Safeguarding Policy

1. Our commitment

NB Private Tuition Ltd is committed to safeguarding and promoting the welfare of every child and young person with whom we work.

The welfare of the child is our primary consideration.

We recognise that safeguarding is everyone’s responsibility and that children have a right to learn in an environment in which they feel safe, respected and able to raise concerns.

This policy applies to all tuition and educational services provided by NB Private Tuition Ltd, including:

• one-to-one tuition;
• group tuition;
• online tuition;
• in-person tuition;
• educational assessments and consultations;
• communications with Students; and
• any tutor, employee, contractor or other person working on behalf of NB Private Tuition Ltd.

For the purposes of this policy, a child is anyone under the age of 18.

2. About us

NB Private Tuition is operated by:

NB Private Tuition Ltd
Company number: 16977031
Registered in England and Wales

Registered office:
147a High Street
Waltham Cross
Hertfordshire
EN8 7AP

Email: nick@nbtuition.co.uk

Safeguarding Lead

Responsibility for safeguarding within NB Private Tuition Ltd rests with the Director of NB Private Tuition Ltd, who acts as the Safeguarding Lead.

The Safeguarding Lead is responsible for:

• maintaining appropriate safeguarding procedures;
• responding to concerns about the welfare of a child;
• maintaining appropriate safeguarding records;
• seeking advice from or making referrals to children’s social care, the police or other safeguarding agencies where necessary;
• responding appropriately to concerns or allegations about adults who work with children;
• ensuring that safeguarding practice is reviewed and kept up to date; and
• ensuring that anyone subsequently engaged by NB Private Tuition Ltd to work with children understands and follows this policy.

Where a safeguarding concern relates to the Safeguarding Lead personally, the matter should not be investigated internally by the Safeguarding Lead. It should instead be referred to the appropriate external safeguarding authority in accordance with section 14 of this policy.

3. Legal and guidance framework

This policy has been prepared with regard to relevant safeguarding legislation and guidance in England, including:

• the Children Act 1989;
• the Children Act 2004;
• Working Together to Safeguard Children 2026;
• the Safeguarding Vulnerable Groups Act 2006;
• the Protection of Freedoms Act 2012;
• the Data Protection Act 2018 and UK GDPR; and
• relevant Department for Education safeguarding guidance and local safeguarding procedures.

NB Private Tuition Ltd is not a school or college and is therefore not subject to every requirement that applies specifically to those institutions. Nevertheless, we seek to follow appropriate safeguarding principles and safer-working practices applicable to professionals working with children.

4. What safeguarding means

Safeguarding and promoting the welfare of children includes:

• protecting children from maltreatment, whether within or outside the home, including online;
• preventing impairment of children’s mental and physical health or development;
• ensuring that children receive appropriate care and support; and
• taking action to enable children to have the best possible outcomes.

Child protection forms part of safeguarding and concerns the action taken where a particular child is suffering, or is at risk of suffering, harm.

A safeguarding concern does not need to amount to proof of abuse before action is taken.

5. Types of abuse and safeguarding concern

Safeguarding concerns can take many forms.

We remain alert in particular to:

Physical abuse

This may include hitting, shaking, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm to a child.

Emotional abuse

This may include persistent behaviour that seriously affects a child’s emotional development or sense of worth.

It can include humiliation, intimidation, threats, rejection, unreasonable expectations, controlling behaviour, serious bullying or making a child feel frightened or worthless.

Sexual abuse

This involves forcing, encouraging or enticing a child to take part in sexual activities, whether or not the child understands what is happening.

Sexual abuse can occur in person or online and can be committed by adults or by other children.

Neglect

Neglect is the persistent failure to meet a child’s basic physical or psychological needs where this is likely to cause serious impairment to the child’s health or development.

It may include inadequate food, clothing, shelter, supervision, medical care, education or emotional support.

Other safeguarding concerns

We recognise that children can also be affected by issues including:

• domestic abuse;
• child-on-child abuse;
• bullying and cyberbullying;
• sexual harassment and harmful sexual behaviour;
• grooming;
• child sexual exploitation;
• child criminal exploitation;
• county lines and gang exploitation;
• online abuse and exploitation;
• coercive or controlling relationships;
• stalking or harassment;
• radicalisation or extremist influence;
• forced marriage;
• so-called honour-based abuse;
• female genital mutilation;
• trafficking and modern slavery;
• discrimination, racism and hate-related abuse; and
• abuse occurring outside the child’s family or home.

A child may experience more than one form of harm at the same time.

Safeguarding concerns may arise from something a child says, something another person reports, a change in the child’s behaviour, an injury, online activity, information observed during tuition, or a pattern of smaller concerns.

6. Children who may be particularly vulnerable

Any child can experience abuse or neglect.

We recognise, however, that some circumstances can make it more difficult for a child to recognise, report or escape harm.

Particular consideration may be required where a child:

• has special educational needs or disabilities;
• has communication difficulties;
• is experiencing difficulties with their mental health;
• is socially isolated;
• is being bullied;
• is looked after or has previously been looked after;
• is experiencing significant family difficulties;
• is affected by domestic abuse;
• has recently experienced bereavement, displacement or another major disruption;
• is experiencing discrimination; or
• has previously experienced abuse or neglect.

A child’s behaviour must not automatically be attributed to a disability, diagnosis or educational need where it could also indicate that something is wrong.

We seek to listen to children in a way appropriate to their age, communication needs and level of understanding.

7. Professional boundaries

Tutoring frequently involves sustained one-to-one contact between an adult and a child. Maintaining clear professional boundaries is therefore an important safeguarding measure.

Anyone working on behalf of NB Private Tuition Ltd must maintain a relationship with Students that is professional, appropriate and centred on education.

Tutors must not:

• pursue or encourage a sexual or romantic relationship with a Student;
• make sexualised comments to or about a Student;
• engage in inappropriate physical contact;
• share sexually explicit, discriminatory or otherwise inappropriate material;
• encourage secrecy from a Student’s parent or guardian;
• establish an inappropriate personal or emotionally dependent relationship with a Student;
• use their position of trust for personal, financial or sexual advantage;
• communicate with a child in a way that they would be unwilling for the child’s parent, guardian or an appropriate safeguarding professional to see; or
• deliberately place themselves or a Student in circumstances that create an unnecessary safeguarding risk.

Professional warmth, humour and a positive tutor–Student relationship are important parts of effective teaching. This policy is not intended to prevent ordinary, appropriate rapport between tutors and Students.

8. Communication with Students

Administrative communication concerning younger Students should normally take place through their parent or guardian.

Direct communication with older Students may be appropriate where a parent or guardian is aware of and agrees to it, particularly for:

• arranging lesson logistics;
• sending academic work;
• returning feedback;
• answering reasonable academic questions; or
• communicating about applications or examinations.

Such communication must remain professional and related to tuition or education.

Where practicable:

• professional communication channels should be used;
• communications should take place at reasonable times;
• significant arrangements should remain visible to the parent or guardian;
• disappearing-message functions should not be used for routine communication with children; and
• tutors should not use personal social-media relationships as a means of communicating privately with Students.

Tutors should not request unnecessary personal information from a Student.

9. One-to-one and in-person tuition

One-to-one tuition is a normal part of our Services and is not, in itself, considered inappropriate.

Reasonable steps should nevertheless be taken to ensure that the environment is suitable for tuition.

Where practicable:

• tuition should take place in an appropriate room or working area;
• doors should not be locked in a manner that prevents another person entering;
• the Student and tutor should have appropriate personal space;
• the location and expected duration of the lesson should be known to the parent or guardian; and
• the tutor should avoid unnecessary situations in which safeguarding boundaries could become unclear.

Where tuition takes place in the Student’s home, the parent or guardian remains responsible for ensuring that suitable arrangements have been made for the child’s supervision outside the lesson itself.

A parent or guardian does not ordinarily need to remain in the same room during one-to-one tuition.

10. Online tuition

The same standards of professional conduct apply online as in person.

For Students under 18:

• a parent or guardian should be aware that the online lesson is taking place;
• communication should remain appropriate and educational;
• both tutor and Student should participate from an appropriate environment so far as reasonably practicable;
• private information visible in the background should be avoided where possible; and
• concerns arising during an online lesson should be treated in the same way as concerns arising during an in-person lesson.

Online lessons will not ordinarily be recorded.

A lesson must not be recorded by us without an appropriate reason and the prior knowledge and agreement of the relevant parent or guardian and, where appropriate, the Student.

Students and Clients should likewise not record or distribute lesson recordings without prior agreement.

Screenshots, photographs or recordings of Students must not be taken for promotional or unrelated purposes without appropriate consent.

11. Physical contact

Physical contact with a child should be limited to circumstances in which it is reasonable, appropriate and necessary.

Routine tuition should rarely require physical contact.

Appropriate contact might exceptionally include:

• action necessary to prevent immediate injury;
• providing appropriate first aid; or
• another brief and proportionate response reasonably necessary for the child’s safety.

Physical contact must never be sexual, punitive, secretive or intended to cause humiliation.

12. If a child makes a disclosure

If a child says that they have been harmed, abused or made to feel unsafe, the tutor will take them seriously.

The tutor should:

1. Listen carefully. Allow the child to explain what they wish to say in their own words.
2. Remain calm. Avoid expressing shock, disbelief or judgement.
3. Do not investigate. A tutor’s responsibility is to receive the information and act appropriately, not to establish whether an allegation is true.
4. Avoid leading questions. Questions should be limited to what is reasonably necessary to understand whether the child is safe and what action may be required.
5. Do not promise confidentiality. The child should be told, in an age-appropriate way, that information may need to be shared with people whose job is to keep them safe.
6. Reassure appropriately. The child can be told that they were right to speak about the concern.
7. Make a written record promptly. This should distinguish clearly between what the child actually said and the tutor’s own observations or interpretation.
8. Act on the concern. The Safeguarding Lead should consider what safeguarding action is required without unnecessary delay.

The child should not be asked repeatedly to recount an allegation.

13. Recording safeguarding concerns

A safeguarding record should be made as soon as reasonably practicable following a significant concern or disclosure.

It should include, where available:

• the child’s name;
• the date and time of the incident, disclosure or observation;
• the date and time the record was made;
• what was seen, heard or reported;
• the child’s own words where significant;
• any relevant contextual information;
• action taken;
• information shared and with whom;
• decisions made; and
• the reasons for those decisions.

Records should be factual and should distinguish observations from assumptions.

Safeguarding records will be handled confidentially and securely in accordance with our Privacy & Cookies Policy and applicable data-protection law.

Safeguarding information will not be routinely shared more widely than necessary.

14. Responding to a safeguarding concern

Safeguarding concerns will be considered according to their seriousness and circumstances.

Immediate danger

Where there is reason to believe that a child is in immediate danger or requires urgent medical or police assistance, the emergency services should be contacted immediately.

The child’s immediate safety takes priority over normal administrative procedures.

Concern that a child is suffering or is likely to suffer significant harm

Where there is reasonable cause to suspect that a child is suffering or is likely to suffer significant harm, we will contact the appropriate local authority children’s social care service and/or police as appropriate.

A referral does not require proof that abuse has occurred.

Where professional advice is required, we may contact the relevant local authority safeguarding service for advice.

Other welfare concerns

Not every concern reaches the threshold for statutory child protection intervention.

Where a child appears to need additional help or support, we may, depending on the circumstances:

• discuss the concern with the parent or guardian;
• encourage the family to seek appropriate support;
• consult an appropriate safeguarding or educational professional;
• share relevant information with the child’s school where appropriate; or
• seek advice from children’s services.

The appropriate response will depend upon the nature and seriousness of the concern.

15. Informing parents and guardians

Parents and guardians will normally be informed of significant concerns about their child.

However, we may decide that it would be inappropriate to inform a parent or guardian before seeking safeguarding advice or making a referral where, for example:

• the parent or guardian may be involved in the alleged harm;
• informing them could place the child or another person at greater risk;
• informing them could interfere with a police or safeguarding investigation; or
• a safeguarding professional advises that they should not yet be informed.

The child’s safety takes precedence.

16. Confidentiality and information sharing

Safeguarding information is sensitive and should be handled carefully.

However, data protection and confidentiality must not be used as a reason for failing to take necessary action to protect a child.

Relevant information may be shared with appropriate people or organisations where this is necessary and proportionate for safeguarding purposes.

Depending on the circumstances, this may include:

• children’s social care;
• the police;
• a child’s school or its Designated Safeguarding Lead;
• healthcare professionals;
• a Local Authority Designated Officer;
• the Disclosure and Barring Service;
• another safeguarding agency; or
• another person with responsibility for the child’s welfare.

Consent will be sought where appropriate, but safeguarding information may be shared without consent where there is a lawful basis to do so and seeking consent would be inappropriate, impracticable or could place a child at increased risk.

Only information relevant to the safeguarding purpose should be shared.

17. Concerns or allegations about a tutor or other adult working with children

Any allegation that an adult working for or on behalf of NB Private Tuition Ltd has:

• behaved in a way that has harmed a child or may have harmed a child;
• possibly committed a criminal offence against or related to a child;
• behaved towards a child or children in a way that indicates that they may pose a risk of harm to children; or
• behaved, whether at work or outside work, in a way that indicates that they may not be suitable to work with children

will be treated seriously.

Such an allegation should not simply be investigated informally within the business.

Where the relevant threshold may be met, the appropriate Local Authority Designated Officer (LADO) or equivalent local authority safeguarding service will be contacted without delay and ordinarily within one working day.

Where a criminal offence may have been committed or a child may be in immediate danger, the police should also be contacted as appropriate.

The business will follow the advice of the LADO, police and/or children’s social care concerning any subsequent investigation or safeguarding measures.

Where the allegation concerns the Safeguarding Lead

Because the Director acts as the Safeguarding Lead, a parent, Student, contractor or other person who has a safeguarding concern about the Director is not required to raise the matter with the Director before seeking outside help.

They may raise the concern directly with:

• the Local Authority Designated Officer for the relevant local authority;
• children’s social care; or
• the police.

The Safeguarding Lead will not attempt to investigate an allegation against themselves before obtaining appropriate external safeguarding advice.

18. Lower-level concerns about adult behaviour

A concern about an adult’s behaviour does not have to reach the threshold of an allegation of abuse before it is taken seriously.

A lower-level concern might include behaviour that:

• is inconsistent with this policy or expected professional boundaries;
• is unnecessarily over-familiar;
• creates an appearance of inappropriate favouritism;
• involves inappropriate language or communication;
• involves avoidable breaches of professional boundaries; or
• otherwise causes reasonable concern about professional conduct around children.

Such concerns should be recorded and considered appropriately.

Where there is uncertainty over whether a concern meets the threshold for referral to the LADO, safeguarding advice should be sought rather than assuming that no referral is necessary.

Patterns of apparently minor concerns may be significant when considered together.

19. Safer recruitment and suitability

Anyone engaged by NB Private Tuition Ltd to work with children must be suitable to do so.

Where applicable to the role, safer recruitment measures may include:

• verification of identity;
• appropriate references;
• verification of relevant qualifications or professional history;
• consideration of unexplained gaps or concerns in employment history;
• confirmation of the person’s right to work;
• appropriate Disclosure and Barring Service checks;
• barred-list checks where the role is eligible and the law permits or requires them; and
• consideration of the person’s understanding of safeguarding and professional boundaries.

A DBS certificate is an important safeguarding measure but does not by itself establish that someone is suitable to work with children.

Suitability is an ongoing responsibility rather than a one-off recruitment check.

No person known to be barred from regulated activity with children will knowingly be permitted to undertake regulated activity from which they are barred.

20. Disclosure and Barring Service referrals

Where NB Private Tuition Ltd is a regulated activity provider and the statutory conditions requiring a referral to the Disclosure and Barring Service are met, we will make the required referral.

This may apply, for example, where a person is removed from regulated activity with children — or would have been removed had they not resigned or otherwise stopped working — because they have harmed a child or pose a relevant risk of harm.

A referral to another safeguarding body does not necessarily remove any separate legal obligation to refer a matter to the DBS.

21. Contractors and additional tutors

If NB Private Tuition Ltd engages additional tutors, employees or contractors who work with children, they will be expected to:

• read and follow this policy;
• understand how to recognise safeguarding concerns;
• know how to report a concern;
• maintain appropriate professional boundaries;
• undertake appropriate safeguarding training;
• cooperate with appropriate safeguarding enquiries; and
• comply with safer recruitment and DBS requirements applicable to their role.

No contractual or commercial consideration takes precedence over a child’s safety.

22. Safeguarding training

The Safeguarding Lead will maintain an appropriate understanding of current safeguarding responsibilities and guidance.

Anyone else engaged by NB Private Tuition Ltd to work with children will receive or undertake safeguarding training appropriate to their role.

Safeguarding knowledge should be refreshed periodically and when significant changes to guidance or practice occur.

23. Child-on-child concerns during group tuition

Children can harm other children.

Abusive or harmful behaviour between Students will not be dismissed as ordinary banter merely because those involved are of a similar age.

Concerns may include:

• bullying;
• discriminatory abuse;
• threatening behaviour;
• sexual harassment;
• sexualised behaviour;
• coercion;
• online abuse;
• physical violence; or
• sharing sexual images.

Where a concern arises during group tuition, steps will be taken to protect the child or children involved and parents, schools or safeguarding agencies may be contacted where appropriate.

24. Transport and meetings outside tuition

A tutor should not ordinarily transport a child in a private vehicle as part of routine tuition.

Where exceptional circumstances make transport necessary, this should ordinarily occur only with the prior knowledge and agreement of the child’s parent or guardian and with appropriate safeguarding arrangements.

Tutors should not arrange private social meetings with Students outside the professional tutoring relationship.

25. Photography and use of Student information

Photographs, video, testimonials, examination results, examples of work or other identifiable information about a child will not be published for promotional purposes without appropriate permission.

A parent or guardian’s consent to tuition does not automatically constitute consent for promotional use of their child’s image, work, name or personal information.

Any such use must also comply with our Privacy & Cookies Policy.

26. Safeguarding and academic wellbeing

Tutors sometimes become aware of circumstances affecting a Student’s wellbeing because tuition provides regular one-to-one contact.

Ordinary academic stress, disappointment or difficulty does not automatically constitute a safeguarding issue.

However, where a Student’s behaviour, statements or circumstances give rise to a reasonable concern about their safety or welfare, the matter will be treated as a safeguarding concern rather than solely as an academic matter.

27. Whistleblowing

Anyone working for or on behalf of NB Private Tuition Ltd should raise safeguarding concerns even where doing so may be uncomfortable or may concern another professional.

No person should suffer retaliation for raising a genuine safeguarding concern in good faith.

Where a person reasonably believes that a safeguarding concern is not being handled appropriately within the business, they should raise the matter directly with an appropriate external safeguarding authority.

28. Review of this policy

This policy will be reviewed periodically and following:

• significant changes to safeguarding legislation or guidance;
• a serious safeguarding incident;
• a material change to the Services we provide; or
• an identified weakness in existing procedures.

The latest version will be published on our website.

29. Contact

Questions about this policy or safeguarding within NB Private Tuition Ltd may be directed to:

Safeguarding Lead
NB Private Tuition Ltd
147a High Street
Waltham Cross
Hertfordshire
EN8 7AP

Email: nick@nbtuition.co.uk

Where a child appears to be in immediate danger, contact the emergency services rather than waiting for a response from NB Private Tuition Ltd.

Where a concern relates to the Safeguarding Lead personally, it may be raised directly with the appropriate local authority safeguarding service, Local Authority Designated Officer or police.