Bright Stars Education – Safeguarding Policy

1. Introduction

a) Bright Stars Education takes its responsibilities to safeguard and protect the interests of the children and young adults who study within its premises very seriously. The nature of its business means that tutors can have regular and sometimes unsupervised contact with children and young adults.
b) Bright Stars Education follows the statutory guidance for UK schools in the safeguarding of children namely: ‘Keeping Children Safe in Education Ltd’ (KCSIE) This ensures that Bright Stars 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, self-employed tutors and volunteers working within Bright Stars Education’s premises or anyone working on behalf of Bright Stars Education. For ease of reference, referred to as ‘tutors’ throughout this policy.
b) It also applies to all students of Bright Stars Education, regardless of their age.
c) This policy is made known to parents on the Bright Stars Education website and is available to parents 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) Students, 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 students
b) To ensure that safeguarding procedures are followed 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 students, including online
e) For all tutors to be aware of the Bright Stars Education Professional Code of Conduct and to ensure they uphold the highest standards of educational practice in their dealings with students and their families.

5. Designated Safeguarding Person (DSP)

5.1 The designated persons for safeguarding within Bright Stars Education are Victoria Carlin or Rachel Atkins. Their contact numbers are 07714 675293 (Victoria) 07747 181958 (Rachel)

5.2 All concerns of a child protection or safeguarding nature, however minor they may seem, should be dealt with by the independent tutor following their own Safeguarding Policy or made directly to either Victoria Carlin or Rachel Atkins following the procedures outlined below. Tutors should not discuss concerns about students 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, students and external agencies
b) To keep detailed, accurate records, including any action taken
c) To ensure that all tutors have been provided with a copy of the Bright Stars Education Safeguarding Policy (i.e. this document) and have read and understood KCSIE Part 1
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 to the police.

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

Any tutor who has any concerns about a student, or if a student discloses information which raises concerns should:
a) Listen carefully and keep an open mind.
b) Reassure the student 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 student is safe, and you will need to ask other adults to help you to do this.
d) Do not cross question the student. You must not ask leading questions, that is, a question which suggests its own answer. Let the student tell you what he or she wants to and no more. The student may be interviewed by a specialist later and too much questioning may prejudice later investigations or cause the student to become anxious and retract his/her information.
e) Be aware that younger students 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 student 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 in person or by telephone to the DSP immediately and then recorded on a Safeguarding Report Form (Appendix 1).
b) The record should be made as soon as possible after speaking to the student 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:

• monitoring the student
• a discussion with parents
• referral to Children’s Services
• report to the police

e) Any tutor making a report will be informed by the DSP of the action taken.
f) If the student’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 student who has known 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 will ensure that action is taken in line with locally agreed procedures.
b) The policy of Bright Stars Education requires that all referrals are made by the DSP; however, an independent tutor may raise concerns directly with Children’s Services.
c) After the contacting the local authority for advice, the DSP will follow the given advice regarding discussing the concerns with the student’s parents/carers and advising them of a referral to Children’s Services. The DSP will not discuss concerns with the student’s parents/carers in circumstances where there is a concern about sexual abuse or where there are concerns that contacting the parents/carers will place the student at increased risk.
d) In cases of extreme emergency or if a serious criminal offence appears to have been committed the police will be contacted immediately
e) The referral process outlined in this policy is also followed when there are concerns about a student 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. Any concerns, 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:

Physical abuse

Emotional abuse (including a child living in a home with domestic violence)

Sexual abuse

• Neglect

More detailed information for tutors is available in KCSIE and all tutors should make themselves aware of KCSIE Part 1.

11. Risk Factors

In an abusive relationship a child may:

• appear frightened or wary of the parent/s or another adult
• 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:

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

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

12 Specific safeguarding issues

12.1 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 student 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 students whose parents are adversely affected by drug or alcohol misuse or mental health issues.

12.2 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 police 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.

12.3 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.

12.4 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 students. Any tutor who is aware of a student 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.

12.5 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.

13. Allegations against a tutor or another adult

a) Any concern about a tutor or another adult’s behaviour, however minor it may appear, must be reported to the DSP. Never think that abuse by 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 one of the DSP, without notifying the other 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 student has made an allegation a written record of what the student has said should be made by the tutor to whom the student 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 student 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 police. It is not the prerogative of the Bright Stars 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 Bright Stars Education ceases to use the services of any person (whether self-employed 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.

14. Professional Code of Conduct for Bright Stars Education Tutors

a) The following Professional Code of Conduct outlines the key principles to which Victoria Carlin and Rachel Atkins adhere. The purpose of the code is to set out the expectations of standards of professional behaviour. Tutors who tutor within Bright Stars Education’s premises will also be made aware with this Code of Conduct as a guide.
b) 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 students, and to reduce the risk of an allegation against a tutor.
c) If at any point during a tuition session a tutor feels uncomfortable about the behaviour of a student or a parent/carer the tutor reserves the right to end the session immediately and contact either of the DSP.
d) It should be noted that forming inappropriate relationships with children or young people who are not students of Bright Stars Education or a tutor working within the same premises, will also be regarded as gross misconduct.

14.1 General guidelines
Tutors should:
a) Treat students 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 students.
c) Work in an open and transparent way, always seeking advice from Bright Stars 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 students.
f) Give regular and appropriate feedback to students and parents on their academic performance. At all times being mindful to maintain a student’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 student or their family members. Avoid taking calls unless an emergency.
j) Not give students gifts without parental knowledge and approval – all gifts/rewards e.g. Christmas gifts must be given with the parent present.
k) Not give students their home address, home telephone number or mobile number unless used in alignment with clause 18.1.
l) Not discuss families or students with others outside Bright Stars Education and must be aware of confidentiality of information. The names, addresses and/or contact numbers of students/parents must not be used or passed on for any other purposes.
m) Not make contact with any student for any reason unrelated to the particular work for which he/she has been engaged.
n) Maintain Bright Stars Education’s reputation for integrity and responsibility and not enter into any social or other non-work related arrangements.

14.2 Students who may be particularly vulnerable
Tutors need to be aware to take particular care when dealing with a student 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

14.3 Physical Contact
Tutors must:
a) Avoid 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. For example, if a student is reluctant to leave the parent, ask the parent how they would like the situation to be dealt with.
c) Do his/her best to comfort or reassure a student if he/she is hurt or distressed, without compromising his/her dignity or doing anything to discredit the person's own behaviour. Ensure that parents are informed at the end of the session.
d) Avoid any conduct that could be taken as a sexual advance.
e) Not do things of a personal nature for students that they can do for themselves (this includes changing clothing, or going to the toilet with them).
f) 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.
g) 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.
h) Not swear or use any sort of offensive language in front of students or parents.
i) Avoid private displays of affection either personally or in writing e.g. messages in birthday cards.

14.4 Other contact
Tutors must not
a) Make arrangements to meet students outside tuition sessions.
b) Give a student a lift in their own vehicle.
c) Invite a student or students to their own home.

14.5 Use of technology, cameras, mobile phones and other devices
a) Tutors must not take video footage or photographs of students unless they have prior written consent from parents. Once they have been used for their agreed purpose e.g. advertising, the tutor must delete them.
b) Any email communication directly between a tutor and student must be ccd into a parent or guardian.
c) Any communication by text or WhatsApp must 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 Bright Stars Education is brought into disrepute.
f) Tutors should not contact students through Facebook, Instagram, Twitter or any other social networking sites and must not accept ‘friend’ requests from students through such sites.
g) Give or show anything to a student which could be construed as pornographic or inappropriate.
h) Engage with students in any other way online in an unacceptable manner.
i) Ensure that any websites to be used have be checked prior to a teaching session for appropriateness.

14.6 Working Alone
Tutors must:
a) Ensure another adult is present when a tuition session is taking place i.e. another tutor. However, if there are no other tutors working at the same time, then the parent must be informed ahead of time and given the option of staying in the room whilst the tuition session takes place.
b) Maintain their timesheet recording the times of all tuition sessions.
c) If working alone, ensure Rachel Atkins or Victoria Carlin are informed.
d) Always inform the parent/guardian if the student becomes upset or distressed.
e) Always report any situation where a student becomes upset or distressed to another tutor.

14.7 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.

15. Safer Recruitment Procedures

a) Bright Stars Education takes its duty of care to students seriously and it is committed to preventing people who pose a risk of harm from working with children.
b) Bright Stars Education also aims to work alongside tutors who share its commitment to safeguarding children and aims to ensure that no potential tutor is treated unfairly by reason of a protected characteristic as defined within the Equality Act 2010. (Candidates with a disability who are invited to an initial discussion should inform Bright Stars Education of any necessary reasonable adjustments or arrangements to assist them in attending.)
c) All Tutors will be required to obtain an enhanced certificate from the Disclosure and Barring Service (“DBS”) before commencing hiring a space within the same premises. Tutors who have been working in a UK school in the three months prior to hiring a space may be eligible to port an existing DBS. Candidates who are registered with the DBS update service must agree to have their DBS checked though the update service.
d) Initial meetings will be conducted in person.
e) All candidates invited to a preliminary meeting must bring the following documents:

• photographic proof of identity e.g. passport or driving licence
• the original certificates of any educational and/or other professional qualifications that are necessary or relevant for tuition
• Where appropriate, any documentation evidencing a change of name
• 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 once the hire of the space is agreed and the original documents returned to the applicant immediately.

16. Hiring a desk within the Bright Stars Education Hub

Providing tuition within the Bright Stars Education Hub will be conditional upon:

• Verification of identity
• A satisfactory enhanced DBS disclosure with Barred List check, the original certificate must be presented to Bright Stars Education Ltd
• A prohibition from teaching check
• Verification of professional qualifications

Referral to the DBS and NCTL
The checks above are carried out prior to tutors working alongside Bright Stars Education; however, Bright Stars 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.