Safeguarding Policy

The National Learning Group (TNLG) Safeguarding Policy and Procedures 2023

  1. Introduction  

Our safeguarding policy and procedures have been created in line with the NSPCC’s safeguarding checklist. 
This document covers the following safeguarding areas: 

● Our safeguarding and child protection policy including the main elements to ensure we protect the children we work with
● The individuals who have responsibility for safeguarding and child protection within the organisation
● The procedures for responding to child protection concerns, including:
● Child in immediate danger
● Child suspected of being abused or at risk of abuse ● Allegations of abuse are made against a member of staff or tutor  
● Links to our whistleblowing policy 

2.  The National Learning Group (TNLG) Safeguarding Policy Statement 

2.1 The purpose of this policy statement  
The purpose of this policy statement is: 
● To protect children and young people who receive The National Learning Group’s services from harm. This includes the children of adults who use our services.
● To provide staff, as well as children and young people and their families, with the overarching principles that guide our approach to child protection.  

This policy applies to anyone working on behalf of The National Learning Group (TNLG) including trustees, senior managers, staff and students.  

2.2 Legal framework 
This policy has been drawn up based on legislation, policy and guidance that seeks to protect children in England. 
A summary of the key legislation is available from www.nspcc.org.uk/learning  

2.3 Supporting documents  

This policy statement should be read alongside our organisational policies, procedures, guidance and other related documents: 

  • Tutor Handbook 

  • Safer recruitment 

  • Whistleblowing Policy 

  • Monitoring and Improving Teaching and Learning Policy 

2.4 We believe that:  

● Children and young people should never experience abuse of any kind. 

● We have a responsibility to promote the welfare of all children and young people, to keep them safe and to practise in a way that protects them.  

  1.  We recognise that:  

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

  • 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. 

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

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

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

● Valuing, listening to and respecting them.  
● Appointing a nominated child protection and safeguarding lead for children and young people and a deputy lead. 
● Adopting child protection and safeguarding best practice through our policies, procedures and code of conduct for staff. 
● Developing and implementing an effective online safety policy and related procedures.  
● Providing effective management for staff through support, training and quality assurance measures so that all staff know about and follow our policies confidently and competently. 
● Recruiting and selecting staff 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 with children and their families via our website and one-to-one discussions. 
● Making sure that children, young people and their families know where to go for help if they have a concern. 
● Using our safeguarding and child protection procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, parents, families and carers appropriately. 
● Using our procedures to manage any allegations against staff appropriately. ● Creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that does arise.  
● Ensuring that we have effective complaints and whistleblowing measures in place.  
● Ensuring that we provide a safe physical environment for our children, young people and staff, by applying health and safety measures in accordance with the law and regulatory guidance. 
● Building a safeguarding culture where staff, children, young people and their families, treat each other with respect and are comfortable about sharing concerns.  

2.6. NLG Specific Safeguards 

Alongside adhering to best practice safeguarding measures, NLG provides additional built-in safeguarding measures:   

  • Tutors never physically meet up with the children.  Our tutors work remotely online. 

  • We never use or record a child’s e-mail address. We will only use and hold a family e-mail address controlled by and which has been given to us by, a parent or carer or other responsible adult on registration, or later updated by a parent or carer or other responsible adult.  

  • When we communicate by e-mail it will only be to this family controlled e-mail address that you have nominated  
    Every child has a unique username and password for our software, without which they cannot log in to their personal online learning or support spaces. These will be provided to the family on or soon after registration.  

  • Teachers and other staff who have access to the children’s learning information and learning records can only access these using a unique username and password of their own.  

  • All tutoring sessions are recorded and stored securely using a cloud system.  

  • A quality assurance team monitor tutoring sessions regularly for every tutor.  

2.7. NLG Commitment to best practice safeguarding measures: 

a) Recruitment 

We commit to check that every NLG tutor has no criminal record through a DBS check, two references are taken and checked and, it is deemed that, through interviews, they are suitable to work with children 

In addition, those tutors who hold QTS (Qualified Teacher Status) undergo additional checks for prohibition from and barred from teaching lists.  

Tutors who have worked overseas will also have additional checks. 

b) Training 

We commit to ensure that every member of NLG staff should have appropriate safeguarding training. 

All staff receive safeguarding training on the policy and procedures of NLG as part of their tutor induction. 

All staff are required to complete an online safeguarding course as part of their induction.  Once complete, they must email a copy of their certificate to the Safeguarding Lead who will record that training has taken place.  

All staff are required to read part 1 of KCSIE 2022 and, when there any updates made to this document, to read the most up to date version.  All staff must email the Safeguarding Lead to inform them they have read and understood the document and record of this is kept.   

On an annual basis, all staff are required to undertake further safeguarding training to ensure their understanding is up to date.   

Safeguarding updates are given to all staff on a regular basis through the NLG newsletter. 

Training will achieve the following outcomes: 

  • Identify what is meant by safeguarding and child protection 

  • Understand the signs and indicators of abuse and neglect 

  • Know how to respond appropriately to concerns about the safety and welfare of children 

  • Identify the correct procedures for reporting a concern and know who to report to and how 

  • Recognised the important of recording and the principles of good recording practice 

  • Understand that safeguarding children is the responsibility of all staff working in an education setting. 

c) Accessibility of Information 

We are committed to making our safeguarding information easily accessible to parents, staff and professionals we work with.  Policies and procedures can be found on our website – nationallearninggroup.co.uk 

d) Making Everyone Feel Comfortable to Raise Concerns about Safeguarding 

We are committed to creating an open and supportive working environment where staff feel able to speak up about any suspected wrongdoing.  This is reinforced in our whistleblowing policy. 

e) Commitment to Regularly Review Safeguarding Measures 

We align with government guidance and regulation on safeguarding and child protection.  We use the NSPCC safeguarding audit to ensure our policies, procedures and practice are up to date.  Our policies and procedures are checked and updated annually and will take into account new guidance, regulation or legislation.  

2.8 Roles and Responsibilities 

a. NLG Tutors 

Should a child disclose, during a session, information that leads a tutor to reasonably believe that the child may be a victim of abuse, the tutor will record everything that is said and then make contact with the Safeguarding Lead or Deputy Safeguarding Lead either by phone or email.  The Safeguarding Lead or Deputy Safeguarding Lead will then follow NLG procedures as outlined below.  

b.  Safeguarding Lead 

The NLG Safeguarding Lead will take the lead responsibility for safeguarding and child protection: 

  • Refer cases where a tutor is dismissed or left due to risk of harm to a child to the Disclosure and Barring Service and, where a crime may have been committed, to the police. 

  • Update the NLG management team quarterly to inform them of any changes in safeguarding policy. 

  • Ensure staff and tutors receive safeguarding training on an annual basis to raise awareness of safeguarding issues, this policy and procedures. 

  • Act as a source of support, advice and expertise for all staff with respect to safeguarding issues. 

  • Support staff who make referrals. 

  • Undergo appropriate training to provide them with the knowledge and skills required to carry out this role.  This training should be updated every two years. 

  • Ensure NLG’s child protection policy is reviewed annually (as a minimum) and the procedures and implementation are updated and reviewed regularly.  

  • Ensure the child protection policy is available on NLG’s website. 

  • Refer the most serious safeguarding issues to schools and, if required, local authorities. 

  • Work with families, schools and other commissioners of NLG tutoring services to ensure they understand our safeguarding policies and procedures. 

c.  Deputy Safeguarding Leads 

NLG’s Deputy Safeguarding Leads will be able to take over any aspects of the Safeguarding Lead’s role when required (e.g. due to absence or when delegated by the Safeguarding Lead).   

d.  All Other NLG Staff 

All staff must: 

  • Report safeguarding issues when they see, or are made aware of them, to the safeguarding lead or deputy safeguarding lead following NLG procedures. 

  • In the event that any member of staff is concerned that a safeguarding concern is not being adequately addressed, they should raise the matter with the Safeguarding Lead and if still not satisfied, use the processes outlined in the whistleblowing policy.    

2.9
Principal Safeguarding Lead: Elisabeth Malone
Contact Details: elisabeth.malone@thenationallearninggroup.co.uk

Deputy Designated Safeguarding Lead: Amy Allsop
Contact Details: amy.allsop@thenationallearninggroup.co.uk

Deputy Designated Safeguarding Lead: Deborah Sontag
Contact Details: deb@thenationallearninggroup.co.uk

For urgent concerns, please email safeguarding@thenationallearninggroup.co.uk or call the office on 01434 239069 and ask to speak to a member of the safeguarding team.

3. NLG Safeguarding Procedures 

There are 3 procedures that cover the most likely scenarios where NLG could become involved in a child protection issue: 

  • The child is at risk of immediate harm during a tutoring session. 

  • The child makes a direct disclosure of abuse during a tuition session or says or writes something that gives the tutor reason to believe that a child is a victim of abuse. 

  • A tutor, or other member of staff, is the subject of an accusation of abuse of a child.  

The procedures outlined below are not an exhaustive list, therefore, if an incident occurs that is not covered by these, you must contact the NLG Designated Safeguarding Lead. 

3.1.  Procedure 1:  Child is in Immediate Danger 

All interactions with children and young people are online.  It is therefore extremely unlikely that a NLG tutor will encounter a child who is in immediate danger.  However unlikely, there are some circumstances in which a child doing tuition may be in immediate danger.  e.g: 

  • A disclosure is made by the child or young person during the session that leads you to believe they are at immediate risk of harm. 

  • An incident occurs in the location the child or young person is working in that puts them in immediate danger.  

Immediate actions 

The tutor should try to establish, without asking leading questions, the nature of the threat and if there is help available in the location of the tutoring from a safe person. 

The tutor must then immediately try to make contact with the Designated Safeguarding Lead or Deputy Safeguarding Lead.  If they are unable to make contact, they must take appropriate action such as contacting emergency services (999) if the child or young person is at immediate risk of harm. 

The tutor should remain in contact with the child/young person (unless this puts them in more danger) and provide updates to the child/young person). 

Follow Up Process 

Once any immediate danger has been resolved, the tutor must send a written report to the Designated Safeguarding Lead.  The Designated Safeguarding Lead will log the incident and decide next steps.  In the event more information is required, or a copy of the recording of the session is needed, the Designated Safeguarding Lead will follow this up with the appropriate members of staff.  

3.2.  Procedure 2:  Children at Possible Risk of Abuse 

All interactions with children and young people are online.  The most likely way NLG will become involved in a potential safeguarding issue is to be told something directly by the child that indicates they are being a bused or at risk if abuse – this is called a disclosure.  Staff should not wait until they are certain abuse has taken place before reporting a concern.  

3.3. Recognising and Responding to an Indication of Child Abuse 

As per our safeguarding training, when a tutor recognises a child protection issue, they should: 

  • Allow the child to talk about it to them by asking open and encouraging questions. 

  • Record what the child is saying as accurately as possible and in their own words. 

  • Reassure the child that they have done nothing wrong and that, in telling the Tutor about their concerns, they have done the right thing. 

  • Tell them you will have to let other people who can help know.  

Guidance around the signs of abuse can be found on the NSPCC website here: https://learning.nspcc.org.uk/media/1188/definitions-signs-child-abuse.pdf 

3.4 Follow Up Process 

Once any immediate danger has been resolved, the tutor must send a written report to the Designated Safeguarding Lead.  The Designated Safeguarding Lead will log the incident and decide next steps.  In the event more information is required, or a copy of the recording of the session is needed, the Designated Safeguarding Lead will follow this up with the appropriate members of staff.  

3.5.  Procedure 3:  Dealing with Allegations Made Against a Member of Staff 

If the person who is the object of the accusation is still working with children, then the concern needs to be discussed immediately with the Designated Safeguarding Lead and a manager.  One of these should then, in a sensitive manner, remove the member of staff who is the object of the allegation from direct contact with children. 

It should then be explained to the person that a complaint has been made against them although any details should not be given at this stage.  The person should be informed that further information will be provided as soon as possible but, until further advice and information n has been obtained, they should not be working with children and that a manager or Designated Safeguarding Lead will contact them as soon as possible. 

Information provided to the object of the accusation at this stage needs to be limited.  Any discussions that take place must be recorded in case they are needed by other agencies or as part of a criminal investigation.  

4. Conducting an Investigation 

Once any urgent steps have been taken, attention can be given to dealing with the full implications of the allegations. 

There are three possible lines of enquiry 

  • A police investigation of a possible criminal offence 

  • Enquires and assessment by the local authority children’s social care department about whether a child is in need of protection 

  • Investigation by NLG and possible disciplinary action being taken against the person in question.  This includes implementing a plan to manage any risk posed by the individual to children and young people until the outcome of any investigations is known.  

4.1. Reporting an Allegation or Concern 

If the allegation is made by a child or family member to a member of NLG staff or a tutor, or if a member of staff or a tutor observes concerning behaviour by a colleague, this should be reported immediately to the Designated Safeguarding Lead. 

If a member of staff or tutor has received an allegation or observed something of concern about the designated safeguarding lead, this should be reported to a manager.  

4.2. Dealing with a Criminal Offence 

If there is reason to suspect that a criminal offence may have been committed, NLG will contact the police. 

All members of NLG staff and tutors must co-operate fully with any discussion involving the police and should ask for similar co-operation from the police in terms of sharing information relevant to the person’s employment. 

4.3. Talking to Parents/Carers about the Allegation or Concern 

If the child’s parents/carers do not already know about the allegation, NLG’s Designated Safeguarding Lead will need to make contact to discuss this with them.  If the tutoring is commissioned by a school or other third-party organisation, NLG should discuss whether they need to be involved in this process.  

4.4. Talking to the Person who is the Object of the Allegation 

The person who is the object of the allegation should be informed as soon as possible after any discussions, including those with the police or children’s social care, have taken place.  

Only limited information should be given to the person in question unless the investigating authorities have indicated that they are happy for all information to be disclosed or unless there is no need for involvement from statutory agencies. 

The Designated Safeguarding Lead will need to keep in close communication with any other agencies involved in order to manage the disclosure of information appropriately. 

4.5. Taking Disciplinary Action 

If the initial investigation does not involve a possible criminal offence, the Designated Safeguarding Lead and Manager will need to consider if formal disciplinary action is needed.  

Checking other Recordings and Further Risks 

Where an investigation concludes that a tutor has caused a child to be abused, then NLG will review all recordings of tuition between that tutor and any other children.  If this review finds further incidents of potential or actual abuse then these will be flagged and shared with the appropriate agencies.  If this review shows that no further incidents are detected, then NLG will contact any relevant agencies to inform them of that.  

4.6. Keeping Records of an Investigation 

All those involved in dealing with the allegation must keep clear notes of allegation made, how they were followed up and any actions taken and decisions made together with reasons for these. 

All notes should be signed and dated by the person making them with their name printed alongside the signature. 

All notes must be kept securely to ensure confidentiality.   

Information Sharing, Confidentiality and Consent 

NLG has a duty to share information with other agencies where it relates to safeguarding. 

Consent to share information should be sought where it is safe and appropriate to do so. 

Information can be shared without consent if there is good reason to do so (i.e. to protect a child) 

Information will be shared on a need to know basis: this may mean that NLG are not told many details by other agencies.  Likewise, NLG and the Designated Safeguarding Lead will apply the same principle with respect to information sharing.  

The decision on what data to share within NLG and between NLG and other parties (the school, police, local authorities and the tutor centres) will be based on the HM Government’s 2018 guidance document entitled: Information Sharing Advice for Safeguarding Practitioners, which uses these 7 golden rules for sharing information:  

● General Data Protection Regulation 2016 (GDPR), Data Protection Act 2018 and human rights laws are not barriers to justified information sharing but provide a framework to ensure that personal information about individuals is shared appropriately.  

● Be open and honest with the individual (and/or their family) from the start about why, what, how and with whom information may be shared, and seek their agreement, unless it is unsafe and inappropriate to do so.  

● Seek advice from others, including external agencies, if there is any doubt about sharing the information without disclosing the identity of the individual.  

● Where possible, share information with consent, and where possible, respect the wishes of those who do not consent to having their information shared. You may share information without consent if you consider the facts presented that there is a lawful basis such as where safety may be at risk.  

● Consider safety and well-being: base information sharing decisions on the safety and well-being of the individual and others who may be affected by their actions.  

● Ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up to date, is shared in a timely fashion, and is shared securely.  

● Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shard, with whom and for what purpose. 

5. Useful Contact Details 

The National Learning Group is located in Northumberland Local Authority and the contact details of the Local Authority Designated Officer (LADO) who can deal with allegations against professionals is: 

Where the allegation in based in another local authority, then please search for “LADO” or “Local Area Designated Officer” and the name of the local authority to find the relevant contact details.  If you do not know the local authority, then please use this website and enter the postcode:  www.gov.uk/find-local-council