Safeguarding and Child Protection Policy

Technology Triumphs Ltd

This policy explains how Technology Triumphs Ltd responds to safeguarding concerns arising through its online resources, submitted learner evidence, assessment feedback and email communication. It applies to directors, employees, assessors, subcontractors, volunteers and anyone acting on TT’s behalf. A child is anyone under 18. Concerns about an adult at risk are referred through the appropriate adult safeguarding route.

Status: Revised draft updated 20 October 2026

Next review: within 12 months of adoption, or sooner following a significant incident or relevant change.

Policy owner: Victoria Rothwell.

Our online provision

TT supplies pre-recorded learning resources and assesses materials submitted by learners or their supporting adults. Families may contact enhanced DBS checked assessors by email about coursework and assessment. TT does not work in a supervisory role with children and provides no face to face tuition. The delivery arrangement assumes that a parent, carer or other supporting adult supervises the learner at home, including practical activities. Where TT’s resources are used within alternative provision, an external tutor works with and supervises the learner, while TT supplies the resources and assesses submitted materials only.

TT’s assessors do not take over the supporting adult’s or external tutor’s responsibility for day-to-day supervision, physical safety or delivery of the wider educational programme. Relevant arrangements must be clear to families and commissioning organisations. TT remains responsible for safe conduct within its own service and for recognising, recording and reporting concerns that come to its attention through email, written work, photographs, video evidence or assessment. Any proposed change to the delivery model requires a fresh review of safeguarding responsibilities before implementation.

Report a concern

Contact	How to contact
Designated Safeguarding Lead or DSL	Victoria Rothwell, also known as Pip 07872307355 technologytriumphs@outlook.com
DSL unavailable or concern about the DSL	Do not wait for Victoria. Contact children’s social care for the child’s location, or the LADO for an allegation about an adult working with children. Call emergency services for immediate danger. Internal deputy and independent escalation contacts must be completed before adoption.
Immediate danger in the UK	Call 999. For a learner abroad, contact emergency services where the child is located. TT email is not an emergency service.
Kent child welfare concerns	Front Door: 03000 41 11 11 Out of hours: 03000 41 91 91 Kent Children’s Portal: kccchildrens.kent.gov.uk
Kent allegations about adults working with children	Use the LADO referral route in the Kent Children’s Portal. General advice: LESAS enquiry form on the KSCMP LADO page. Parent referral email: lesasenquiries@kent.gov.uk. See section 5.

 

 

DSL details are reproduced from the supplied policy and require confirmation. Kent is used as the provisional organisational contact area; the child’s own local authority may be elsewhere. Verified external contact routes are listed in section 12.

1 Principles and safeguarding framework

The child’s welfare and best interests guide every decision. We listen to children, take their wishes seriously, explain what will happen and adapt our communication to their age and needs. Their wishes are considered and recorded, but cannot prevent necessary protective action. Children must not be blamed for abuse or expected to investigate it.

TT will provide equal protection, respect dignity, privacy and family life, and make reasonable adjustments. We will not tolerate sexism, misogyny, misandry, racism, homophobia, biphobia, transphobia, disability discrimination or other harassment. Staff challenge discriminatory behaviour safely and report it. A child’s identity, disability, culture or family circumstances must never be treated as proof of risk.

TT takes account of relevant safeguarding principles in Keeping Children Safe in Education 2026 and Working Together to Safeguard Children 2026, proportionate to its role as an online resource and assessment provider. References to school guidance do not describe TT as a school or a provider of daily supervision, pastoral education or a full curriculum. The directors confirm which statutory and commissioning requirements apply to TT’s actual activities and meet those requirements. Resource and assessment provision alone must not be used to assume exemption from a legal duty that otherwise applies.

Relevant frameworks include the Children Acts 1989 and 2004, the Equality Act 2010, the Human Rights Act 1998 where applicable, the Safeguarding Vulnerable Groups Act 2006, the Sexual Offences Act 2003, UK GDPR and the Data Protection Act 2018, the Children and Families Act 2014 and the SEND Code of Practice. Prevent responsibilities are addressed in section 8. For learners outside England, the DSL must use the applicable local safeguarding law and referral arrangements.

2 Roles and accountability

Victoria Rothwell as Designated Safeguarding Lead

Victoria Rothwell is TT’s Designated Safeguarding Lead or DSL. She receives and records concerns arising through TT’s service, assesses the need for referral, contacts relevant safeguarding agencies and follows up action. She supports assessors in handling disclosures and safe email communication and oversees safeguarding information, recruitment checks and policy review. Where another organisation provides tuition or supervision, the DSL coordinates relevant concerns with its safeguarding lead where safe and appropriate. She does not replace the supervising provider’s safeguarding arrangements or undertake day-to-day welfare monitoring of learners.

TT must publish a trained deputy or equivalent documented cover arrangement and the hours when the DSL or cover can be reached. Until cover is established, staff use direct external referral routes whenever the DSL is unavailable. Nobody waits for permission to protect a child or make a referral.

Directors and governance

TT’s directors are accountable for effective safeguarding arrangements and adequate resources. They approve the policy, check implementation and address any failure. At least annually they review anonymised safeguarding themes, referral outcomes, staff checks and training, online controls and actions from incidents. An appropriate independent person or external safeguarding adviser must provide oversight where Victoria’s

 

 

DSL and leadership roles create a conflict. Allegations about Victoria bypass her and go directly to the LADO; she must not investigate her own conduct.

Staff and assessors

Staff and assessors must understand this policy, maintain professional boundaries, recognise concerns within the information available to them, report promptly and keep accurate records. Safeguarding induction focuses on these responsibilities and the reporting route. Relevant sections of KCSIE may be used as reference material where appropriate to the role or required by a commissioning arrangement. Staff do not undertake routine welfare surveillance, attendance monitoring or preventative teaching on TT’s behalf. They must not assume that a parent or external tutor has dealt with a concern: they check that their report has reached the DSL and escalate unresolved risk.

Families and learners

Families receive this policy and information explaining TT’s limited role and how to report concerns. A parent, carer or supporting adult is responsible for supervision at home. Where an external tutor supports alternative provision, that tutor or their employing organisation is responsible for the supervision and direct work they provide; the commissioner must clarify the wider responsibilities in the placement arrangements. Families or commissioners are asked to provide current contact details and relevant support information. Learners can report concerns themselves and will be listened to even where TT normally communicates through an adult’s email address. No learner needs a parent’s permission to report abuse.

3 Recognising and responding to a concern

Recognise

A concern may arise from a disclosure, an email, a change in behaviour or engagement, written work, an injury or something visible or audible in submitted evidence. Abuse may happen at home, online or elsewhere. Proof is not needed to report a concern. Consider the child’s circumstances and any pattern across small concerns, rather than interpreting one sign in isolation.

Respond to a disclosure

• Stay calm, listen and take the child seriously. Reassure them that telling was the right thing to do and that abuse is not their fault.
• Do not promise secrecy. Explain that information will be shared only with people who need it to help keep them safe.
• Let the child use their own words. Ask only minimal, open questions needed to clarify immediate safety, such as “Are you safe now?” Do not ask leading questions, seek proof or ask them to repeat their account.
• Do not confront an alleged abuser, investigate, arrange mediation or contact a parent automatically. A parent may be implicated or contact may increase risk.
• For an email disclosure, preserve the original email securely, report it immediately and agree a safe reply route. Do not copy in a parent if that could expose the child to harm. Do not delay urgent protective action while waiting for an email reply.
• Where urgent action is required, establish the child’s current location if possible. Contact emergency services or children’s social care without waiting for the DSL.

 

Record

Make a factual record as soon as possible, including the child’s exact words, date and time of receipt, how the concern arose, observations, immediate actions and everyone contacted. Separate fact from interpretation. Record the child’s wishes, current location if known, relevant communication needs and any concern about contacting parents. Sign or identify the author and date the record. Section 11 provides a recording template.

Report

Report to Victoria immediately on discovering a safeguarding concern, by telephone for urgent concerns, followed by a secure written record. Do not leave an urgent concern in an inbox or voicemail without checking it has been received. Non-emergency concerns must still be reported the same working day. If the DSL is unavailable, use cover arrangements or contact children’s social care directly. Concerns about staff follow section 5.

Refer and follow up

The DSL reviews a report on receipt and determines the next action that day. Suspected significant harm, abuse or immediate danger requires immediate referral to children’s social care and/or police. A referral is made to the authority where the child lives, with urgent coordination where the child is currently elsewhere. Staff can refer directly at any time and inform the DSL afterwards unless she is implicated.

Where the concern does not meet a child protection threshold, the DSL considers family help or other appropriate support, with informed family involvement where safe. Record the decision, reasons, agreed support, owner and review date. Seek professional advice if unsure. Consent is sought where appropriate for support, but is not a condition for necessary protective information sharing.

The DSL confirms receipt of an external referral, records the reference and follows up without delay if risk remains or no response is received. Use the authority’s escalation or professional challenge procedure if a response does not protect the child. Re-refer if circumstances worsen. Keep the child and safe carers informed as appropriate; do not disclose information that would compromise protection or an investigation.

 

4 Safeguarding action flowchart

Use this flowchart alongside the detailed procedure in section 3. Reporting and recording must not delay emergency help. The same reporting route applies to online and offline harm.

5 Allegations and concerns about adults

Concerns meeting the harm threshold

Report immediately if a person working for TT may have harmed a child, committed an offence against or related to a child, behaved towards children in a way that indicates a risk of harm, or behaved in any setting in a way that may make them unsuitable to work with children. This includes conduct outside TT and online behaviour.

Report to Victoria unless she is the subject of the concern. In that case, report directly to the Local Authority Designated Officer or LADO and to a non-implicated director or the independent safeguarding contact once appointed. A learner, family member or member of staff may contact the LADO directly. Allegations must never be routed solely through the accused person.

 

 

The non-implicated case manager contacts the relevant LADO without delay and within one working day of becoming aware of an allegation meeting the harm threshold. Where unsure, seek LADO advice within the same timescale. Immediate danger or suspected crime also requires police and/or children’s social care referral; the LADO process does not replace child protection action. The case manager acknowledges a report within one working day where it is safe to do so. This is an acknowledgement, not a promised investigation outcome.

Preserve original evidence securely and record the allegation and actions. Agree next steps with the LADO before undertaking substantive enquiries or telling the subject of the allegation. Risk assess continued access to children, emails and evidence. Restrict duties or suspend where needed to protect children and records; suspension is not automatic. Provide appropriate support and fair treatment for both the child and staff member, without prejudging the outcome.

The case manager follows the LADO’s advice on investigations, communication, updates and information sharing, including notification to commissioners where required. Record decisions and outcomes confidentially, review risk and lessons, and make required professional or DBS referrals. An individual leaving TT does not end the process.

Low level concerns

A low level concern is behaviour inconsistent with TT’s professional code that does not appear to meet the harm threshold, however small or uncertain. Examples include over-familiar emails, unnecessary personal contact, favouritism or use of an unapproved private channel. “Low level” does not mean unimportant.

Report the same working day to Victoria; concerns about her use the independent route or LADO advice. Encourage self-reporting of boundary lapses. Record the concern, context and actions in a restricted staff concern log. The case manager reviews it promptly, normally within one working day, acts proportionately and checks for patterns. Escalate to the LADO if the threshold may be met or remains unclear. Do not dismiss a pattern because each incident seems minor.

Duty to refer to the DBS

TT’s classification as a regulated activity provider must be assessed against the activities actually carried out and the relevant legal criteria. Providing resources, assessment or email contact does not, by itself, settle that classification; neither does the absence of a supervisory role establish exemption. TT obtains role-specific DBS eligibility advice where needed. Where TT is a regulated activity provider and the statutory referral conditions are met, it must refer the individual to the DBS, including where a person is removed from regulated activity, or would have been removed had they not left, because of relevant conduct, the harm test or relevant offences. Police or LADO referral does not discharge that separate duty. The case manager records the assessment, seeks advice where necessary and makes any required referral promptly. Resignation or a settlement must not prevent a required referral.

Whistleblowing and challenging unsafe practice

Staff raise unsafe practice immediately and must not suffer retaliation for doing so in good faith. If management is implicated or fails to act, staff contact the appropriate external safeguarding service or police. A complaint about assessment may also contain a safeguarding concern: deal with the protection issue promptly alongside any complaints process.

 

6 Safe working recruitment and training

Email contact and positions of trust

Assessors hold professional authority and must not exploit a learner’s dependence, admiration or need for support. Staff must never pursue sexual, romantic, financial or other exploitative relationships with learners. The criminal law on positions of trust applies where its legal conditions are met, including for some 16 and 17 year olds; TT’s professional boundaries apply to all staff regardless of the precise legal category.

• Use only TT-approved email accounts and course systems. Keep communication relevant to learning, support or safeguarding, courteous and suitable for the learner’s age. Do not move conversations to private social media, personal messaging, disappearing messages or secret accounts.
• Ordinary course emails should use the registered parent or carer contact and, where agreed, copy them into learner correspondence. Do not apply this automatically to disclosures: consult the DSL about a safe contact route. Retain appropriate records of direct learner contact.
• Do not share unnecessary personal information, request secrecy, send sexualised or humiliating comments, arrange private meetings, offer inappropriate gifts or request unnecessary images. Do not contact a learner privately after leaving TT.
• Use respectful, accessible feedback. If inappropriate behaviour is observed, interrupt or stop the activity where possible and safe, name the boundary calmly, support the affected child and report the incident. If it appears only in submitted evidence, record and report rather than contacting an alleged abuser.
• Receive practical evidence through approved systems. Ask families to avoid other children, identifying details or private areas in photos and videos. Marketing use requires separate informed consent and the child’s agreement where appropriate; refusing publicity must not disadvantage a learner.

Safer recruitment and DBS checks

Before access to learners or identifiable evidence, TT verifies identity, employment history and gaps, relevant qualifications and references, considers suitability and obtains the legally appropriate DBS check. TT’s assessors are enhanced DBS checked. For other roles, determine eligibility before requesting an enhanced check; a children’s barred list check is obtained only where the role is eligible. No barred person may undertake prohibited regulated activity. Appropriate additional checks are considered for time spent abroad.

Proposed TT renewal standard: repeat eligible enhanced DBS checks at least every three years, with earlier checks if suitability concerns arise. This implements the reviewer’s requested organisational standard; DBS certificates have no statutory three-year expiry. TT may additionally use eligible Update Service checks with consent. Record the check type, date, result, decision and renewal due date securely. DBS clearance is one part of safer recruitment, not a guarantee of safety. Staff report relevant changes in suitability immediately.

Safeguarding induction and staff competence

Assessors and other staff receive safeguarding information and induction appropriate to their role in receiving coursework, assessing evidence and communicating by email. They must know how to recognise a possible concern, respond to a disclosure, preserve relevant information safely and contact the DSL or an external safeguarding agency. TT checks understanding of these procedures and keeps a record of relevant learning and briefings. Staff are not expected to deliver safeguarding lessons, radicalisation training, RSE or a wider pastoral curriculum to learners.

The DSL maintains knowledge appropriate to receiving concerns, making referrals and managing allegations in this delivery model, using suitable safeguarding learning and professional advice. TT reviews staff learning needs when responsibilities, risks, guidance or commissioning requirements change, and arranges relevant

 

 

updates or refresher learning where needed. This policy does not prescribe a blanket annual course programme, fixed course levels or specialist annual Prevent training. Any specific legal, contractual or agreed commissioner training requirement still applies and must be recorded and met. The reviewer’s separate request for annual staff training remains a matter for agreement before the policy is accepted; see Appendix A.

7 Abuse and exploitation

Staff consider the following indicators in context and report concerns using section 3. A child may show no obvious signs. Disability, distress or unusual creative content alone is not evidence of abuse; do not dismiss concerns as part of a diagnosis or infer abuse from one sign.

Physical abuse emotional abuse sexual abuse and neglect

Physical abuse may include hitting, shaking, poisoning, burning or other injury. Indicators include unexplained injuries, inconsistent explanations, fear of a person or violence heard in video evidence. Emotional abuse can involve threats, humiliation, coercion, rejection, isolation or making a child witness abuse; signs may include marked fear, withdrawal or repeated self-blame.

Sexual abuse includes contact and non-contact abuse, grooming, sexual coercion and exploitation, including online abuse. Possible signs include sexualised messages, secrecy about an adult contact, distress, unexplained gifts or disclosures. Neglect involves persistent failure to meet basic physical or emotional needs, including food, care, medical treatment, safety or supervision. In remote provision, unsafe conditions in evidence or repeated disclosures of unmet needs may raise concerns; poverty alone must not be equated with neglect.

Child on child abuse and harmful sexual behaviour

Children may harm other children through bullying, discriminatory harassment, intimidation, coercive relationships, sexual harassment or violence, and sharing sexual images. Harm can occur outside TT even without group teaching. Do not dismiss it as banter or normal development. Harmful sexual behaviour means sexual behaviour that is inappropriate to age or development, harmful, coercive or abusive; seek specialist advice where uncertain.

Report immediately, support the affected child and consider the needs and risks of all children involved. The DSL records a safety assessment covering contact, online access, retaliation and support, refers to police or social care where required and coordinates with safe carers and professionals. Do not use mediation to respond to sexual violence or coercion, or require a child to manage contact with the alleged perpetrator.

Sexual and criminal exploitation county lines and modern slavery

Child sexual exploitation or CSE and child criminal exploitation or CCE involve power imbalances and manipulation, threats or control. County lines may involve children carrying drugs or money for criminal networks. Modern slavery includes trafficking, forced labour and domestic servitude. Indicators include unexplained money or gifts, debts, multiple phones, threatening contacts, unexplained journeys, missing episodes or control by another person. Apparent agreement or offending behaviour does not remove the child’s victim status. Staff report; the DSL seeks coordinated protection and specialist advice.

Domestic abuse and serious violence

Children can be victims of domestic abuse through seeing, hearing or experiencing its effects, including coercive control. An abusive adult may monitor email and devices. Consider safe contact before communicating with carers. Serious violence concerns may include threats, weapons, gang coercion,

 

 

 

exploitation or injuries. Staff do not confront suspected offenders or attempt to remove weapons. Call emergency services for immediate threats and refer other concerns promptly.

Extra familial and contextual safeguarding

Risk can arise in friendship groups, neighbourhoods, relationships, workplaces or online communities rather than within the family. TT does not monitor these settings, but the DSL records relevant information that comes to TT’s attention and refers concerns to agencies able to address them. A supporting adult’s or external tutor’s supervisory role does not prevent TT from reporting a concern arising through its own service.

8 Specific risks and support

Mental health and self harm

Distress, self-harm, eating difficulties or serious changes in wellbeing may be a safeguarding concern, particularly alongside abuse or exploitation. Staff listen, avoid judgement and report concerns; they do not diagnose or provide therapy. Immediate risk of serious injury or danger requires emergency help. The DSL agrees proportionate support with safe carers and relevant professionals, such as the GP or local children’s mental health service, and reviews wellbeing alongside adjustments to learning. Ordinary support or course flexibility must not replace a protective referral.

Prevent radicalisation and Channel

TT does not deliver Prevent lessons, radicalisation education or specialist counter-terrorism training to learners. Its assessors’ role is to report relevant concerns that become apparent in correspondence or submitted evidence, using the same safeguarding route as other concerns. Examples include coercive extremist contact or encouragement of terrorist violence. Do not equate religion, ethnicity, political debate or lawful expression with terrorism. The DSL seeks local Prevent or police advice where appropriate and makes a relevant referral; immediate threats go to police. Channel is a voluntary multi-agency support programme delivered by the relevant agencies. The directors check whether any statutory Prevent duty or commissioning conditions apply to TT and meet them where applicable; this policy does not assume either that TT is a specified authority or that its delivery model exempts it.

Honour based abuse forced marriage and harmful practices

So-called honour based abuse can include threats, violence, forced marriage, female genital mutilation or FGM, and breast ironing or flattening. Abuse may also be justified through beliefs about faith, possession or witchcraft. Culture or religion never excuses abuse. Do not contact or mediate with family or community members where this may increase risk. Refer promptly to specialist police and social care services; contact emergency services if a child is in immediate danger.

Marriage involving a person under 18 in England and Wales is a particular safeguarding concern. Staff report threats or plans promptly. For FGM, staff never examine a child or request intimate photographs. Suspected or threatened FGM follows child protection procedures. Where the individual is within the statutory mandatory reporting duty and a girl under 18 directly discloses known FGM, that professional makes the required police report personally, normally by the next working day, and informs the DSL. The DSL must not substitute her referral for that personal legal duty. TT checks applicability to each role and setting.

Abduction and community safety

Report threats of abduction, stalking, harassment, coercion or unsafe community contact immediately. Do not disclose a child’s address, schedule or contact details to an unverified person. Verify identity and authority

 

before sharing information, including with a person claiming to be a parent. Relevant court restrictions and safety plans guide communication. Suspected abduction or immediate danger requires police action.

Pregnancy and parenting

A pregnant learner or young parent is offered respectful support and adjustments, with specialist signposting as needed. Consider coercion, exploitation, domestic abuse, age and power imbalance, and risks to an unborn or born baby. Pregnancy alone is not a reason to exclude the learner or assume abuse. Sexual activity involving a child under 13 requires urgent child protection consideration and referral.

9 Learners who may need additional protection

SEND and communication needs

Children with special educational needs and disabilities may face barriers to disclosing abuse, dependence on adults, isolation, bullying or difficulty recognising online risk. Staff must not attribute injuries, behaviour changes or distress solely to SEND. Use accessible language, shorter questions, processing time, written or alternative communication and appropriate specialist support. Listen directly to the child rather than relying only on an adult’s account.

TT makes reasonable adjustments to the resources, assessment and communication it provides and considers relevant support information from families, tutors and commissioners. The supervising adult or external tutor provides day-to-day support for the learner. TT has regard to the SEND Code of Practice where relevant and fulfils duties applying to its activities or contracts. Staff make safeguarding information and reporting routes accessible, taking account of communication needs; they must not assume a child can readily describe harm.

Elective home education and education otherwise than at school

Home education is not itself a safeguarding concern. TT supplies resources and assessment for families choosing home education and for learners receiving education otherwise than at school or other alternative arrangements. At home, a supporting adult supervises the learner. In alternative provision using an external tutor, that tutor provides the direct work and supervision; TT provides resources and assessment of submitted materials only. The family or commissioner retains responsibility for arranging the wider suitable education programme. The DSL liaises with relevant professionals about specific concerns where appropriate and shares only necessary information.

TT does not operate a school attendance register, supervise learning sessions or monitor a child’s daily whereabouts. Learners may pause submissions, and lack of coursework alone does not establish absence from suitable education or neglect. The supervising tutor or commissioning organisation manages attendance and welfare checks under its own arrangements. TT supplies factual assessment or submission information where agreed and reports any concern that comes to its attention. If unexpected disengagement occurs alongside disclosures or other indicators of harm, the DSL reviews the available information and refers where necessary. TT must not claim that a child is safe simply because an adult or tutor is expected to supervise them.

Children with a social worker and care experienced learners

Where TT is told that a child has a social worker, a protection or support plan, or is looked after or previously looked after, the DSL records relevant contacts and the responsibilities agreed for TT’s resource and assessment role. Where necessary, she shares concerns with the social worker, supervising provider or commissioner and contributes relevant factual information. TT does not assume responsibility for managing the child’s wider plan. Refer fresh concerns promptly even where a plan already exists. Clarify who may consent, receive information and make decisions; do not assume a foster carer has every parental responsibility.

 

Young carers and family pressures

Caring responsibilities can affect wellbeing and learning. Offer flexible support and consider referral to appropriate young carer services or family help. Homelessness, insecure housing, parental imprisonment or court proceedings can create stress and practical barriers. Staff avoid judgement, seek support for the child and report abuse or unmet protective needs rather than treating the circumstance alone as evidence of harm.

Language migration and identity

For children learning English as an additional language, offer accessible communication and a suitable independent interpreter where needed. Do not use an alleged abuser, or a child, to interpret a disclosure. Refugee and asylum seeking learners may need support for trauma, displacement or exploitation; immigration status must not obstruct protective action.

Lesbian, gay, bisexual, trans or gender questioning children may experience bullying, isolation or targeting. Listen respectfully, challenge harassment and base support on the individual’s welfare. Do not assume identity is a risk in itself or disclose sensitive information automatically. The DSL considers safe family involvement, the child’s wishes and current applicable guidance, seeking specialist safeguarding advice where needed.

Children and the courts

Family or criminal court proceedings may affect a child’s safety, authorised contacts and wellbeing. TT considers relevant verified orders, supports continuity of learning and limits information to those entitled to receive it. Staff do not offer legal advice, decide disputes between adults or question a child for evidential purposes.

10 Online safety and prevention

The four Cs

Risk	Examples and TT response
Content	Harmful, violent, pornographic, extremist or misleading material, including AI-generated material. Review TT resources and external links; report harmful content.
Contact	Grooming, impersonation, coercion or unwanted adult or peer approaches. Use approved channels and verified contacts; report attempts to move to private contact.
Conduct	Bullying, threats, harassment or sharing sexual images, including deepfakes. Challenge safely, protect the child and follow safeguarding procedures.
Commerce	Scams, fraud, gambling, manipulative advertising or exploitation involving money. Provide practical warnings and route concerns to the DSL where a child may be at risk.

Filtering monitoring and email security

TT does not control or supervise learners’ use of home internet connections, phones or smart devices. The supporting adult or external tutor manages supervision and appropriate device use in their setting. TT’s responsibilities concern the safety of its own resources, email contact, assessment systems and handling of submitted evidence. Families and tutors may be signposted to suitable online safety information where relevant; TT does not provide a general online safety curriculum or claim to monitor learners’ wider online activity.

The directors must establish and document proportionate controls for systems TT controls: approved accounts, secure authentication including multi-factor authentication where supported, anti-malware and email protections, restricted staff access, secure evidence storage, appropriate filtering on managed devices

 

and a clear process for reporting suspicious messages or harmful material. Specify the platform, responsible person and monitoring arrangements before adoption; do not describe unverified controls as already operational.

Monitoring relates to systems TT controls and concerns reported to it; it is not continuous monitoring of children or their home devices. The DSL and those responsible for TT’s systems review access, email and evidence-handling risks when this policy is reviewed and when systems or risks change. Document the controls actually in place, their limitations and any action needed. Staff report suspected compromise or harmful material promptly and preserve relevant logs safely. Any specific statutory or commissioned filtering or monitoring requirements must be confirmed and met where applicable.

Sexual images and harmful digital evidence

If a concern involves nude or semi-nude images of a child, including altered or AI-generated images, staff must not request, forward, copy, print, save to personal devices or deliberately view them. Do not ask a child to send evidence. Stop viewing if content is encountered accidentally, note the source and report immediately. The DSL seeks police or social care advice and arranges secure handling of any material already received. Do not delete original material before advice if doing so may destroy evidence. Avoid circulating it while preserving the location and reporting facts.

Information for families and questions from learners

TT explains its resource and assessment role, approved communication channels and how families, tutors and learners can raise concerns. It does not deliver a preventative safeguarding curriculum, PSHE programme or lessons on radicalisation. The supporting adult, external tutor or commissioning provider arranges wider safety education as appropriate to the learner’s educational arrangements. TT can signpost suitable resources without claiming to deliver that wider programme. Concerns arising through TT’s own service are reported under this policy.

TT does not provide Relationships and Sex Education as part of its resource and assessment service. Staff respond respectfully to questions, stay within their competence and refer questions outside the service to appropriate support. Do not invite personal sexual disclosures or provide private counselling. A disclosure or concern about abuse, coercion or unsafe relationships goes to the DSL rather than being treated only as a curriculum question. Any requirement to provide additional education under a specific legal or commissioning arrangement must be clarified before TT accepts that responsibility.

11 Records information sharing and review

The DSL keeps child protection records separate from ordinary coursework and routine customer records, in secure storage accessible only to authorised people. Protect accounts and devices, avoid shared passwords and personal email forwarding, and remove access promptly when staff leave. Records include a chronology, the original concern, referrals, agency responses, decisions, support and review dates.

Share relevant information accurately, securely and proportionately with professionals who need it to protect a child. Verify the recipient and record what was shared, why and the lawful basis. Data protection does not prevent necessary safeguarding sharing. Explain sharing to the child and safe carers where appropriate, but do not seek consent or notify someone when doing so would increase danger or prejudice an investigation.

TT must approve a written retention schedule before adoption covering child protection records, allegations, low level concerns and recruitment information. The DSL checks applicable statutory, contractual and local requirements rather than applying one period to every record. Review retention, record lawful deletion and preserve records subject to investigation or legal hold. Where relevant, transfer safeguarding records securely to an appropriate receiving professional and confirm receipt.

 

 

Safeguarding concern record template

• Child’s name, date of birth, current address and location if known; safe contact details and relevant professional contacts.
• Reporter’s name and role; date and time observed, received, recorded and reported.
• How the concern arose; exact words used; factual observations; source of relevant evidence. Do not attach sexual images.
• Immediate safety concerns; child’s wishes; communication needs; whether contact with a parent or particular adult may be unsafe.
• Action taken; people and agencies contacted; times, reference numbers and receipt confirmation.
• DSL assessment; decision and reasons; lawful information sharing; named action owner and next review date.
• Follow-up, escalation, support and outcome. Record amendments with an audit trail rather than overwriting the original account.

Annual review and implementation

Victoria Rothwell reviews the policy at least annually, with approval by the directors and independent input where appropriate. Review sooner after serious incidents, changes in delivery, commissioner requirements, contact routes or legislation. Keep a dated version record, make the adopted policy available to families, and obtain staff confirmation that they have read and understood it. Check external contact details at review and before making a non-emergency referral; never delay emergency action to verify an administrative detail.

Related procedures cover staff conduct, safer recruitment, complaints and whistleblowing, anti-bullying, acceptable use of TT systems, privacy and retention, evidence handling and marketing consent. The procedures here apply within TT’s resource and assessment role. TT does not provide premises, adult to child supervision ratios, in-person behaviour management or a full pastoral programme. Supporting adults, external tutors and commissioning providers retain their respective responsibilities. Any expansion into tuition, live activities or supervision requires a fresh assessment and revised arrangements before implementation.

12 Source and contact directory

Official guidance and external contact routes checked 14 October 2026. Use the child’s own local safeguarding partnership and children’s social care for referrals outside Kent. For international learners, identify the child’s location and the relevant local emergency and child protection agencies.

Keeping Children Safe in Education 2026
https://www.gov.uk/government/publications/keeping-children-safe-in-education–2
Out-of-school settings safeguarding guidance for providers
https://www.gov.uk/government/publications/keeping-children-safe-in-out-of-school-settings-code-of-practice

Working Together to Safeguard Children 2026
https://www.gov.uk/government/publications/working-together-to-safeguard-children–2

Kent LADO and LESAS contact routes and enquiry form
https://www.kscmp.org.uk/procedures/local-authority-designated-officer-lado

Kent Children’s Portal for welfare and LADO referrals
https://kccchildrens.kent.gov.uk/web/portal/pages/home

 

 

DBS referral duties
https://www.gov.uk/government/publications/dbs-guidance-leaflets/the-legal-duty-to-refer-to-dbs

Prevent duty guidance
https://www.gov.uk/government/publications/prevent-duty-guidance

FGM mandatory reporting guidance
https://www.gov.uk/government/publications/mandatory-reporting-of-female-genital-mutilation-procedural-information