobic, and sexual bullying.

Recruiting the Right People

District Tuition is committed to safeguarding and promoting the welfare of children, young people and vulnerable adults and expects all staff to share this commitment.

When undertaking any recruitment process, District Tuition will take the following steps:

• All job descriptions and person specifications will include a specific reference to suitability to work with children and young people and refer to the responsibility for safeguarding and promoting the welfare of children and young people.
• Comprehensive information from applicants will be obtained and scrutinised, and any discrepancies or anomalies will be investigated and resolved.
• Independent professional and character references relating to an applicant’s suitability to work with children and young people will be obtained.
• A face-to-face interview will be held with all successful applicants before engagement.
• The successful applicant's identity, qualifications and previous employment history will be verified before the appointment.
• A check will be made to confirm the right of the successful applicant to work in the United Kingdom before the appointment.
• Where the successful applicant has lived outside the United Kingdom, further checks considered appropriate will be carried out before the appointment.
• A check will be made on the successful applicant’s mental and physical health.
• A check of the relevant mandatory lists (set out below) and a disclosure (currently DBS) check will be carried out regarding the successful applicant before an appointment.
• Any offer of employment or engagement will be made conditional upon the satisfactory completion of the above checks and verifications.

District Tuition will ensure that:

An individual will not be recruited to be our tutors where they are named on any of the following lists:

• The Protection of Children Act (PoCA) List (England and Wales);
• List 99 (England and Wales);
• The Protection of Vulnerable Adults (POVA) List (England and Wales);
• The Disqualified from Working with Children List (DWCL - Scotland);
• The Disqualification from Working with Children List (Northern Ireland); and
• The Disqualification from Working with Vulnerable Adults List (Northern Ireland).

An individual appointed and subsequently found to be named on any of these lists will be removed from the position.

An individual will be referred to the appropriate List where the grounds for referral under the Acts are met.

A disclosure check will be carried out on all new employees, and further disclosure checks will be carried out periodically during their tenure (disclosure checks being conducted by the relevant legislation in force from time to time; currently via the Criminal Records Bureau (CRB) in England, Wales and Northern Ireland and by Disclosure Scotland in Scotland).

District Tuition will obtain a DBS check for all teachers, tutors, assistants or other staff before employment (if not employed elsewhere with a current statement) or during the first month of their engagement if they are already used and hold a DBS check elsewhere.

Confidentiality and Data Sharing

We recognise that all matters relating to child protection are sensitive and confidential. Information is shared only on a ‘need to know, what and when’ basis. Concerns about individuals should never be discussed elsewhere, inside or outside the educational provision, unless in confidential meetings to safeguard. This is to respect any individuals involved and ensure that information released into the public domain does not compromise evidence.

Child protection information will be stored and handled per the Data Protection Act 2018 principles. Information is processed for limited purposes; it is adequate, relevant, and not excessive. It is accurate; kept no longer than necessary; processed by the data subject’s rights; and secure. Learner protection records will be stored securely online in a partitioned limited access area of the network and only made available to relevant individuals. Learner protection records are generally exempt from the disclosure provisions of the Data Protection Act. This means that learners and parents do not have an automatic right to see them. If a tutor receives a request from a learner or parent to see learner protection records, they will refer the request to the DSL, who will be guided by advice from the Data Privacy Officer.

Whistleblowing

Tutors can raise concerns when they suspect past, present, or imminent wrongdoing or an attempt to conceal misconduct. Officially this is called ‘disclosing the public interest’. We encourage all tutors who have concerns about wrongdoing or malpractice involving any aspect of our work to feel able to come forward and voice these without fear and in confidence. Considerations must be raised as soon as possible to allow the opportunity to address and resolve any problems quickly.

The concern should, in most instances, be raised with the tutors’ line manager though the problem must be presented with the person best placed to deal with the matter and with whom the employee feels most comfortable. There may be certain rare occasions, however, when it would be inappropriate to raise the concern with the line manager because, for example, the concern:

• May implicate the manager in some way
• is about a senior manager within the line management chain or somewhere else in the department
• is particularly serious and needs to be dealt with urgently.

Once a tutor meeting has been raised, a concern may be arranged with them to determine how the situation should be resolved. Under this procedure, all investigations will be conducted sensitively and quickly. The study should be concluded within three months of the matter being raised, though some scenarios may result in a longer timeframe.

Concerns or Allegations Relating to Tutors

When an allegation is made against a tutor working for or on behalf of District Tuition or a concern is expressed about their conduct relating to learners, set procedures must be followed. It is rare for a learner to make an entirely false or malicious allegation. However, misunderstandings and misinterpretations of events can happen, and a learner may make an allegation against an innocent party because they are too afraid to name the perpetrator.

Reporting concerns

A tutor concerned about a colleague's conduct towards a learner must remember that the learner's welfare is paramount. No member of the tutors will suffer a detriment for raising a genuine concern.

Allegations or concerns against members of tutors, including the DSL, should be reported directly to the District Tuition Global Director of Safeguarding or a Global Safeguarding Manager. Tutors may also report any allegations or concerns directly to the police if they believe direct reporting is necessary to secure action and they feel a crime has been committed. Tutors may additionally use the NSPCC whistleblowing helpline number, 0800 028 0285, if they think that tutors' conduct may not have passed the threshold for a criminal offence but raise concerns which are not being addressed within the internal reporting mechanisms. Allegations against a former tutor no longer working for us should be referred to the police.

Reports can be made verbally but should be supported by a dated and timed note of what has been disclosed or noticed, said or done.

The case manager in Global Safeguarding must log the incident before the end of the day. It is vital that expressions of concern that do not necessarily amount to ‘allegations’ are reported, mainly if there are repeated reports of such problems and questionable conduct.

It may be that the concern expressed has been raised by another party. If there are repeated reports of such problems and questionable conduct, a pattern of unacceptable behaviour may be identified.

Threshold for concerns

We accept that some professionals can pose a severe risk to learners, and we will act on every allegation or concern that a person working with or who is in contact with learners may have:

• behaved in a way that has harmed a learner or may have broken a learner;
• possibly committed a criminal offence against or related to a learner;
• behaved towards a learner or learners in a way that indicates they may pose a risk of harm to learners; and/or
• behaved or may have acted in a way that may not be suitable to work with learners (including behaviour that might have happened outside of the learning environment).

Responding to low-level concerns

A low-level concern is when behaviour is inconsistent with the tutor's code of conduct, including inappropriate behaviour outside of work, but when this behaviour does not meet the harm threshold set out above.

Examples of such behaviour could include, but are not limited to:

• being over-friendly with learners;
• having favourites;
• engaging with a learner on a one-to-one basis without recording the meeting; and
• using inappropriate sexualised, intimidating or offensive language.

Sharing low-level concerns is vital to create and embedding a culture of openness, trust and transparency in which our values and expected behaviour, as set out in the tutor's code of conduct, are constantly lived, monitored and reinforced by all tutors. Sharing concerns includes self-referral, where, for example, a tutor member may have found themselves in a situation that could be misinterpreted, might appear compromising to others, and/or, on reflection, believe they have behaved in such a way they consider falls below the expected professional standards.

Where a low-level concern is raised, this will be dealt with promptly and appropriately. A record of the problem will be kept allowing any patterns of unacceptable behaviour to be identified. To address low-level concerns, we will:

• ensure tutors are clear about what appropriate behaviour is and are confident in distinguishing expected and proper conduct from concerning, problematic or inappropriate behaviour in themselves and others;
• encourage tutors to share any low-level safeguarding concerns;
• address unprofessional behaviour and support the individual to correct it at an early stage;
• provide a responsive, sensitive and proportionate handling of such situations when they are raised; and
• monitor low-level concerns to help identify any weaknesses in the safeguarding system.

Responding to crimes that reach the threshold

Suppose an allegation meets the abovementioned criteria under the ‘Threshold for Concerns’ section. In that case, it will be dealt with according to the statutory guidance in Keeping Learners Safe in Education (DfE, September 2022).

Tutors, parents, and members of the Governing Body are reminded not to investigate the matter themselves, make assumptions or offer alternative explanations for behaviours, or promise confidentiality to the alleged victim(s).

On receiving a reported concern, the case lead will proceed as follows:

• If there is no written record, write a dated and timed note of what has been disclosed or noticed, said or done.
• Notify the Local Authority Designated Officer (LADO) within 24 hours and send copies of any documentation concerning the
• Liaise with the LADO and cooperate with the investigating agencies as appropriate.
• Consider employment issues and possible disciplinary action where the investigating agencies take no further action.

The Education Act 2011 prohibits the publication of material that may lead to identifying a tutor who is the subject of an allegation. ‘Publication’ includes verbal conversations or writing, including content placed on social media sites. We will always comply with the provisions of the Act.

Managing Allegations

Upon receiving an allegation or concern about a tutor, the case manager will immediately discuss the allegation with the LADO. The purpose of an initial discussion is for the LADO and the case manager to consider the allegation's nature, content and context and agree on a course of action.

In the process of this liaison, the case manager and LADO will:

• share what information is available, both from the source of the allegation and also from Personnel files;
• identify what other information might be needed;
• consider whether the alleged perpetrator should continue working or remain in contact with learners;
• think whether suspension is appropriate;
• decide what information and/or advice is to be given to the case manager, including whether tutors should be informed of the allegation at this stage; and
• decide what action is needed and who needs to be involved and informed (including the Disclosure and Barring Service [DBS] and/or Teaching Agency).

Decisions about the course of action are taken on a case-by-case basis, bearing in mind the paramount importance of the safety of any learner(s) involved but also remembering that tutors, against whom an allegation has been made, has the right to remain anonymous and to expect any allegations to be investigated as expeditiously as possible.

Any course of action is subject to a risk assessment. Decisions would also follow the guidance of the LADO and/or police. Suppose the parties involved in these discussions consider it necessary. In that case, a Strategy Meeting is arranged, usually by Social Services, which will include representatives from the LADO, the police and the provider (e.g., the Principal, DSL or Chair of Management Board, as appropriate).

From the above discussions, there are three possible courses of action:

• It may be the subject of a police force and/or joint police and Social Services investigation and possible activity through the courts; or
• It may be the subject of a disciplinary investigation; or
• The matter may be remitted to the provider to be dealt with.

The following definitions will be used when determining the outcome of allegation investigations:

• Substantiated: there is sufficient evidence to prove the allegation
• Malicious: there is enough evidence to disprove the allegation, and there has been a deliberate act to deceive
• False: there is enough evidence to disprove the allegation
• Unsubstantiated: there is insufficient evidence to prove or disprove the allegation; therefore, the term does not imply guilt or innocence 
• Unfounded: to reflect cases without evidence or reasonable basis supporting the allegation.

If Social Services and the police decide to take no action, we will still need to consider what further investigation is necessary. If there is a case to answer, a disciplinary hearing will be called, which could lead to dismissal.

Where a criminal investigation has taken place and either (i) a trial has resulted, (ii) the investigation has been closed without charge, or (iii) a decision has been taken not to prosecute a case after charge, the case manager will discuss with the LADO what, if any, further action is required as regards the tutors concerned and the sharing of information obtained by the agencies involved in assisting any further action to be taken by us.

Where a disciplinary investigation is required, the study should be conducted by our disciplinary procedure. ‘Settlement agreements’ (by which contract a person agrees to resign, we decide not to pursue disciplinary action, and both parties.

Agree on a form of words to be used in any future reference), will not be used in these cases.

Supporting those involved

Every effort will be made to maintain confidentiality and guard against publicity while an allegation is being investigated or considered. Apart from keeping the learner(s), appropriate external parties and the person about whom the allegation has been made (in cases when this would not place the learner at further risk) up to date with the progress of the case, information should be restricted to those who need to know to protect learners, facilitate enquiries or manage related disciplinary processes. As a tutor, we have a duty of care towards our tutors. District Tuition will ensure adequate support for anyone facing an allegation and provide a named contact if they are suspended.

Social contact with colleagues will only be prevented if evidence suggests that it is likely prejudicial to the gathering and presenting of evidence. The deliberations of a disciplinary hearing, and the information taken into account in reaching a decision, cannot normally be disclosed, but relevant parties will be told the outcome.

Action upon conclusion of a case

We will refer to the DBS (following consultation with the LADO) any person who has been removed from working (paid or unpaid) in regulated activity or would or might have been so removed had he/she/they not resigned or left his/her/their own accord. This is because it believes the person may have harmed, attempted to break, incited another to damage or put a learner at risk of harm or if there is reason to believe the person may have committed one of several offences listed under the Safeguarding Vulnerable Groups.

Act (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009. ‘Removal from working’ for these purposes will include dismissal, non-renewal of a fixed term contract, no longer using a supply teacher engaged directly or supplied by an agency, terminating the placement of a trainee or volunteer, no longer using tutors employed by a contractor and resignation or voluntary withdrawal from any of the above.

In cases where it is decided on the conclusion of the possibility that a person who has been suspended can return to work, we will consider how best to facilitate this. We appreciate that most people would benefit from help and support when returning to work after a stressful experience. Depending on the individual’s circumstances, a phased return and providing a mentor to aid and support in the short term may be appropriate. We will also consider how the person’s contact with the learners who made the allegation can best be managed if they still attend the educational provision.

Suppose an allegation is determined to be false. In that case, the manager may refer the matter to Children’s Services to determine whether the learner needs services or may have been abused by someone else. On the other hand, suppose an allegation is shown to have been deliberately invented or malicious. In that case, District Tuition will inform the leading education provider, who can consider whether any disciplinary action is appropriate against the learner who made it.

A referral will be made to the Teaching Regulation Agency (TRA) via the GOV.UK website where a teacher has been dismissed (or might have been dismissed had they not resigned), and a prohibition order may be appropriate. The reasons such an order would be considered are ‘unacceptable professional conduct’, ‘conduct that may bring the profession into disrepute’ or a ‘conviction, at any time, for a relevant offence’.

Records

A central record of all allegations and concerns (and related documents) against tutors will be kept securely, separate from regular tutors' and learners' records, and with access limited to the DSL and DDSL, as well as District Tuition Human Resources representatives and officers who may be critical workers for cases.

The only exception to this requirement for permanent recording is where allegations are malicious. In such cases, all records will be removed from the tutor's personnel files.

The record of allegations may clarify cases where a future DBS disclosure reveals information from the police about an allegation that did not result in a criminal conviction. It will also help to prevent unnecessary re-investigation if, as occasionally happens, an allegation resurfaces after a period. The record will be retained until the tutors involved have reached the average retirement age or for ten years from the allegation date if that is longer. An allegation proven false, unsubstantiated or malicious will not be included in references for tutors. However, where there have been concerns about a tutor, and they leave us to work elsewhere, the District Tuition Global Director of Safeguarding will consider passing the references to the new employer or authority. If applicable, we will pass on allegations or concerns affecting a learner to their next provider.

Learner Code of Conduct

We expect that all learners are responsible for their behaviour. We expect all learners to participate positively in their educational provision and gain from experience. All learners are expected to:

• ensure a neutral background when on video;
• treat tutors and their peers with respect and fairness;
• not make any improper suggestions towards tutors or their peers during their sessions or through their online communications;
• not send a ‘friend’ or ‘follow’ request to their tutors via social They will refrain from asking tutors to disclose their personal information, such as their address or phone number, and
• be responsible for the security of their login details to the platform and any communication sent from this They must not share their username and password or let someone else log into their account, assuming their identity.
• If learners feel their login details have been compromised, they must immediately change their password and report the situation.
• Learner on Learner abuse will not be tolerated.

Learners should always access their educational provision in a way that shows consideration and respect. Using obscene, profane, threatening, or disrespectful language is unacceptable. These behaviours will result in sanctions, and where appropriate, Safeguarding procedures will be initiated:

• sending or posting discriminatory, harassing, or threatening messages or images;
• stealing, using, or disclosing someone else's code or password without authorisation;
• sending or posting confidential material;
• violating copyright law;
• participating in the viewing or exchange of pornography or obscene materials;
• sending or posting messages that defame or slander other individuals;
• using the platform to promote radicalisation or any gambling;
• refusing to follow our rules;
• recording any session and transmitting it;
• not dressing appropriately (examples: dressed in revealing clothes, dressed in clothes with inappropriate sayings); and
• participating in cyberbullying and/or harassment.

Tutors Code of Conduct

We expect that all tutors are responsible for their behaviour. We hope that all tutors will always model professional behaviours. The safeguarding of Learners is paramount and takes precedence over all other considerations. All tutors are expected to:

• identify a suitable environment for meetings and any online interactions;
• discourage, where possible, learners from making video calls from their bedrooms;
• insist on appropriate clothing for all participants;
• ensure none of their items is visible in the background in online meetings;
• ensure distractions and disturbances are minimised;
• be conscious of confidentiality when working online;
• not engage in conduct (including other employment) which could reasonably be expected to damage the reputation and standing of the organisation;
• complete all relevant safeguarding training provided;
• treat all learners fairly and without prejudice, and treat learners and other tutors with respect;
• not make any improper suggestions towards any learner during their sessions or through their communications;
• not share their personal contact details with learners, including their mobile number, email address, social media, or gaming accounts. Tutors should, therefore, not accept any ‘friend’ or ‘follow’ requests from learners on their social media accounts; and
• Tutors should only share the link to an online meeting with the learners involved in the session.
• Tutors are responsible for securing their login details to the platform and any communication sent from their work Therefore, they must not share their username and password and must not let someone else log into their account, assuming their identity.
• If tutors are concerned their login details may have been compromised, they must immediately change their password and report the situation to the Designated Safeguarding Lead with the relevant information.
• Any instances where tutors feel their actions, or the actions of others, may have compromised the organisation, or their professional standing, should be recorded and reported to the Safeguarding Lead.

Although this Code of Conduct gives advice and instruction on dealing with specific situations, it should differ from professional common sense and good judgement. In all matters relating to learners/tutors relationships, tutors must consider how a third party might reasonably regard an action.

Accessing, Storing, and Retaining Learner Protection Records

Child protection records refer to concerns about a learner’s safety and welfare and possible risks posed by people working with learners, young people, and vulnerable adults. These documents will be stored separately from a learner, young person and vulnerable adults’ public documents and will be up to-date and relevant to the purpose for which they are held. These will only be kept for as long as necessary and destroyed when they are no longer relevant.

The files will only be accessed by those involved in the safeguarding procedures of the organisation. However, they will be made available to safeguarding agencies/the Police and the Designated Safeguarding Lead if necessary. In England, Scotland and Wales, the file should be kept for seven years or until the learner is 25 (this is seven years after they reach the provider leaving age) (Information and Records Management Society (IRMS), 2019).

In Northern Ireland, the government recommends keeping learner protection files until the learner’s 30th birthday (Department of Education, 2016).

If concerns have been raised about an adult’s behaviour around learners, the general rule is that we keep the records in their personnel file at least until they reach their average retirement age or for ten years. We keep records simultaneously, regardless of whether the allegations were unfounded. However, if the allegations are malicious, we destroy the form immediately.

Training and Development

We consider Safeguarding training essential for ensuring all Learners are protected. As such, all tutors will:

• receive Safeguarding training in their induction (this will include the use of the functionality of any online delivery platforms and specific online Safeguarding practices);
• receive Prevent training;
• read and understand Part 1 of Keeping Learners Safe in Education;
• read and understand our Safeguarding and Child Protection statement;
• receive regular emails and other communications updating them on new information, legislation etc.;
• undergo early Safeguarding update training; and
• receive training and workshops around specific themes

Designated Safeguarding Leads must complete the additional training below:

• Specialist Designated Safeguarding Lead training
• Topic-specific training

Recruiting managers

• All interview panels will contain at least one member trained in Safer Recruitment.

Organisational Structure and Governance

We have the following roles and responsibilities regarding Safeguarding: All tutors must:

• provide a safe environment where learners can learn;
• be prepared to identify learners who may benefit from early help; and
• follow the Safeguarding procedure when they have a Safeguarding concern.

The Designated Safeguarding Lead must:

• take the lead for Safeguarding;
• make the necessary links and referrals to other agencies and professionals;
• support and advise other tutors about Safeguarding;
• raise awareness of Safeguarding;
• encourage a culture of listening to learners and taking account of their wishes and feelings in any measure put in place to protect learners; and
• be available during our operating hours for tutors to discuss their Safeguarding concerns.

In addition to the above, all tutors can consult with District Tuition’s Safeguarding Leader and District Tuition’s UK Safeguarding Manager regarding any issue of Safeguarding.