1. Introduction

a) Ivy Education takes its responsibilities to safeguard and protect the interests of the children and young adults with whom it works very seriously. The nature of its business means that its staff, self-employed tutors and consultants can have regular and unsupervised contact with children and young adults. This may include providing tutoring and other educational services in a pupil’s home or elsewhere.

b) Ivy Education follows the statutory guidance for UK schools in the safeguarding of children and in the safer recruitment of personnel namely: Keeping Children Safe in Education (KCSIE) This ensures that Ivy Education maintains the highest possible standards of safeguarding practice. Please refer to KCSIE for further information.

2. Scope

a) This policy applies to all directors, employees, self-employed tutors, consultants and volunteers of Ivy Education or anyone working on behalf of Ivy Education. For ease of reference, referred to as ‘tutors’ throughout this policy.

b) It also applies to all pupils of Ivy Education, regardless of their age.

c) This policy is made known to parents and tutors on the Ivy Education website and is available to parents and tutors on request.

3. Basic Principles

a) Everyone has a role to play in safeguarding children and they should ensure that their approach is always child centred: this means that the best interests of the child are paramount and must be kept at the heart of all decision making.

b) Safeguarding concerns may arise in any family regardless of economic or educational status, religion, nationality, ethnicity, sexual identity or any other dynamic which may affect families.

c) Pupils, parents and tutors must feel confident to share any concerns and be reassured that there are procedures in place to ensure these are dealt with professionally and effectively.

4. Aims of this policy

a) To provide the safest possible environment for pupils

b) To ensure that safeguarding procedures are followed by all tutors in accordance with this policy

c) To emphasise the need for clear and prompt communication in matters relating to safeguarding

d) For all tutors to be alert to the risks to pupils, including online

e) For all tutors to understand and follow the Ivy Education Professional Code of Conduct (clause 18) and to ensure they uphold the highest standards of educational practice in their dealings with pupils and their families

f) To ensure that all tutors are recruited in accordance with the Ivy Recruitment Policy (clause 19).

5. Designated Safeguarding Person (DSP)

5.1 The designated person for safeguarding within Ivy Education is our Safeguarding Lead, Jessica Flinn. Their contact number is 02077366977. Our Deputy DSP is our Head of Client Services, Ellen O'Leary, who can be contacted at 02077366977. In an emergency, Alastair Delafield can be contacted out of office hours on 07915067600.

5.2 All concerns of a child protection or safeguarding nature, however minor they may seem, should be made directly to the DSP following the procedures outlined below. Tutors should not discuss concerns about pupils with others, including the child’s parents, until further advice is obtained. If a tutor believes a child is in immediate danger the police should be called on 999.

5.3 The duties of the DSP include:

a) To co-ordinate and monitor all matters related to safeguarding, being the first point of contact for tutors, parents, pupils and external agencies

b) To keep detailed, accurate records, including records of any action taken

c) To ensure that all tutors have confirmed that they have been provided with a copy of the Ivy Education Safeguarding Policy (i.e. this document) and KCSIE Part 1 and have read and understood it

d) To report any concern about a child to the local authority of where the child resides.

e) To report any allegations made against a tutor of Ivy Education to the Local Authority Designated Officer for Hammersmith & Fulham which is:- Tri-Borough LADO and Safer Organisations Manager: Megan Brown London Borough of Hammersmith and Fulham: 0208 753 5125 / LADO@lbhf.gov.uk

6. What to do if a child discloses information or there are other concerns about a child

a) Listen carefully and keep an open mind.

b) Reassure the pupil if they have made a disclosure that he/she is right to tell you and is not to blame. Avoid overreacting with a strong emotional response, it is important to remain calm.

c) Never promise confidentiality. Explain that you need to make sure that the pupil is safe, and you will need to ask other adults to help you to do this.

d) Do not cross question the pupil. You must not ask leading questions, that is, a question which suggests its own answer. Let the pupil tell you what he or she wants to and no more. The pupil may be interviewed by a specialist later and too much questioning may prejudice later investigations or cause the pupil to become anxious and retract his/her information.

e) Be aware that younger pupils may disclose issues of a safeguarding nature in general conversation rather than as a specific disclosure.

f) Immediately after any disclosure make a written record of events. Be as clear and precise as you can, use the same words the child used, make note of the date, time, venue, who was present and the behaviours, mood and actions of the child during the disclosure.

g) Concerns may arise about a child without a disclosure being made or without specific concrete evidence. There may be a change in a child’s behaviour or written work may show signs of confusion or distress.

h) Concerns may also need to be raised about a parent’s interaction with a pupil or issues such as parental alcohol/drug misuse, domestic violence or mental health.

i) In many safeguarding cases it is not one major incident which triggers a referral but a series of seemingly minor events. It is therefore important that all concerns are recorded and reported to the DSP.

7. Recording safeguarding concerns

a) All safeguarding concerns must be reported by telephone to the DSP immediately and then recorded on a Safeguarding Report Form (received from the DSP after telephoning).

b) The record should be made as soon as possible after speaking to the pupil and should contain facts and information only, taking care to avoid personal opinion.

c) The original of the form must be given to the DSP and no copies should be retained, either electronically or in hard copy.

d) On receipt of the completed safeguarding form, the DSP will record the action taken and he / she will also sign and date the form. Action will depend on the nature of the concern. It may include one or more of the following:

1. monitoring the pupil
2. a discussion with parents
3. referral to the Children's Services
4. report to the police

e) Any tutor making a report will be informed by the DSP of the action taken.

f) If the pupil's situation does not appear to be improving the tutor should request the DSP to re-consider the action taken.

8. Child Protection Records

a) Safeguarding forms are kept securely in one central location by the DSP.

b) The DSP will contact the local authority for advice prior to notifying parents if a referral to Children’s Services is thought to be required.

c) All discussions with the local authority along with the decisions made and the reasons for those decisions will be recorded in writing by the DSP.

d) Any new concern or information about a pupil who has active (or previous) involvement with Children’s Services must be passed to the local authority without delay.

9. Procedures for child protection referrals

a) The DSP, or in her absence a deputy, will ensure that action is taken in line with locally agreed procedures.

b) Referrals about an individual pupil must be made to the borough in which the pupil resides. However, informal advice may be obtained from the Hammersmith & Fulham’s Children’s Services department, regardless of the where the pupil resides.

c) The policy of Ivy Education requires that all referrals are made by the DSP; however, in exceptional circumstances a tutor may raise concerns directly with Children’s Services.

d) The DSP will discuss the concerns with the pupil’s parents/carers and advise them of a referral to Children’s Services, except in circumstances where there is a concern about sexual abuse or where there are concerns that contacting the parents/carers will place the pupil at increased risk.

e) In cases of extreme emergency or if a serious criminal offence appears to have been committed the police will be contacted immediately

f) The referral process outlined in this policy is also followed when there are concerns about a pupil who may be at risk of radicalisation.

10. Categories and definitions of child abuse

All tutors should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In many cases issues will overlap with one another. The following information is intended as a guide only and further information for tutors is available in KCSIE. Any concerns, whether they are listed below or not, should be brought to the attention of the DSP immediately.

In paragraph 35 of KCSIE abuse is defined as

‘a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or another child or children.’

The main categories of abuse are:

1. Physical abuse
2. Emotional abuse (including a child living in a home with domestic violence)
3. Sexual abuse
4. Neglect

11. Physical abuse

A form of abuse which 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 the symptoms of, or deliberately induces, illness in a child.

12. Emotional abuse

Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child's emotional development. This may include:

a) Conveying to a child that he or she is worthless or unloved, inadequate, or valued only insofar as meeting the needs of another person.

b) Not giving the child opportunities to express his or her views, deliberately silencing the child or 'making fun' of what he or she says or how the child communicates.

Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

13. Sexual abuse

a) Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities. It may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet).

b) Boys and girls of all ages may be sexually abused and are frequently scared to say anything due to guilt and/or fear. Recognition can be difficult, unless the child discloses. There may be no physical signs and indications are more likely to be emotional/behavioural.

14. Neglect

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. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

15. Risk Factors

In an abusive relationship a child may:

1. appear frightened or wary of the parent/s or another adult
2. act in a way that is inappropriate to her/his age and development though full account needs to be taken of different patterns of development and different ethnic groups

The parent may:

1. have unrealistic expectations of their child
2. frequently complain about/to the child and may fail to provide attention or praise (high criticism/low warmth environment)
3. be absent, misusing substances and/or have mental health issues
4. be involved in domestic violence and/or a coercive controlling relationship

Tutors should also be alert to changes in a pupil’s behaviour if there is a new carer e.g. nanny or au pair.

16. Specific safeguarding issues

16.1 Domestic Abuse

It is important to recognise that children may live in families where domestic abuse is a factor, and that these situations have a harmful impact on children emotionally, as well as placing them at risk of physical harm.

Where the DSP determines that a pupil has encountered domestic violence, directly or indirectly, the DSP will immediately discuss the matter and take advice from Children’s Services. The DSP will also take advice if he is concerned about pupils whose parents are adversely affected by drug or alcohol misuse or mental health issues.

16.2 Female Genital Mutilation (FGM)

FGM is illegal in the UK and there is a mandatory duty on teachers to report cases of FGM to the policy if it is believed that an act of FGM has been carried out or where a girl may be at risk of FGM being carried out.

16.3 Grooming

When someone builds an emotional connection with a child or a young person to gain their trust for the purposes of sexual abuse or exploitation. Adults who engage in grooming behaviour will often seek to influence other adults around the child to gain their trust.

16.4 Self-harm

Self-harm is any behaviour where the intent is to deliberately cause harm to one’s own body. It is estimated that up to one in ten young people in the UK engage in self-harming behaviours. All tutors should be aware of the signs of self-harm in pupils. Any tutor who is aware of a pupil engaging in or suspected to be at risk of engaging in self-harm should refer the matter to the DSP. Following the report, the designated person will decide on the appropriate course of action.

16.5 Sexting

Sexting is when someone shares sexual, naked or semi-naked images or videos of themselves or others, or sends sexually explicit messages. They may be sent using mobile phones or any other device which allows media and messages to be shared. Creating or sharing explicit images of a child is illegal, even if the person doing it is a child.

17. Allegations against a tutor or another adult

a) Any concern about a peer, tutor or another adult’s behaviour, however minor it may appear, must be reported to the DSP. Never think that abuse by a student's peer or an adult is not possible, or immediately disbelieve an accusation against someone you may know well and trust.

b) An allegation against the DSP should be reported to Alastair Delafield, Deputy DSP, the managing director of Ivy Education, without notifying the DSP first.

c) The DSP will obtain written details of the allegation, signed and dated, from the person who received the allegation or the person who is making the allegation. If a pupil has made an allegation a written record of what the pupil has said should be made by the tutor to whom the pupil disclosed.

d) If an allegation is made against a tutor, the priority will be to achieve a quick resolution in a fair and consistent way that provides effective protection for any pupil involved, and at the same time supports the person who is the subject of the allegation, minimising the stress for all parties.

e) Any case of allegations against tutors, including those considered borderline, will be discussed with the LADO. It is not the prerogative of the Ivy Education to determine the threshold for what is to be reported.

f) In the case of a referral and investigation, the DSP must ensure, before contacting any of the parties concerned, that there is no objection by the investigating agencies.

g) If Ivy Education ceases to use the services of any person (whether employed, self-employed, contracted or a volunteer) because that person was considered unsuitable to work with children, a prompt and detailed report will be made to the DBS. For teachers, it also has a responsibility to report the matter to the Secretary of State for Education, which may result in a prohibition order in respect of the person being made.

18. Professional Code of Conduct for Tutors

a) The following Professional Code of Conduct outlines the key principles to which all tutors must adhere. The purpose of the code is to set out the expectations of standards of professional behaviour. Allegations of unprofessional conduct or improper contact or words can arise at any time. One to one tuition can present different challenges to those encountered in a school setting. Tutors are reminded that professionalism and vigilance are required to ensure the safety of the pupils, and to reduce the risk of an allegation against a tutor.

b) If at any point during a tuition session a tutor feels uncomfortable about the behaviour of a pupil or a parent/carer, the circumstances must be reported to Ivy Education without delay. If necessary, the tutor should end the session and leave.

c) It should be noted that forming inappropriate relationships with children or young people who are not pupils of Ivy Education will also be regarded as gross misconduct.

18.1 General guidelines

Tutors should:

a) Treat pupils with dignity, building relationships rooted in mutual respect, and at all times observing proper boundaries appropriate to their professional position.

b) Model and demonstrate consistently the positive attitudes, values and behaviour expected of pupils.

c) Work in an open and transparent way, always seeking advice from Ivy Education if in any doubt.

d) Ensure good communication and working relationships with parents.

e) Plan and prepare suitable academic work and use engaging teaching strategies appropriate to the age and ability of pupils.

f) Give regular and appropriate feedback to pupils on their academic performance. At all times being mindful to maintain a pupil’s self-esteem and self-confidence.

g) Wear appropriate clothing reflecting their professional role, although there is no requirement to dress formally.

h) Provide tuition with focus and total attention (e.g. not eating, focusing on other work, texting).

i) Avoid mobile phone use whilst teaching or in the presence of a pupil or their family members.

j) Not give pupils gifts without prior parental approval – all gifts/rewards must be recorded in lesson notes.

k) Not give pupils their home address, home telephone number or mobile number unless used in alignment with clause 18.1.

l) Not discuss families or pupils with others outside Ivy Education and must be aware of confidentiality of information. The names and addresses of pupils/parents must not be used or passed on for any other purposes.

m) Not make contact with any pupil for any reason unrelated to the particular work for which he/she has been engaged.

n) Maintain Ivy Education’s reputation for integrity and responsibility and not enter into any social or other non-work related arrangements.

18.2 Pupils who may be particularly vulnerable

Tutors need to be aware to take particular care when dealing with a pupil who:

a) appears to be emotionally distressed, or is generally vulnerable and/or who is seeking expressions of affection.

b) may present with mental health issues such as an eating disorder or self-harm.

c) acts in a sexually provocative way, or who is inclined to make exaggerated claims about himself or herself and others, or to fantasise, or one whose manner with adults is over-familiar.

d) may have reason to make up an allegation to cover the fact that he/she has not worked hard enough for examinations.

These behaviours should be reported to the DSP in accordance with this policy.

18.3 Physical Contact

Tutors must:

a) Avoid all unnecessary physical contact and apologise straight away if there is accidental physical contact.

b) Only use physical contact if it is to prevent accident or injury to themselves or anyone else (e.g. to prevent a fall), or in the case of medical assistance being needed (e.g. to administer first aid), in which case the prior consent of the affected person should be requested where possible. Where possible, consent from parents or those with parental or caring responsibility should be obtained.

c) Do his/her best to comfort or reassure a pupil if he/she is hurt or distressed, without compromising his/her dignity or doing anything to discredit the person's own behaviour.

d) Not do things of a personal nature for pupils that they can do for themselves (this includes changing clothing, or going to the toilet with them).

e) Not use any form of aggressive contact such as holding, pushing, pulling or hitting, which could amount to a criminal assault, or threatening words. All forms of corporal punishment are unlawful and corporal punishment must never be threatened.

f) Ensure the use of appropriate language at all times. Avoid words, expressions or humour that may have any sexual innuendo, may be misconstrued or any words or actions that are over-familiar.

g) Avoid any conduct that could be taken as a sexual advance.

h) Not swear or use any sort of offensive language in front of pupils or parents.

i) Avoid displays of affection either personally or in writing e.g., messages in birthday cards.

18.4 Other contact

Tutors must not:

a) Make arrangements to meet pupils outside tuition sessions.

b) Give a pupil a lift in their own vehicle.

c) Invite a pupil or pupils to their own home, outside of arranged tuition sessions.

18.5 Use of technology, cameras, mobile phones and other devices

a) Tutors must not take video footage or photographs of pupils.

b) Any email communication directly between a tutor a pupil must have a parent or guardian in copy. Failure to do so may result in disciplinary
action.

c) Any communication by text or WhatsApp must be brief and relate only to tutoring or the organisation of tutoring sessions.

d) Emails or any other written communication should be drafted carefully so messages cannot be misinterpreted, avoiding any displays of affection or over familiarity.

e) Tutors should use social networking sites with great caution so neither they nor Ivy Education is brought into disrepute. Maximum privacy settings should be utilised.

f) Tutors should not contact pupils or parents through Facebook, Instagram, Twitter or any other social networking sites and must not accept ‘friend’ requests through such sites from present or past pupils.

g) Give or show anything to a pupil which could be construed as pornographic or inappropriate.

h) Engage with pupils in any other way online in an unacceptable manner.

18.6 Working within a pupil's home

Tutors must:

a) Ensure a parent or other approved adult is present when tuition is taking place. If a parent/guardian wishes to go out (e.g. shopping) leaving the tutor alone, the tutor must make clear arrangements with the parent/guardian about arrangements for dismissal at the end of the session. Tutors must not leave children under the age of 12 alone should the parent not return on time. If the parent is late returning the tutor should contact Ivy Education.

b) Maintain their timesheet by recording the times of all tuition sessions on TutorCruncher.

c) Work with the room door always left open.

d) If at all possible, tutoring should not take place in a pupil’s bedroom.

e) Remain in the designated room of the home for the tuition session.

f) Always inform the parent/guardian if the pupil becomes upset or distressed.

g) Always report any situation where a pupil becomes upset or distressed to Ivy Education.

h) Tuition may take place in another venue other than the pupil’s home. This must be agreed with the parent/guardian in advance along with arrangements for meeting and dismissing the pupil.

18.7 Breach of the Professional Code of Conduct

Failure to follow the professional code outlined above is considered serious and may lead to termination of any working agreement.

19. Safer Recruitment Procedures

a) Ivy Education takes its duty of care to pupils seriously and it is committed to preventing people who pose a risk of harm from working with children. All tutors are thoroughly vetted, and the recruitment procedures used adhere to the guidance for safer recruitment outlined in KCSIE.

b) Ivy Education also aims to recruit tutors who share its commitment to safeguarding children and aims to ensure that no job applicant is treated unfairly by reason of a protected characteristic as defined within the Equality Act 2010. (Candidates with a disability who are invited to interview should inform Ivy Education of any necessary reasonable adjustments or arrangements to assist them in attending the interview.)

c) All applicants must complete an Ivy Education Application Form, CVs will not be accepted in substitution although they may still be provided. The application form must be signed by the candidate to verify that all information is true.

d) The application form must include months and years, detailing the occupation of the candidate from leaving school to the point of application, without any periods of time being omitted.

e) Successful applicants will be required to obtain an enhanced certificate from the Disclosure and Barring Service (“DBS”). Candidates who are registered with the DBS update service must agree to have their DBS checked though the update service.

f) All applicants will be required to show Ivy Education the original copy of their DBS certificate.

g) Current and previous employers will be asked about disciplinary offences, including disciplinary offences relating to children (whether the disciplinary sanction is current or time expired), and whether the candidate has been the subject of any child protection allegations or concerns and if so the outcome of any enquiry or disciplinary procedure.

h) Interviews will be conducted in person and during each interview safeguarding knowledge and awareness will be explored.

i) All candidates invited to a preliminary interview must bring the following documents:

1. photographic proof of identity e.g. passport or driving licence
2. the original certificates of any educational and/or other professional qualifications that are necessary or relevant for the post
3. A utility bill or financial statement issued within the previous three months – this must show the applicant’s current name and address (not a mobile phone bill)
4. Where appropriate, any documentation evidencing a change of name
5. Where the candidate is not a citizen of the UK proof of entitlement to work and reside in the UK.
6. If a DBS is already held, the original DBS certificate

Please note that originals of the above are necessary: photocopies or certified copies are not sufficient.

Copies of the original documents will be made during the interview and the original documents returned to the applicant immediately.

19.1 Joining Ivy Education

Joining Ivy Education will be conditional upon:

1. Verification of identity
2. Evidence of the right to work in the UK
3. A satisfactory enhanced DBS disclosure with Barred List check, the original certificate must be presented to Ivy Education
4. Satisfactory references: Comprising of two professional references, if applicable from the heads of previous employing schools, and one character reference who has known the applicant for at least five years. Testimonials (often headed “To whom it may concern”) are not acceptable and not regarded as references.
5. A prohibition from teaching check
6. Verification of professional qualifications
7. Verification of employment history
8. For those candidates who have been resident in an EU country, a check of the European Economic Area (EEA) teacher sanctions and restrictions.
9. Where the candidate has worked or been resident overseas, such checks and confirmations as Ivy Education may consider appropriate. (This may include an overseas police clearance from any country where the applicant has resided for three months or more during the past five years.
10. A declaration by the candidate of satisfactory medical fitness to carry out the role envisaged

Single Central Register of all Employment Checks

A record of all the employment checks listed above will be recorded by Ivy Education on a Single Central Register in line with the practice for all UK schools.

Referral to the DBS and NCTL

The checks above are carried out prior to tutors joining Ivy Education; however, Ivy Education also has a legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child, and who has been removed from working (paid or unpaid) in regulated activity, or would have been removed had that person not left. A referral may also be made to the Secretary of State for Education which may result in a prohibition order from the NCTL.