1. Purpose and scope

The Study Studio LLP (The Study Studio, we, us or our) provides private tutoring and related educational services to children and young people (at The Study Studio, children aged 5 to 18), whose welfare is our paramount concern. This policy sets out how we safeguard and promote the welfare of the children who attend our setting, and how everyone connected with The Study Studio should act to keep children safe.

This policy applies to all partners, employees, tutors, volunteers, contractors, agency staff and visitors (together, staff). It covers all activities we run, whether on our premises, at another venue, or online. In this policy, a child means anyone who has not yet reached their 18th birthday.

Note: As a private tuition provider in England, The Study Studio is an out-of-school setting. This policy is designed to meet the expectations of the Department for Education's guidance Out-of-school settings: safeguarding guidance for providers, and to have regard to Keeping Children Safe in Education. It should be read alongside our other policies (for example our privacy policy and our terms and conditions).

2. Policy statement

The Study Studio is committed to safeguarding and promoting the welfare of all children in our care in accordance with statutory frameworks, and we expect all staff to share this commitment. We recognise that safeguarding is everyone's responsibility. We will:

• provide a safe environment in which children can learn;

• take all reasonable steps to protect children from harm, discrimination and degrading treatment, and respect their rights, wishes and feelings;

• identify children who may need early help or who are suffering, or likely to suffer, significant harm, and take appropriate action;

• ensure that everyone who works with children is suitable to do so and understands their safeguarding responsibilities; and

• work openly and in partnership with parents, carers and the relevant local safeguarding partners (the local authority, health and the police).

3. Legal and regulatory framework

This policy has regard to the following legislation and statutory guidance, as amended or replaced from time to time:

• Out-of-school settings: safeguarding guidance for providers (Department for Education);

• Keeping Children Safe in Education (Department for Education statutory guidance);

• Working Together to Safeguard Children (HM Government multi-agency guidance);

• the Children Act 1989 and the Children Act 2004;

• the Safeguarding Vulnerable Groups Act 2006 and the arrangements operated by the Disclosure and Barring Service (DBS);

• the Sexual Offences Act 2003 (including the position of trust provisions, as amended); and

• the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Note:The statutory guidance is updated periodically. The DSLs are responsible for monitoring changes and updating this policy accordingly.

4. Roles and responsibilities

All staff

Every member of staff has a duty to promote the welfare of children and to act on any concern that a child may be at risk. All staff must read and follow this policy, complete safeguarding training appropriate to their role, know who the Designated Safeguarding Leads are, and report concerns immediately.

Designated Safeguarding Leads (DSLs)

The Study Studio has two named Designated Safeguarding Leads who take lead responsibility for safeguarding and child protection. At least one DSL (or a trained deputy) is available at all times while children are present. The DSLs are responsible for:

• receiving and acting on safeguarding concerns and disclosures;

• deciding whether to make a referral to the local authority children's social care, the police or other agencies, and making such referrals without delay;

• keeping accurate, secure and confidential safeguarding records;

• liaising with parents, carers and external agencies as appropriate;

• ensuring staff are trained and that this policy is understood and followed; and

• championing a culture in which children and staff feel able to raise concerns.

Our Designated Safeguarding Leads are: Frédérique D.-Aubry and Laurine Marie Vieira. See the key contacts table at the end of this policy for their contact details.

5. Types of abuse and neglect

Abuse and neglect are forms of maltreatment. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. The main categories are physical abuse, emotional abuse, sexual abuse and neglect. Children may be abused by an adult or adults, or by another child or children. Staff should also be alert to specific safeguarding issues such as online harm, child sexual and criminal exploitation, and the influence of extremism or radicalisation.

Staff should be alert to possible indicators of abuse, which may include unexplained injuries, marked changes in behaviour or mood, fear of a particular person, age-inappropriate knowledge, poor hygiene or self-care, or a child disclosing harm. A single indicator does not necessarily mean a child is being abused, but any concern must be reported to a DSL.

6. Child-on-child abuse and sexual harassment

The Study Studio does not tolerate abuse of one child by another, including physical abuse, sexual violence and sexual harassment, initiation or hazing, bullying (including online bullying), and the sharing of nude or semi-nude images. We will treat all such concerns seriously, never dismiss them as banter or part of growing up, and respond in line with the reporting procedures in this policy. Both the child who has allegedly been harmed and the child who has allegedly caused harm will be supported.

7. Recognising and responding to concerns and disclosures

If a child makes a disclosure, or a member of staff, volunteer or visitor otherwise suspects that a child is at risk, they must report it immediately to a Designated Safeguarding Lead. When receiving a disclosure, staff should:

• listen calmly and take the child seriously, without promising confidentiality;

• not interview or lead the child, or ask probing or leading questions, and only clarify in order to understand;

• reassure the child that they were right to speak up;

• make an accurate written record as soon as possible, using the child's own words, and noting the date, time, what was said and observed, and any action taken; and

• pass the concern and record to a DSL without delay.

8. Reporting and referral procedures

The DSL will consider the information and decide on the appropriate action, which may include managing the concern internally, providing or coordinating early help, or making a referral to external agencies. Where a child is believed to be at risk of significant harm, the DSL will refer to the local authority children's social care (the multi-agency safeguarding hub, or MASH) without delay. If a child is in immediate danger, staff will call the police on 999 first.

Referrals will normally be made by telephone and confirmed in writing within 24 hours. If a member of staff feels that a child is at risk and that the concern has not been acted upon, they may make a referral directly to children's social care or the police, and may contact the NSPCC helpline. Safeguarding a child always takes precedence over any concern about confidentiality or reputation.

9. Allegations against staff, volunteers or visitors

Allegations that an adult working with children has behaved in a way that has harmed, or may have harmed, a child, possibly committed a criminal offence against a child, behaved towards a child in a way that indicates they may pose a risk, or behaved in a way that indicates they may not be suitable to work with children, will be taken seriously. Any such allegation or concern must be reported immediately to a DSL or, if it concerns a DSL or partner, to [insert alternative senior contact].

Where the threshold is met, The Study Studio will contact the Local Authority Designated Officer (LADO) within one working day, will not investigate the matter itself before doing so, and will follow the LADO's advice. Where appropriate, we will also consider a referral to the DBS and/or the police. We will keep a clear written record of any allegation and its outcome.

10. Low-level concerns

We promote an open culture in which any concern about the conduct of an adult, however minor, can be raised and addressed. Low-level concerns, meaning behaviour that is inconsistent with our staff code of conduct but does not meet the allegations threshold, should be reported to a DSL, who will record and consider them. Recording low-level concerns helps identify patterns and prevent abuse.

11. Safer recruitment and safe and suitable people

We seek to ensure that everyone who works with children is suitable to do so. Our recruitment and vetting arrangements include:

• obtaining an enhanced Disclosure and Barring Service (DBS) certificate, including a check of the children's barred list where the role amounts to regulated activity with children;

• verifying identity, relevant qualifications and the right to work, and obtaining and checking references;

• exploring any gaps in employment history and asking about suitability to work with children at interview;

• having in place a written agreement and code of conduct that each member of staff signs; and

• keeping a record of the checks carried out on each member of staff (a single central record).

Note:Whether a role amounts to regulated activity (and so whether a barred-list check is available and required) depends on the nature, frequency and supervision of the work. The Study Studio should confirm the correct DBS level for each role, applying the DfE out-of-school settings guidance on DBS checks, including for self-employed tutors.

12. Staff code of conduct

All staff are expected to maintain professional boundaries and to model appropriate behaviour. Staff must not be alone with a child in a way that cannot be observed unless it is a planned and risk-assessed part of the tuition; must not communicate with children privately or through personal social media or messaging accounts; must not give personal contact details to children; and must avoid any conduct that could be misinterpreted or that could place a child at risk. Any breach may be treated as a disciplinary and/or safeguarding matter.

13. Online safety and use of devices

Where tuition is delivered online or uses digital tools, sessions will be conducted through approved platforms and, so far as practicable, in a way that can be supervised, with appropriate privacy and security settings. On our premises, independent or unsupervised device use by children is not permitted. On arrival, children are asked to place their mobile phones in the designated basket. No child is left unattended with an electronic device, and any device used for educational purposes is supervised by a tutor. We will act on any online safety concern in the same way as any other safeguarding concern.

14. Supervision, arrival and collection of children

The Study Studio is responsible for supervising children only during their scheduled session. Parents and carers must ensure that children are not left unattended on the premises before the start of their session. For safeguarding reasons, children are not permitted to leave the premises unescorted: a parent, carer or authorised adult must collect the child at the end of the session. Staff will follow our agreed arrangements for signing children in and out, for recording who is authorised to collect a child, and for managing any child who is not collected on time.

15. Walking bus and escorting children

The Study Studio offers an optional school pick-up (walking bus) service, in which a tutor collects a child from school (or, during school holidays, from home) and accompanies them to The Study Studio, within approximately a 15-minute walking distance. Because this service involves a member of staff accompanying a child away from our premises, we apply additional safeguarding measures:

• the service is provided only with the prior written authorisation of the child's parent or carer, who confirms the agreed collection point, route and handover arrangements;

• staff who provide the service are subject to our safer-recruitment checks, including an enhanced DBS check where the role amounts to regulated activity;

• we risk-assess the route and handover, agree how the child is signed out of school and into our care, and verify the identity of the adult at each handover;

• staff carry a means of contacting The Study Studio and the parent or carer, and follow agreed procedures if a child is absent, unwell or cannot be safely collected; and

• the service is subject to availability and to the conditions notified by The Study Studio from time to time.

Note:The Study Studio should confirm and document its operating procedure for the walking bus (consent form, route risk assessment, staffing arrangements, lone-working procedures and insurance) and reflect it here and in its terms and conditions.

16. Health, safety and first aid

We will provide a safe physical environment, carry out appropriate risk assessments, and maintain suitable first aid arrangements and accident recording. Staff will be made aware of any medical condition, allergy or additional need notified by a parent or carer, and appropriate arrangements will be agreed in advance.

Note: The Study Studio should confirm its arrangements for administering medication, managing allergies and food, first aid cover and insurance, and reflect them here and in its terms and conditions.

17. Records, confidentiality and information sharing

Safeguarding and child-protection records are kept securely, held separately from general student files, and treated as confidential. Access is restricted to those who need it. We process personal data, including any special category data such as information relating to a child's health, in accordance with the UK GDPR, the Data Protection Act 2018 and our privacy policy. We will share information with safeguarding partners where it is necessary to protect a child; the need to share information to safeguard a child can override a duty of confidentiality.

18. Whistleblowing

Staff who have concerns about how safeguarding is being handled, or about the conduct of a colleague, should raise them with a DSL or the policy owner. Concerns can be raised without fear of reprisal. If a member of staff feels unable to raise a concern internally, or feels that their concern has not been addressed, they may contact the NSPCC whistleblowing helpline on 0800 028 0285.

19. Training

All staff receive safeguarding induction before working with children and refresher training at appropriate intervals. The DSLs undertake enhanced training for their role and update their knowledge and skills regularly. Training records are maintained.

20. Preventing radicalisation

We are alert to the risk of children being drawn into extremism or radicalisation. Staff who have a concern that a child may be at risk in this way must report it to a DSL, who will consider whether a referral to the local authority or the police (Channel programme) is appropriate.

21. Complaints

Concerns about a child's safety should be raised through the safeguarding procedures in this policy rather than the general complaints process, so that they can be dealt with quickly. Other complaints about our services may be made in accordance with our terms and conditions.

22. Monitoring and review

This policy is reviewed at least annually, and sooner if there is a significant change in legislation, guidance or our operations, or following any safeguarding incident. The DSLs and the policy owner are responsible for the review.

23. Key contacts

The following contacts should be completed by The Study Studio and kept up to date and displayed where staff can access them: