FLYING COLOURS TUITION UK SAFEGUARDING POLICY

INTRODUCTION

Flying Colours Tuition UK exists to provide an introductory service between self-employed private tutors and prospective students, and to assist in sourcing experienced and reputable tutors for companies and institutions.

We do not maintain educational premises, and we do not hold or arrange events at which children are likely to be present. Many of the tutors we work with are self-employed, and are responsible for the conduct of their own tuition. The majority of the students using our services are in full-time education, and the majority of tuition arranged through our company takes place online.  

 

DEFINITIONS

“Child’ is defined as a person who has not yet reached their 18th birthday (i.e. is under 18)

“Adult at risk” is defined by the Care Act 2014 as an adult aged 18 or over who (a) has needs for care and support (whether or not the authority is meeting any of those needs), (b) is experiencing, or is at risk of, abuse or neglect, and c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.

The term “young person” is occasionally used as an additional term when describing children, in recognition that this is a widely-used term to describe those aged under 18 but over 16. 

SCOPE

This policy is intended to promote the welfare of children and adults at risk. It is also intended to act as a guide for the self-employed tutors we represent, introduce or work with in any other legitimate manner, to help them follow our approach to safeguarding.

This policy applies to anyone working with or on behalf of our company, including senior managers, directors, employees, contractors, volunteers and tutors. We expect any tutor, mentor, coach or other individuals who we introduce (including where we act as an employment agency) to comply with this policy, wherever possible and appropriate, and to take prompt and effective action in the event of a safeguarding concern arising.

LEGAL FRAMEWORK

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in United Kingdom. However, it is understood and intended that this policy will apply to our employees, agents, contractors and other connected parties wherever they work across the world. In this event, we expect the policy to be followed to the fullest extent permissible in any given jurisdiction, with the intention of safeguarding children and young people. Where we operate outside of the UK we undertake to:-

  • Comply with local laws, regulations, instructions from law enforcement agencies, rulings by any legitimate judicial authority or similar;

  • Refer any matters of criminal conduct, especially in relation to safeguarding, (as applicable in the local jurisdiction) to the local authorities responsible for policing and law enforcement;

  • Wherever local legislation permits, or is ambiguous or indifferent (for example, but not limited to, activity in disputed territories, activities ongoing during a change of government or political structure and activities taking place when local legislation is amended, added to or repealed), we undertake to follow this guidance to the fullest extent possible in order to safeguard children and adults at risk (according to the broadest definition applied by either local or UK legislation).

A summary of the key UK legislation and guidance is available from https://learning.nspcc.org.uk/safeguarding-child-protection/

SUPPORTING DOCUMENTS

This policy statement should be read alongside our Terms and Conditions and Privacy Policy, and the following policy documents, included as appendices:

We recognise that:

  • The welfare of children is paramount in all the work we do and in all the decisions we take.

  • Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.

  • All children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse.

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

  • Extra safeguards may be needed to keep children who are additionally vulnerable safe from abuse.

  • Adults may also be at risk, for a variety of reasons including (but not limited to) age and disability, and are deserving of the same care, attention and protection.

We will seek to keep children and young people safe by:

  • Valuing, listening to and respecting them.

  • Appointing a designated child protection lead for children and young people.

  • Adopting child protection and safeguarding best practice through our policies, procedures and code of conduct for staff and volunteers.

  • Developing and implementing an effective online safety policy and related procedures.

  • Providing effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all staff and tutors know about and follow our policies, procedures and behaviour codes confidently and competently.

Contact details 

Designated safeguarding lead: 

Name: Megan Whitehead

Role: Founder / English Tutor

Phone: 07506690833

Email: flyingcolourstuitionuk@gmail.com

 

NSPCC Helpline 

0808 800 5000 - Open 10am-4pm Monday to Friday

help@nspcc.org.uk - email 24 hours a day

If a child, young person, or any person is in immediate danger, call 999 (for a person in the UK).

This policy, and our good practice, will be reviewed annually.

This policy was last reviewed on: 24/10/2024

Signed: M.Whitehead


ROLE DESCRIPTION FOR THE DESIGNATED SAFEGUARDING LEAD

Purpose of the Role

  • To take the lead in ensuring that appropriate arrangements for keeping children and young people safe are in place at the company.

  • To promote the safety and welfare of children and young people involved in the company’s activities at all times.

Duties and responsibilities

  1. Take a lead role in developing and reviewing the company’s safeguarding and child protection policies and procedures.

  2. Take a lead role in implementing Flying Colours Tuition UK’s safeguarding and child protection policies and procedures: ensuring all safeguarding and child protection issues concerning children and young people who take part in Flying Colours Tuition UK’s activities are responded to appropriately.

  3. Make sure that everyone working with or for children and young people at Flying Colours Tuition UK including the board of directors, understands the safeguarding and child protection policy and procedures and knows what to do if they have concerns about a child’s welfare.

  4. Make sure children and young people who use the company’s services, and their parents, know who they can talk to if they have a welfare concern and understand what action the organisation will take in response.

  5. Receive and record information from anyone who has concerns about a child who uses the company’s services, and ensure reports are stored securely.

  6. Take the lead on responding to information that may constitute a child protection concern, including a concern that an adult involved with Flying Colours Tuition UK may present a risk to children or young people. This includes:

    1. assessing and clarifying the information - not investigating

    2. making referrals to statutory organisations as appropriate

    3. consulting with and informing the relevant members of the organisation’s management

    4. following the organisation’s safeguarding policy and procedures.

      7. Liaise with, pass on information to and receive information from statutory child protection agencies such as:

  1.  the Local Children's Safeguarding Partnership (LSCP)

  2. the Local Authority Designated Officer (LADO)

  3. the police.

2. This includes making formal referrals to agencies when necessary.

3. Consult the NSPCC Helpline when support is needed, by calling 0808 800 5000 (10am-4pm, Mon-Fri)  or emailing help@nspcc.org.uk.

4.  Store and retain child protection records according to legal requirements and the organisation’s safeguarding and child protection policy and procedures.

5.  Work closely with the company directors to ensure they are kept up to date with safeguarding issues and are fully informed of any concerns about organisational safeguarding and child protection practice.

6. Report regularly to the company directors on issues relating to safeguarding and child protection, to ensure that child protection is seen as an ongoing priority issue and that safeguarding and child protection requirements are being followed at all levels of the organisation. 

7.  Be familiar with and work within inter-agency child protection procedures developed by the local child protection agencies. 

8.  Be familiar with and work within inter-agency child protection procedures developed by any educational settings we work in (e.g. schools) and share these with Flying Colours Tuition UK staff working in those places - seeking the name and contact details of the safeguarding lead in the setting and how to report any concerns, then sharing this with Flying Colours Tuition UK staff before they start work. Make the setting aware that Flying Colours Tuition UK also have safeguarding policies and part of working together means that as well as reporting concerns to them, staff may make reports to Flying Colours Tuition UK as well, and these may be passed on to other authorities. Share DBS status of staff/volunteers with any settings they may go to work in - this should be made clear to all staff/volunteers when working for Flying Colours Tuition UK.

9. Be familiar with issues relating to child protection and abuse, and keep up to date with new developments in this area. 

10. Attend training in issues relevant to child protection and share knowledge from that training with everyone who works or volunteers with or for children and young people at Flying Colours Tuition UK. 

11.  Attend team meetings, supervision sessions and management meetings as arranged. 

RESPONDING TO CONCERNS ABOUT THE WELFARE OF A CHILD OR ADULT AT RISK

Flying Colours Tuition UK take safeguarding seriously and staff will be trained to notice signs where the welfare of a child or adult at risk may be at risk. Staff and volunteers for Flying Colours Tuition UK should report their concerns directly to the safeguarding lead flyingcolourstuitionuk@gmail.com. It is important to remember that perpetrators can be adults but they can also be other young people - there is no specific identity of a perpetrator.

Any concerns should be reported without delay to allow those reporting to make the most accurate report of what raised the concern - delaying making a report can lead to forgotten or altered details.

All concerns should include only the facts of what raised the concern. Assumptions or interpretations should not be included. For example, if a person was crying the report should state that they were crying, not that they were sad or upset as this is an interpretation of the situation.

If there are concerns about a child or an adult considered to be at risk or a disclosure is made by them, it should be taken seriously and listened to. It is important not to ask leading questions, any questions should be very open and not suggestive of anything. For example, if they say "[name] hurt me yesterday", responding "did they hit you?" would not be appropriate, but repeating back "how did they hurt you?" would allow the person to respond openly in their own words.

It is very important to never promise to keep things secret, or not to tell others. Instead, we should be open with children and adults at risk so that they can talk to us, but if we have concerns for their welfare, we might have to talk to others. It should be made clear that this will only be done with a view to keeping them safe and getting them support.

It is rare that we can be 100% sure that something is or is not taking place, but it is not our place to investigate. The role of those working with children is to be aware of the signs that welfare may be at risk and to report those concerns to those with the authority and experience in doing so - such as the Local Children's Safeguarding Partnership or the police. In this way, we safeguard children and allow any investigations to be done through the proper channels.

Who to report to

Who to report concerns to will depend on the situation.

Reports about concerns raised whilst working in the capacity of staff or volunteering with Flying Colours Tuition UK can be made directly to the safeguarding lead and deputy lead. This should be done by completing the form and sending it securely to the safeguarding email address (or handed directly to the safeguarding lead/deputy lead if seeing them in person).

If working through Flying Colours Tuition UK, but in a school, college or other educational settings, their internal safeguarding procedures should be followed and a report to Flying Colours Tuition UK should be made as normal. This should be shared with the safeguarding lead at the setting so that they are aware. 

Tutors who work with children or adults at risk - online or in person (including in a family-based residential setting) - are encouraged to report directly to the Local Children's Safeguarding Partnership LCSP) or Adult Safeguarding Board as appropriate where the child or adult at risk lives, and/or report to the NSPCC helpline on 0808 800 5000 (Mon-Fri, 10am-4pm). If the person they are concerned about lives abroad, they should try to contact the local authorities where that person lives as this is where the concern will need to be dealt with.

Note that there are some occasions where the police should be contacted, as well as reports being made. If there is reason to believe the child or adult at risk is in immediate danger, the police can be contacted. A report should be made in the usual way to safeguarding leads/bodies, but the police can be contacted in order to protect that person from harm.

If it is ever unclear about who to report to, or how, instead of leaving the concern unreported, it is important to check. For staff/volunteers of Flying Colours Tuition UK, this can be the safeguarding lead or deputy lead. For those who work for themselves, this can be checked with the NSPCC helpline.

STORING CHILD PROTECTION RECORDS

GDPR does not change the way child protection records should be stored. Flying Colours Tuition UK team will follow the guidance for storing data - outlined by the NSPCC.

When Flying Colours Tuition UK works with others (including children and adults at risk, and their carers), Flying Colours Tuition UK may collect and store data about these people in order to reasonably provide services.

Additionally, some data may be collected for the purposes of child protection - this is to protect the children concerned. It should be noted that in these cases, data may be shared with appropriate agencies or authorities such as the Local Children's Safeguarding Partnership (LCSP), or the police. This will only ever be shared for the purpose of safeguarding.

Personally identifiable data may be kept by Flying Colours Tuition UK for as long as is necessary and appropriate to carry out business and provide a service. After this time, as per GDPR, users can request their data be deleted. However, data relating to child protection may be kept for longer.

In such cases, Flying Colours Tuition UK will keep data for as long as is appropriate to retain the data. Generally, educational settings keep records until any person turns 25.

All physical records will be securely stored - locked away in a secure space that only the safeguarding team can access. And digital records will be stored in password-protected folders on computers with password protection and software to prevent hacking and viruses.

PREVENTING AND RESPONDING TO BULLYING

We recognise that bullying can take many forms. Anyone can engage in bullying behaviour and anyone can be bullied. It is important to remember that perpetrators can be adults but they can also be other children - there is no specific identity of a perpetrator.

When trying to prevent bullying, it is important to make it clear to others that we treat them equally and without judgement and to teach them that this is how everyone should be treated. Flying Colours Tuition UK staff and volunteers will always treat others, with respect - regardless of their identity.

If bullying is seen or disclosed it will be reported as a safeguarding concern to the relevant person. For example, the safeguarding lead at Flying Colours Tuition UK, or for the educational setting they are in.

KEEPING CHILDREN SAFE ONLINE

We recognise some of the work we do with children takes place online, and that keeping them safe online is equally as important as keeping them safe in person.

One of the key things Flying Colours Tuition UK does is to only ever interact with children using their services through agreed means and times - arranged through a responsible adult - for example, a parent or carer, or through a school representative. Note that an adult may have vulnerabilities but still be able to arrange their own tuition - this should be considered when booking.

Staff and volunteers of Flying Colours Tuition UK will not contact children using their services through social media platforms or through their own personal profiles. The only time staff or volunteers will talk to children through social media if they contact Flying Colours Tuition UK company profiles in order to seek support or ask about their services.

Flying Colours Tuition UK will also advise tutors connecting to families through Flying Colours Tuition UK to follow this guidance.

Flying Colours Tuition UK staff and volunteers will check all resources shared with or sent to children to ensure they are appropriate. Content should not include anything which could harm children or expose them to harm. For example, anything depicting illegal activity, violence or extreme views. 

If sensitive topics arise in educational content, resources will be carefully chosen and will be checked by other staff to ensure they are appropriate for purpose.

RECRUITING THE RIGHT PEOPLE TO VOLUNTEER OR WORK WITH CHILDREN

All staff and volunteers working with Flying Colours Tuition UK will be considered for recruitment without discrimination to their identity (race, sex, gender, age, disability, pregnancy/maternity, religious belief, or sexual orientation). 

Flying Colours Tuition UK engages in work with children - an enhanced DBS check is required by all employees and volunteers. This will be indicated in any advertisements.

Tutors connected to families through Flying Colours Tuition UK are directed to seek DBS checks.

Prior to the checks, applicants are required to provide at least two references who can be contacts. If the role is working directly with children, at least one referee should be for a role where the applicant has worked or volunteered with children.

Applicants will be given an opportunity to declare any prior convictions including any child protection investigations - regardless of their outcome. This can be written and delivered in a confidential way - for this to be reviewed by the safeguarding team at Flying Colours Tuition UK.

ID will be required from applicants to confirm identity - these should be viewed in person wherever possible as this helps to check the authenticity of the documents. Copies and prints outs will not be accepted - e.g. a printed online bank statement. If an in-person check is not possible, under the guidance in place since July 2021 this can be done via a video call. In both cases, the person checking the ID should be in physical possession of the original documents.

The criminal background checks required for staff and volunteers include:

  • A DBS check - note that an enhanced check is required for anyone who will or may have direct contact with children. These checks should be put on the update service so that Flying Colours Tuition UK can check their status periodically - if a check is not on the update service, a new one will be required every year.

  • An overseas police check for any staff of volunteers who have lived abroad in the past 5 years.

Please note that a DBS check is not used to check the right to work in the UK - this is done separately. 

CODES OF CONDUCT FOR ALL STAFF AND VOLUNTEERS IN RELATION TO SAFEGUARDING

All staff and volunteers working with Flying Colours Tuition UK are expected to follow the general code of conduct laid out by company policy.

With regards to safeguarding this includes:

  • Engaging with safeguarding policies laid out by Flying Colours Tuition UK - including attending training when it is offered.

  • Complete an enhanced DBS check as laid out in Flying Colours Tuition UK' safeguarding policy.

  • Treating all service users (regardless of age or other identifiers) with equal respect.

  • Not contact children from personal accounts - including online communication (e.g. emails and social media), or in person. 

  • If staff or volunteers have an existing personal relationship with any children or their families/carers, this should be declared to management and safeguarding staff as soon as is possible. We understand that not having contact with existing friends or family would not be possible, but by declaring any connections, we can be aware that communication may occur.

  • Staff and volunteers with Flying Colours Tuition UK must not have a sexual or romantic relationship with any child under the age of 18. They should also not start such a relationship with a service user when the user turns 18 after contact with them prior to their birthday. This could be considered an offence under the Sexual Offences Act 2003. 

  • Not being left completely alone with children. If there are occasions where staff/volunteers may be alone with a child, it is important that others should be notified (for example, other staff at Flying Colours Tuition UK, teachers/staff at an educational institution, or the parents/carers of the child). If there are other people in a building but not in the same room, the door should be left open where possible; where not possible (e.g. fire doors) the door should remain unlocked.

  • When tutoring children in their homes (online or in-person), the tutorials should ideally take place in a communal space (for example, a living room, kitchen or office) - this should ideally be a quiet and calm space, but one which others could access if they wanted to check-in. 

  • When tutoring children online, this should be arranged through a responsible adult such as their parent, carer or teacher. That adult should have the time and date of the tutorial, and a link to join. They do not need to join for the length of the tutorial but this allows them to check in on the tutor and student should they wish to. Adults responsible for the welfare of a child should never be prevented from being able to access a tutorial if they wish to do so.

  • The contents of a tutorial should be kept confidential from others (other than where there is a lawful reason for the contents to be shared, e.g. if the tutor genuinely believes that one or more persons is at risk, or may be at risk, of harm).

  • Live online tutorials may be recorded (in whole or in part) unless there is a specific request from the client not to do this. Students and clients should always be made aware of when a tutorial is, or is not, being recorded. Any recordings will be securely stored and provided to those requesting them, and a record that the tuition is being recorded would be made for transparency. Recordings will always be made available to the client on request, other than where doing so is reasonably believed to increase the risk of harm to any person (in which case, Flying Colours Tuition UK will take appropriate action, in line with this policy).

  • The person providing an online tutorial should be in a secure space and should be alone - not caring for or joined by others. If part of the tutorial includes another person being with them or joining the call, this must be communicated ahead of time to the client taking the call. For example, a colleague who joins the tutorial to provide specific information about a topic.

  • Staff and volunteers are encouraged to speak to management and the safeguarding team at Flying Colours Tuition UK if they are ever unclear about matters of conduct. It is better to have a conversation ahead of time and clarifying anything they are unclear about. 

  • Any and all devices used by staff and volunteers of Flying Colours Tuition UK which are used to carry out business on behalf of the company may be recalled or checked. Company devices can be recalled and checked at any time. Personal devices used for business purposes may be requested as part of an investigation by an independent authority, e.g. police. Where tutors use their own devices when delivering tuition through, or via an introduction from, Flying Colours Tuition UK, they consent for those devices to be investigated as part of any necessary safeguarding investigation by relevant authorities or agencies. 

  • Any devices used to carry out online tutorials should have antivirus software and anti-malware software installed.

WHISTLEBLOWING POLICY FOR ALL STAFF AND VOLUNTEERS IN RELATION TO SAFEGUARDING

When reporting safeguarding concerns it is important to follow the proper procedures.

When working with Flying Colours Tuition UK, this means that reports should be made by any responsible adult through the reporting procedure laid out in this policy - reporting to the safeguarding lead and/or deputy lead. Staff and volunteers are welcome to ask the safeguarding team for updates on what they have done. The team are not obliged to share specific details of actions taken but can share whether the report has been acted upon or referred internally or to external authorities/agencies. If a report has not been acted on or referred to relevant authorities and the staff member/volunteer feels it should have been, another report can be made and a discussion should be held with the safeguarding team. Staff and volunteers are encouraged to have discussions with the team as they may be aware of more information than the staff member/volunteer. Again, the team will not necessarily share specifics as these may be confidential but will aim to have a discussion around the concern raised and explain the actions taken.

If the staff member or volunteer still has concerns, the child protection report should be made to the Local Children's Safeguarding Partnership (LCSP) where the child lives (or the relevant board if the concern is about an adult at risk (in other jurisdictions the relevant authority will vary). At this time, the staff or volunteer may tell the board that they did make a report to Flying Colours Tuition UK but they feel it hasn't been passed along appropriately. This will help to ensure the report is passed along securely to the appropriate authorities.

It is not appropriate to go directly to the media or to post on social media. This will be treated as whistleblowing, in line with Flying Colours Tuition UK' general company whistleblowing policy and may result in disciplinary action and/or dismissal.

MANAGING CONCERNS ABOUT OR ALLEGATIONS MADE AGAINST STAFF OR VOLUNTEERS

Allegations made against staff and/or volunteers at Flying Colours Tuition UK will be taken seriously.

All allegations against staff and or volunteers will be passed along to independent authorities to investigate - for example, the LADO via the Local Children's Safeguarding Partnership (LCSP) - and the person the allegation has been made against may be suspended from their duties whilst the authorities investigate. Advice on this will be taken from the LCSP or other authorities who have been notified. 

Whilst any investigations are taking place (by the relevant independent authorities) other staff and volunteers will not be informed of the nature of why the person is not working - this is to maintain confidentiality and allow the proper investigations to take place. If the authorities need to talk to other staff or volunteers, this should be kept confidential.

Any allegations proven to be truthful will lead to disciplinary action or dismissal - dependant on the nature of the allegation and any historical incidents. Again, advice will be sought from the relevant authorities. Any truthful allegations may be passed on to future employers seeking a reference.

Any allegations proven to be false will remain on a record but the outcome of any and all independent investigations will be included with it.

It is important that any and all allegations are taken seriously and investigated fully by the appropriate authorities. This ensures that we uphold our duty to safeguard children. It also helps to ensure that any false allegations are investigated and the truth can come out - clearing the name of the person concerned.

MANAGING CONCERNS ABOUT OR ALLEGATIONS MADE AGAINST OTHER CHILDREN - CHILD ON CHILD ABUSE

We recognise that perpetrators can be adults but they can also be other children - there is no specific identity of a perpetrator.

If an allegation is made against a child it will be reported as a safeguarding concern to the relevant person. For example, the safeguarding lead at Flying Colours Tuition UK, or for the educational setting they are in. In some cases, it will be necessary to refer the matter to external authorities or agencies, such as social workers, the police or international authorities.

It is important that any and all allegations are taken seriously and investigated fully by the appropriate authorities. This ensures that we uphold our duty to safeguard children. This guidance follows Keeping children safe in education - GOV.UK

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