Child Protection and Safeguarding Policy

1. Policy Statement

Ember Learning Ltd, trading as Ember Tutors, is committed to safeguarding and promoting the welfare of all children and young people with whom it works. This commitment is unconditional and underpins every aspect of our organisation.

Ember Tutors provides online small group tutoring in mathematics and English to secondary-aged students aged 11 to 16. Our students are referred to us by commissioning Local Authorities and Multi-Academy Trusts ('Commissioners'), principally as a form of non-statutory alternative provision arranged under Section 19 of the Education Act 1996 and/or the Children and Families Act 2014. Sessions are delivered via the Vedamo online platform by self-employed Tutor Associates.

We believe that:

• The welfare of every child is paramount, regardless of age, ability, disability, gender, race, religion, sexual orientation, or background
• All children, whatever their circumstances, have the right to be protected from harm
• Every member of our organisation — including self-employed associates — shares responsibility for safeguarding and has a duty to act if they have concerns
• Safe and effective safeguarding practice must be embedded in our culture, our recruitment, our training, and our operational delivery

This Policy is informed by and consistent with Keeping Children Safe in Education (DfE, 2025) ('KCSIE'), Working Together to Safeguard Children (HM Government, 2023), and all applicable legislation. Although Ember Tutors is not a registered school, we apply KCSIE principles as best practice because we deliver regulated activity with children.

2. Scope

2.1 This Policy applies to:

• All Company directors and employees
• All self-employed Tutor Associates engaged by Ember Tutors, regardless of the frequency or nature of their engagement
• Any volunteer or observer present during a tutoring session

2.2 Self-employed status does not reduce, remove, or limit any individual's safeguarding obligations. Any person working with students under this Policy must comply with it fully.

2.3 This Policy covers all tutoring sessions delivered via the Vedamo platform, all administrative and management activities, and any other activity in which Ember Tutors staff or associates come into contact with children.

3. Legal and Regulatory Framework

This Policy reflects the requirements of the following legislation and guidance:

• Keeping Children Safe in Education (DfE, 2025) — applied as best practice
• Working Together to Safeguard Children (HM Government, 2023)
• The Children Act 1989 and the Children Act 2004
• The Children and Families Act 2014
• Section 19 of the Education Act 1996
• The Safeguarding Vulnerable Groups Act 2006
• The Protection of Freedoms Act 2012
• The Counter-Terrorism and Security Act 2015 (Prevent duty)
• The Online Safety Act 2023
• Information sharing: advice for practitioners (HM Government, 2024)
• What to do if you're worried a child is being abused (DfE, 2015)

4. Key Personnel and Responsibilities

4.1 DSL Availability. The DSL must be contactable during all hours in which sessions are scheduled. Where the DSL is unavailable (e.g. due to leave or illness), the Deputy DSL must be available to cover. Sessions shall not be delivered without DSL or Deputy DSL cover.

4.2 All Associates. Every Tutor Associate shares responsibility for the welfare of students. Where an associate identifies or suspects a safeguarding concern, they must act immediately in accordance with Section 8 of this Policy.

5. Types of Abuse and Neglect

All staff and associates must be aware of the four main categories of abuse, as defined in Working Together to Safeguard Children (2023):

Physical Abuse 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 or induces illness.

Emotional Abuse is the persistent emotional maltreatment of a child. It 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. It may feature age-inappropriate or developmentally inappropriate expectations being imposed on a child, or the serious bullying or witnessing of abuse of others.

Sexual Abuse involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence. This includes contact activities (such as rape, sexual assault, or penetration) and non-contact activities (such as creating or viewing sexual imagery involving children, or encouraging children to behave in sexually inappropriate ways). Online child sexual abuse is within scope.

Neglect is the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. This includes failure to provide adequate food, clothing, shelter, supervision, medical care, or emotional support.

Associates should also be alert to indicators of:

• Child sexual exploitation (CSE) and child criminal exploitation (CCE)
• Domestic abuse (including where the child witnesses domestic abuse)
• Female genital mutilation (FGM)
• Forced marriage
• Honour-based abuse
• Radicalisation and extremism (Prevent)
• County lines and gang exploitation
• Children missing from education
• Online harms, grooming, and exploitation
• Mental health concerns that may indicate abuse or neglect

6. Recognising Abuse — Signs and Indicators

6.1 In an online tutoring context, associates should be particularly alert to the following potential indicators during sessions:

• Unexplained or recurrent absences from sessions without explanation
• A student appearing distressed, withdrawn, or unusually emotional during or at the start of a session
• Visible injuries visible on screen (unexplained bruising, burns, or marks)
• Disclosures — direct or indirect — of abuse, neglect, exploitation, or harm
• Significant changes in behaviour, mood, or engagement over time
• A student appearing to be in an inappropriate location, in the presence of an adult causing concern, or in apparent distress in their home environment
• Signs of radicalisation, extremist language, or vulnerability to exploitation
• Inappropriate contact with the student observed via the platform's chat or messaging features

6.2 Associates are not expected to be expert investigators. They are not required to determine whether abuse has occurred. Their role is to notice, record, and report. The DSL decides on next steps.

7. Contextual Safeguarding

7.1 Safeguarding concerns do not always arise from within the home. Associates should be aware that harm to students can occur in peer relationships, online, in communities, and in other contexts. This is particularly relevant in an online delivery model where students may be visible in environments beyond school or home.

7.2 Any concern that appears to relate to the student's external context — including concerning language, apparent fear of others, or references to unsafe situations outside the home — should be reported to the DSL in the same way as any other concern.

8. Reporting a Safeguarding Concern — Procedure for Associates

8.1 Where to Report. All concerns must be reported using BOTH of the following channels:

• Step 1: Use the safeguarding concern reporting feature on the Vedamo platform to log the concern, completing all fields as fully as possible. This must be done within one hour of the session ending, or immediately if the concern arises outside a session
• Step 2: Contact the DSL (Jack Bradley) directly by telephone immediately — do not wait until after completing the platform report. If the DSL is unavailable, contact the Deputy DSL (Mahesh De Zoysa) immediately

8.2 What to Report. When reporting a concern, associates should record:

• The student's name and year group
• The date and time of the observation or disclosure
• A factual, objective account of what was seen, heard, or disclosed — using the student's exact words where a disclosure was made
• Why the associate is concerned
• Any contextual information that may be relevant

8.3 What Not to Do. Associates must NOT:

• Investigate or ask leading questions
• Promise confidentiality to a student
• Contact the student's family or carers about the concern without DSL authorisation
• Discuss the concern with anyone other than the DSL or Deputy DSL
• Delay reporting on the basis that a concern seems minor or uncertain

8.4 Receiving a Disclosure. If a student makes a disclosure during a session, the associate should:

• Remain calm and listen attentively
• Not stop the student from speaking or tell them to stop
• Use open, non-leading responses such as 'I hear you' or 'tell me more if you want to'
• Not promise that what is said will be kept secret
• Explain calmly that they will need to share what has been said with someone who can help
• Complete the report to the DSL as soon as the session ends

9. The DSL's Role in Managing Concerns

9.1 On receipt of a concern, the DSL will:

• Assess the concern and determine appropriate next steps
• Decide whether to make a referral to children's social care, the police, or both
• Notify the referring Commissioner's Designated Safeguarding Lead within 24 hours of a concern involving a referred student, unless there is a specific reason not to do so (for example, where doing so could put the student at increased risk)
• Maintain a written record of all concerns, actions taken, and decisions made
• Review session recordings where relevant to the concern, in accordance with the Session Recording Policy (ET-SRP-002)

9.2 Referral to Children's Social Care. Where the DSL believes a student may be at risk of harm, they will make a referral to the relevant Local Authority's Children's Social Care without delay. The DSL will not wait for certainty before making a referral if the threshold of reasonable suspicion is met.

9.3 Information Sharing. The DSL will share information about a student with statutory agencies in accordance with the principle that the welfare of the child overrides data protection considerations. The DSL will be guided by Information sharing: advice for practitioners (HM Government, 2024).

9.4 Safeguarding Records. The DSL maintains a confidential safeguarding record for each concern raised. Records are stored securely with restricted access. They are retained in accordance with the Company's data retention policy and are not included in general student files.

10. LADO Referral — Allegations Against Staff or Associates

10.1 Any allegation that a member of staff or a Tutor Associate has:

• Behaved in a way that has harmed, or may have harmed, a child
• Possibly committed a criminal offence against or related to a child
• Behaved towards a child in a way that indicates they may pose a risk of harm to children
• Behaved or may have behaved in a way that indicates they may not be suitable to work with children (including behaviour outside of the workplace)

must be referred to the relevant Local Authority Designated Officer (LADO) without delay.

10.2 The DSL is responsible for making LADO referrals. The Company Director must be informed immediately of any allegation against a member of staff or associate.

10.3 Where an allegation is made against the DSL, the referral must be made by the Company Director.

10.4 On receipt of an allegation, the Company will:

• Refer to the LADO within one working day
• Not investigate the matter internally before LADO referral
• Follow all LADO guidance regarding the management of the individual's continued engagement pending investigation
• Suspend or withdraw the individual from student-facing activities where required by the LADO or where this is necessary to protect children's welfare

10.5 Whether or not an allegation results in a criminal prosecution or disciplinary action, a thorough review will be conducted to determine whether the individual should continue to work with children.

11. Prevent — Radicalisation and Extremism

11.1 Ember Tutors is committed to protecting students from radicalisation and extremist ideology. All associates must be alert to signs that a student may be at risk of radicalisation or being drawn into extremism.

11.2 Signs that may indicate radicalisation include: use of extremist language or glorification of violence; withdrawal from usual social activity; expression of intolerant views about others based on religion, ethnicity, or ideology; apparent contact with extremist groups; and possession or sharing of extremist materials.

11.3 Where an associate has a concern that a student may be at risk of radicalisation, they should report this to the DSL in the same way as any other safeguarding concern. The DSL will consider whether a referral to the Channel programme is appropriate.

12. Safer Recruitment

12.1 Ember Tutors will not permit any individual to deliver sessions or access student personal data without completing the mandatory safer recruitment process set out in the Safer Recruitment Process document (ET-SRP-001).

12.2 This process requires, at minimum: an enhanced DBS check with barred list check; two satisfactory references (one involving work with children where applicable); identity verification; employment history review; and mandatory safeguarding training.

12.3 These requirements apply to all Tutor Associates without exception, regardless of self-employed status. The Company Director is responsible for ensuring the pre-start checklist is completed and signed off before any associate delivers a session.

13. Training

13.1 DSL and Deputy DSL. The DSL and Deputy DSL must complete DSL-level safeguarding training appropriate to their role. This training must be refreshed at least every two years. In addition, the DSL and Deputy DSL should update their knowledge and skills regularly through reading, briefings, and engagement with current safeguarding guidance.

13.2 Tutor Associates. All Tutor Associates must complete the Company's mandatory safeguarding awareness training before delivering any session. This training covers: recognising abuse and neglect; understanding the Company's reporting procedure; online safety in a tutoring context; and Prevent awareness. Training must be renewed annually.

13.3 The DSL is responsible for keeping a record of all completed training. Associates must provide evidence of completion before commencing sessions.

14. Record Keeping and Information Governance

14.1 All safeguarding concerns, referrals, and actions are recorded in writing by the DSL. Records are:

• Stored securely and separately from general student records
• Accessible only to the DSL, Deputy DSL, and Company Director
• Factual, dated, and signed
• Retained in accordance with the Company's data retention schedule

14.2 Session recordings are retained for safeguarding purposes in accordance with the Session Recording Policy (ET-SRP-002).

14.3 Where a student moves on from Ember Tutors, the DSL will consider whether any safeguarding information should be shared with the receiving organisation, in accordance with the principle that the child's welfare takes precedence.

14.4 All data held for safeguarding purposes is processed in accordance with the Data Processing Agreement (ET-DPA-001) and the Company's obligations under UK GDPR and the Data Protection Act 2018.

15. Working with Commissioners

15.1 Ember Tutors recognises that the responsibility for safeguarding referred students is shared with commissioning Local Authorities and Multi-Academy Trusts.

15.2 The Company's DSL will establish contact with each Commissioner's Designated Safeguarding Lead at the point of referral and maintain that contact for the duration of the placement.

15.3 The DSL will notify the Commissioner's DSL within 24 hours of any safeguarding concern arising in relation to one of the Commissioner's referred students, unless doing so would place the student at increased risk.

15.4 The Company will cooperate fully with any safeguarding investigation involving a referred student.

15.5 Where a Commissioner raises a safeguarding concern with Ember Tutors, the DSL will respond immediately and in accordance with Section 9 of this Policy.

16. Whistleblowing

16.1 Ember Tutors supports a culture in which concerns about safeguarding practice — including the conduct of the DSL, Company directors, or any associate — can be raised safely and without fear of retaliation.

16.2 Any person who has concerns about safeguarding practice within the Company should raise them first with the DSL (or, where the concern involves the DSL, with the Company Director).

16.3 If the concern relates to the conduct of the Company Director, or if concerns raised internally have not been addressed, the individual may report to:

• The NSPCC Whistleblowing Advice Line: 0800 028 0285
• The relevant Local Authority's LADO
• Ofsted (where the concern involves regulated activity with children)

16.4 The Company will not penalise or disadvantage any person who raises a safeguarding concern in good faith.

17. Linked Policies and Documents

This Policy should be read alongside the following Ember Tutors documents:

• Online Safety Policy (ET-OSP-001)
• Session Recording Policy (ET-SRP-002)
• Safer Recruitment Process (ET-SRP-001)
• Tutor Associate Agreement (ET-TAA-001) — including Schedule 2 (Confidentiality and Data Handling Undertaking)
• Data Processing Agreement (ET-DPA-001)
• Service Agreement (ET-SA-001)
• Complaints Procedure (ET-CP-001)

18. Policy Review

This Policy will be reviewed annually and following any significant safeguarding incident, change in legislation, or updated statutory guidance. The review date and version will be updated below.