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Child Protection and Safeguarding Policy

Reference: ET-CPSP-001Last reviewed: July 2026

1. Policy Statement

Ember Learning Ltd is committed to safeguarding and promoting the welfare of all students and young people with whom it works. This commitment is unconditional and underpins every aspect of our organisation.

Ember Learning provides online small group teaching in mathematics and English to secondary-aged students aged 11 to 16. Our students are referred to us by commissioning bodies, which may be Local Authorities, Multi-Academy Trusts, or individual schools (‘Commissioners’). Where provision is arranged by a Local Authority, this is principally as a form of non-statutory alternative provision under Section 19 of the Education Act 1996 and/or the Children and Families Act 2014. Where a school commissions directly, the school acts as the responsible commissioning body. Sessions are delivered via an approved online platform by self-employed teachers.

We believe that:

  • The welfare of every child is paramount, regardless of age, ability, disability, gender, race, religion, sexual orientation, or background
  • All children, whatever their circumstances, have the right to be protected from harm
  • Every member of our organisation — including self-employed associates — shares responsibility for safeguarding and has a duty to act if they have concerns
  • Safe and effective safeguarding practice must be embedded in our culture, our recruitment, our training, and our operational delivery

This Policy is informed by and consistent with Keeping Children Safe in Education (DfE, 2025) (‘KCSIE’), Working Together to Safeguard Children (HM Government, 2023), and all applicable legislation. Although Ember Learning is not a registered school, we apply KCSIE principles as best practice because we deliver regulated activity with children.

2. Scope

This Policy applies to:

  • All Company directors and employees
  • All self-employed teachers engaged by Ember Learning, regardless of the frequency or nature of their engagement
  • Any volunteer or observer present during a teaching session

Self-employed status does not reduce, remove, or limit any individual's safeguarding obligations. Any person working with students under this Policy must comply with it fully. The Policy covers all teaching sessions delivered via the approved session platform, all administrative and management activities, and any other activity in which Ember Learning staff or associates come into contact with children.

3. Legal and Regulatory Framework

  • Keeping Children Safe in Education (DfE, 2025) — applied as best practice
  • Working Together to Safeguard Children (HM Government, 2023)
  • The Children Act 1989 and the Children Act 2004
  • The Children and Families Act 2014
  • Section 19 of the Education Act 1996
  • The Safeguarding Vulnerable Groups Act 2006
  • The Protection of Freedoms Act 2012
  • The Counter-Terrorism and Security Act 2015 (Prevent duty)
  • The Online Safety Act 2023
  • Information sharing: advice for practitioners (HM Government, 2024)
  • What to do if you're worried a child is being abused (DfE, 2015)

4. Key Personnel and Responsibilities

  • Designated Safeguarding Lead (DSL) — Jack Bradley. Responsibility for safeguarding policy and practice. Point of contact for all safeguarding concerns. Makes decisions on referrals to statutory agencies. Maintains safeguarding records. Liaises with Commissioners' DSLs. Available during all session hours.
  • Deputy DSL — Mahesh De Zoysa. Acts as DSL in the DSL's absence. Trained to the same level. Has full access to safeguarding records and session recordings. May make safeguarding referrals where the DSL is unavailable.
  • Company Directors — Jack Bradley, Kate Bradley, and Mahesh De Zoysa. Responsibility for ensuring the organisation has an effective safeguarding policy, adequate DSL cover, and that all associates complete safer recruitment checks and mandatory training before working with students.

4.1 DSL availability. The DSL must be contactable during all hours in which sessions are scheduled. Where the DSL is unavailable (for example due to leave or illness), the Deputy DSL must be available to cover.

4.2 All associates. Every teacher shares responsibility for the welfare of students. Where an associate identifies or suspects a safeguarding concern, they must act immediately in accordance with Section 8.

5. Types of Abuse and Neglect

All staff and associates must be aware of the four main categories of abuse, as defined in Working Together to Safeguard Children (2023):

  • Physical abuse 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 or induces illness.
  • Emotional abuse is the persistent emotional maltreatment of a child. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age-inappropriate or developmentally inappropriate expectations, or the serious bullying or witnessing of abuse of others.
  • Sexual abuse involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence. This includes contact activities and non-contact activities such as creating or viewing sexual imagery involving children. Online child sexual abuse is within scope.
  • Neglect is the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in serious impairment of the child's health or development. This includes failure to provide adequate food, clothing, shelter, supervision, medical care, or emotional support.

Associates should also be alert to indicators of:

  • Child sexual exploitation (CSE) and child criminal exploitation (CCE)
  • Domestic abuse, including where the child witnesses domestic abuse
  • Female genital mutilation (FGM)
  • Forced marriage
  • Honour-based abuse
  • Radicalisation and extremism (Prevent)
  • County lines and gang exploitation
  • Children missing from education
  • Online harms, grooming, and exploitation
  • Mental health concerns that may indicate abuse or neglect

6. Recognising Abuse — Signs and Indicators

6.1 In an online teaching context, associates should be particularly alert to the following potential indicators during sessions:

  • Unexplained or recurrent absences from sessions without explanation
  • A student appearing distressed, withdrawn, or unusually emotional during or at the start of a session
  • Visible injuries on screen — unexplained bruising, burns, or marks
  • Disclosures — direct or indirect — of abuse, neglect, exploitation, or harm
  • Significant changes in behaviour, mood, or engagement over time
  • A student appearing to be in an inappropriate location, in the presence of an adult causing concern, or in apparent distress in their home environment
  • Signs of radicalisation, extremist language, or vulnerability to exploitation
  • Inappropriate contact with the student observed via the platform's chat or messaging features

6.2 Teachers are not expected to be expert investigators. They are not required to determine whether abuse has occurred. Their role is to notice, record, and report. The DSL decides on next steps.

7. Contextual Safeguarding

7.1 Safeguarding concerns do not always arise from within the home. Teachers should be aware that harm to students can occur in peer relationships, online, in communities, and in other contexts. This is particularly relevant in an online delivery model where students may be visible in environments beyond school or home.

7.2 Any concern that appears to relate to the student's external context — including concerning language, apparent fear of others, or references to unsafe situations outside the home — should be reported to the DSL in the same way as any other concern.

8. Reporting a Safeguarding Concern — Procedure for Associates

8.1 Escalation framework. Teachers must use the following three-level framework when responding to concerns during or after a session:

  • Level 1 — concern noted, no immediate risk: log the concern via the Ember Learning safeguarding reporting function within the Platform, within one hour of the session ending. The DSL should be notified at the next available opportunity.
  • Level 2 — urgent concern requiring DSL input: contact the DSL by telephone immediately. If the DSL is unavailable, contact the Deputy DSL immediately. Do not wait until after the session. Log the concern within one hour.
  • Level 3 — student in immediate danger: call 999 first, without waiting for DSL authorisation. Then contact the DSL immediately. DSL contact never takes precedence over emergency services.

8.2 Where to log. Concerns must be logged via the safeguarding reporting function within the Platform, within one hour of the session ending, or immediately where the concern arises between sessions. Teachers receive guidance on accessing the reporting function at onboarding and whenever the Platform interface changes.

8.3 Single-student protocol. If only one student attends a session, making it a 1:1 session, the teacher must notify the DSL by or at the end of the session. The session may proceed unless the DSL advises otherwise. If 1:1 sessions become a recurring pattern for a particular student, the teacher must notify the DSL so that this can be reviewed and appropriate mitigants confirmed. Read alongside Clause 15.6.

8.4 What to do. When logging any safeguarding concern, the report must include:

  • The student's name and year group
  • The date and time of the observation or disclosure
  • A factual, objective account of what was seen, heard, or disclosed — using the student's exact words where a disclosure was made
  • Why the associate is concerned
  • Any contextual information that may be relevant

8.5 What not to do.

  • Investigate or ask leading questions
  • Promise confidentiality to a student
  • Contact the student's family or carers about the concern without DSL authorisation
  • Discuss the concern with anyone other than the DSL or Deputy DSL
  • Delay reporting on the basis that a concern seems minor or uncertain

8.6 Receiving a disclosure. If a student makes a disclosure during a session, the associate should:

  • Remain calm and listen attentively
  • Not stop the student from speaking or tell them to stop
  • Use open, non-leading responses such as ‘I hear you’ or ‘tell me more if you want to’
  • Not promise that what is said will be kept secret
  • Explain calmly that they will need to share what has been said with someone who can help
  • Complete the report to the DSL as soon as the session ends

9. The DSL's Role in Managing Concerns

9.1 On receipt of a concern, the DSL will assess it and determine next steps; decide whether to refer to children's social care, the police, or both; notify the referring Commissioner's designated safeguarding contact within 24 hours, unless doing so could put the student at increased risk; maintain a written record of all concerns, actions, and decisions; and review session recordings where relevant, in accordance with the Session Recording Policy (ET-SRP-002).

9.2 Referral to children's social care. Where the DSL believes a student may be at risk of harm, they will make a referral to the relevant Local Authority's Children's Social Care without delay. The DSL will not wait for certainty before making a referral if the threshold of reasonable suspicion is met.

9.3 Information sharing. The DSL will share information about a student with statutory agencies in accordance with the principle that the welfare of the child overrides data protection considerations, guided by Information sharing: advice for practitioners (HM Government, 2024).

9.4 Safeguarding records. The DSL maintains a confidential record for each concern raised. Records are stored securely with restricted access, retained in accordance with the Company's data retention policy, and are not included in general student files.

10. LADO Referral — Allegations Against Staff or Associates

10.1 Any allegation that a member of staff or a teacher has behaved in a way that has harmed or may have harmed a child; possibly committed a criminal offence against or related to a child; behaved towards a child in a way that indicates they may pose a risk of harm; or behaved in a way that indicates they may not be suitable to work with children — including behaviour outside the workplace — must be referred to the relevant Local Authority Designated Officer (LADO) without delay.

10.2 The DSL is responsible for making LADO referrals. The Company Director must be informed immediately of any allegation.

10.3 Where an allegation is made against the DSL, the referral must be made by the Company Director.

10.4 On receipt of an allegation, the Company will refer to the LADO within one working day; not investigate internally before LADO referral; follow all LADO guidance regarding the individual's continued engagement pending investigation; and suspend or withdraw the individual from student-facing activities where required by the LADO or where necessary to protect children's welfare.

10.5 Whether or not an allegation results in criminal prosecution or disciplinary action, a thorough review will be conducted to determine whether the individual should continue to work with children.

10.6 Commissioning body context. The relevant LADO is determined by the local authority area in which the student resides, not the area of the commissioning body. Ember Learning retains responsibility for making LADO referrals directly and will not delegate this to the commissioning body. Where the Commissioner is a school, the DSL will notify the school's own DSL at the same time as making the LADO referral, unless doing so would place the student at increased risk or delay the referral. Where the Commissioner is a Local Authority, the DSL will notify the LA's designated safeguarding contact in parallel. In all cases the LADO referral will be made within one working day.

11. Prevent — Radicalisation and Extremism

11.1 Ember Learning is committed to protecting students from radicalisation and extremist ideology. All associates must be alert to signs that a student may be at risk of being drawn into extremism.

11.2 Signs may include use of extremist language or glorification of violence; withdrawal from usual social activity; expression of intolerant views about others based on religion, ethnicity, or ideology; apparent contact with extremist groups; and possession or sharing of extremist materials.

11.3 Concerns are reported to the DSL in the same way as any other safeguarding concern. The DSL will consider whether a referral to the Channel programme is appropriate.

12. Safer Recruitment

12.1 No individual may deliver sessions or access student personal data without completing the mandatory process set out in the Safer Recruitment Process (ET-SRP-001).

12.2 This requires, at minimum: an enhanced DBS check with barred list check; two satisfactory references, one involving work with children where applicable; identity verification; employment history review; and mandatory safeguarding training.

12.3 These requirements apply to all teachers without exception, regardless of self-employed status. The Company Director is responsible for ensuring the pre-start checklist is completed and signed off before any associate delivers a session.

13. Training

13.1 DSL and Deputy DSL. Both must complete DSL-level safeguarding training appropriate to their role, refreshed at least every two years, and update their knowledge regularly through reading, briefings, and engagement with current guidance. Both must read Keeping Children Safe in Education in full, annually.

13.2 Teachers. All teachers must complete mandatory safeguarding awareness training before delivering any session, covering recognising abuse and neglect, the Company's reporting procedure, online safety in a teaching context, and Prevent awareness. Training is renewed annually. All teachers must read KCSIE Part One annually and confirm in writing that they have done so before commencing sessions each year.

13.3 Responsible adult recommendation. Ember Learning operates a small group session format as a structural safeguard: no student is ever alone with a teacher. The small group format (2–3 students per session) is explicitly recognised by this Policy as a core organisational safeguard. In addition, Commissioners are responsible for communicating the following recommendation to parents and carers before a student's first session: for students under 12, a responsible adult should be present in the same room or immediately available during sessions, consistent with NSPCC guidance that younger children should not be left unattended during online educational activity; for students aged 12 and over, a parent or carer should be reachable and in the locality during sessions, without a requirement to specify their exact location. Where no adult is present or reachable, the DSL should be notified in advance by the Commissioner. This is a recommendation, not an absolute requirement: Ember Learning does not hold responsibility for verifying or enforcing supervision arrangements in the student's home. Ember Learning is responsible for providing clear written guidance for Commissioners to share with parents and carers.

13.4 The DSL keeps a record of all completed training. Teachers must provide evidence of completion before commencing sessions.

14. Record Keeping and Information Governance

14.1 All safeguarding concerns, referrals, and actions are recorded in writing by the DSL. Records are stored securely and separately from general student records; accessible only to the DSL, Deputy DSL, and Company Director; factual, dated, and signed; and retained in accordance with the Company's data retention schedule.

14.2 Session recordings are retained for safeguarding purposes in accordance with the Session Recording Policy (ET-SRP-002).

14.3 Where a student moves on from Ember Learning, the DSL will consider whether any safeguarding information should be shared with the receiving organisation, in accordance with the principle that the child's welfare takes precedence.

14.4 All data held for safeguarding purposes is processed in accordance with the Data Processing Agreement (ET-DPA-001) and the Company's obligations under UK GDPR and the Data Protection Act 2018.

15. Working with Commissioners

15.1 Ember Learning works with two categories of commissioning body: Local Authorities (typically commissioning under Section 19 of the Education Act 1996) and schools (commissioning alternative provision directly). In both cases, responsibility for safeguarding referred students is shared between Ember Learning and the commissioning body.

15.2 The DSL will establish contact with the Commissioner's designated safeguarding contact at the point of referral and maintain it for the duration of the placement — the LA's designated safeguarding lead or virtual school officer, or the school's own DSL. This contact must be established before the student's first session, with details confirmed in the Order Form.

15.3 The DSL will notify the Commissioner's designated safeguarding contact within 24 hours of any safeguarding concern arising in relation to one of their referred students, unless doing so would place the student at increased risk.

15.3a Attendance. Student non-attendance is treated as a potential safeguarding matter from the first unplanned absence. The Platform generates automatic attendance alerts to the Commissioner's nominated safeguarding contact where a student fails to attend without prior notification. The full notification and escalation procedure, including response timescales and the circumstances in which a statutory referral may be made, is set out in the Service Agreement (ET-SA-001).

15.4 The Company will cooperate fully with any safeguarding investigation involving a referred student.

15.5 Where a Commissioner raises a safeguarding concern, the DSL will respond immediately and in accordance with Section 9.

15.6 1:1 session protocol. The standard session format is small group (2–3 students). A session in which only one student is present constitutes a 1:1 session between a teacher and a child, which is an elevated-risk configuration requiring additional oversight. If a session becomes 1:1 for any reason, the teacher must notify the DSL by or at the end of that session. The session may proceed; DSL sign-off is not required in advance. However, if 1:1 sessions become a recurring pattern for a particular student, the DSL must be informed so that the configuration can be reviewed and appropriate mitigants confirmed and documented. Read alongside Clause 8.3.

15.7 Student onboarding. Commissioners are responsible for ensuring parents and carers receive clear written information about session arrangements before or at the point of a student's first session. This information, provided by Ember Learning for Commissioners to share, must cover the platform used and how students access it; the responsible adult recommendation (Clause 13.3); what to do if a concern arises during a session; and what students are expected to bring and how to prepare. Where practicable, a parent or carer should be available at the student's induction session.

16. Whistleblowing

16.1 Ember Learning supports a culture in which concerns about safeguarding practice — including the conduct of the DSL, Company directors, or any associate — can be raised safely and without fear of retaliation.

16.2 Concerns should be raised first with the DSL, or, where the concern involves the DSL, with the Company Director.

16.3 If the concern relates to the conduct of the Company Director, or if concerns raised internally have not been addressed, the individual may report to:

  • The NSPCC Whistleblowing Advice Line: 0800 028 0285
  • The relevant Local Authority's LADO
  • Ofsted, where the concern involves regulated activity with children

Adopted 1 July 2026 · Version 1.0 · Reviewed annually and following any significant safeguarding incident, change in legislation, or updated statutory guidance. The full policy document is available on request — contact hello@embertutors.co.uk.