At Primary Tutor Project, we believe every child has the right to feel safe, valued and supported. Safeguarding is at the heart of everything we do. While our primary purpose is to provide high-quality online tuition, we recognise that every adult working with children has a responsibility to protect them from harm and to promote their welfare. As an online tuition provider, we understand that our tutors often develop trusted relationships with children and their families. These relationships place us in a unique position to recognise changes in a child's behaviour, wellbeing or circumstances and to respond appropriately where concerns arise. We are committed to creating an environment where children feel listened to, respected and supported, where tutors understand their safeguarding responsibilities, and where parents and carers are recognised as essential partners in promoting children's welfare. Safeguarding is everyone's responsibility. Every member of the Primary Tutor Project team is expected to remain vigilant, act professionally and report concerns promptly. The welfare of the child will always be our paramount consideration.

The purpose of this policy is to ensure that every child receiving tuition through Primary Tutor Project is protected from abuse, neglect, exploitation and harm. This policy sets out the safeguarding responsibilities of Primary Tutor Project, our tutors, staff, parents, carers and students. It provides clear guidance on recognising safeguarding concerns, responding appropriately and ensuring concerns are managed safely, consistently and in accordance with current legislation and statutory guidance. Primary Tutor Project recognises that safeguarding extends beyond responding to abuse. It includes creating safe learning environments, promoting children's wellbeing, maintaining professional boundaries, supporting positive relationships with families and taking appropriate action whenever concerns arise. This policy applies to: • Primary Tutor Project employees • Self-employed tutors • Contractors • Volunteers • Students receiving tuition • Parents and carers • Anyone working on behalf of Primary Tutor Project By engaging with Primary Tutor Project, all parties agree to support the safeguarding principles and expectations outlined within this policy.

Primary Tutor Project believes that effective safeguarding is built upon trusted relationships, professional curiosity and early intervention. As an online tuition provider, we work closely with families and recognise that parents and carers retain primary responsibility for their children's welfare. Our role is not to replace that responsibility but to work alongside families, schools and safeguarding agencies where appropriate to help keep children safe. We are committed to: • putting children's welfare first in every decision we make; • listening to children and taking their views seriously; • creating a culture where safeguarding concerns are reported without hesitation; • maintaining the highest standards of professional conduct; • promoting safe and respectful online learning; • working collaboratively with parents, carers, schools and safeguarding agencies; • recognising that it is always better to share a concern than to assume someone else will. Safeguarding is not viewed as a standalone responsibility of the Designated Safeguarding Lead. It is an integral part of every tutor's professional role and underpins every interaction with children and families.

This policy has been developed with reference to current safeguarding legislation and statutory guidance, including: • Children Act 1989 • Children Act 2004 • Working Together to Safeguard Children (latest version) • Keeping Children Safe in Education (KCSIE) (latest version) • Prevent Duty Guidance • Online Safety Act • Data Protection Act 2018 • UK General Data Protection Regulation (UK GDPR) • Human Rights Act 1998 • Equality Act 2010 • Children Wellbeing and Schools Act (where applicable) Primary Tutor Project will review this policy whenever legislation or statutory guidance changes.

Safeguarding Safeguarding is the action taken to protect children from abuse, neglect, exploitation and harm while promoting their health, development and wellbeing. Child Protection Child protection forms part of safeguarding and refers to the activity undertaken to protect individual children who are suffering, or are likely to suffer, significant harm. Child A child is any person under the age of eighteen. Designated Safeguarding Lead (DSL) The Designated Safeguarding Lead (DSL) is responsible for leading safeguarding arrangements across Primary Tutor Project, managing safeguarding concerns, supporting tutors and staff, maintaining safeguarding records and liaising with external agencies where appropriate. Abuse Abuse may occur in many forms, including but not limited to: • physical abuse; • emotional abuse; • sexual abuse; • neglect; • domestic abuse; • child criminal exploitation; • child sexual exploitation; • bullying; • cyberbullying; • online abuse; • grooming; • radicalisation; • harmful sexual behaviour; • peer-on-peer abuse; • forced marriage; • female genital mutilation (FGM); • county lines exploitation. Primary Tutor Project recognises that safeguarding concerns rarely present in isolation. Tutors are expected to remain professionally curious and report any concern, however small it may appear.

Designated Safeguarding Lead (DSL) Designated Safeguarding Lead: Callie Moir Director, Primary Tutor Project Email: callie@primarytutorproject.com The Designated Safeguarding Lead (DSL) has overall responsibility for safeguarding and child protection across Primary Tutor Project. The DSL will: • Promote a culture where safeguarding is everyone's responsibility and the welfare of children is paramount. • Act as the first point of contact for all safeguarding concerns raised by tutors, staff, parents or external agencies. • Receive, assess and manage safeguarding concerns promptly and proportionately. • Maintain confidential, accurate and secure safeguarding records. • Assess risk and determine the most appropriate course of action for each safeguarding concern. • Make referrals to Children's Social Care, the Police, the Local Authority Designated Officer (LADO), the Disclosure and Barring Service (DBS), the Prevent/Channel programme or other statutory agencies where appropriate. • Liaise with schools, local authorities and other professionals where this supports the safety and wellbeing of a child. • Support tutors and staff throughout safeguarding processes. • Ensure safeguarding concerns are followed through until an appropriate outcome has been reached. • Keep safeguarding policies and procedures under regular review. • Monitor safeguarding trends across the organisation and implement improvements where necessary. • Ensure safer recruitment procedures are followed. • Ensure safeguarding training remains current across the organisation. • Undertake regular continuing professional development to maintain up-to-date safeguarding knowledge. The DSL retains overall responsibility for safeguarding decisions within Primary Tutor Project and will ensure that all actions are guided by the best interests of the child. Availability The DSL is available during normal business hours to provide safeguarding advice and support. Where an immediate safeguarding concern arises outside these hours and a child is believed to be at immediate risk of harm, tutors should contact the appropriate emergency service or Children's Social Care without delay before notifying the DSL as soon as reasonably practicable. Tutors Every tutor working through Primary Tutor Project has a responsibility to safeguard the children they teach. Tutors are expected to: • Place the welfare of the child above all other considerations. • Complete mandatory safeguarding and Prevent training before teaching through Primary Tutor Project and keep this training up to date. • Read, understand and comply with all safeguarding policies and procedures. • Maintain appropriate professional boundaries at all times. • Remain vigilant to signs of abuse, neglect, exploitation, radicalisation, self-harm, mental health concerns and online harm. • Listen carefully to children and take any concern or disclosure seriously. • Report safeguarding concerns to the DSL immediately. • Record concerns factually, accurately and promptly. • Cooperate fully with safeguarding investigations where required. • Promote safe online learning throughout every lesson. • Maintain confidentiality while recognising that safeguarding information cannot always be kept confidential. Tutors must never investigate safeguarding concerns themselves or promise a child that information will be kept secret. Parents and Carers Primary Tutor Project recognises that parents and carers retain parental responsibility for their children and play a central role in safeguarding their welfare. We believe safeguarding is most effective when tutors, parents and Primary Tutor Project work together in partnership to support children. Parents and carers are expected to: • Provide a safe and appropriate environment for online tuition. • Inform Primary Tutor Project of any medical, behavioural, educational or safeguarding information that may affect their child's safety or wellbeing. • Inform the organisation of any safeguarding concerns relating to their child. • Work collaboratively with tutors and the DSL where concerns arise. • Be available during lessons for younger children where appropriate. • Support their child to participate safely and respectfully during online sessions. • Respect professional boundaries with tutors. Parents are encouraged to share information openly with tutors where this will help them better understand and support their child. Working in Partnership with Parents Primary Tutor Project values the trusting relationships that develop between tutors, children and their families. Unlike schools, our tutors often work closely alongside parents, who remain responsible for making decisions about their child's welfare and education. We therefore believe that open communication between tutors and parents is an important part of safeguarding and promoting children's wellbeing. Tutors are encouraged to communicate professionally with parents regarding matters such as: • a child's engagement during lessons; • changes in behaviour or emotional wellbeing; • concerns affecting learning; • online safety; • attendance and participation; • pastoral concerns; • strategies that may better support the child. In most circumstances, sharing concerns with parents supports positive outcomes for children and enables families to access appropriate support at an early stage. However, tutors should not discuss safeguarding concerns directly with parents where: • the concern relates to possible abuse or neglect by a parent or family member; • doing so may place the child or another person at increased risk; • the child has made a disclosure that requires safeguarding assessment; • the tutor is unsure whether information should be shared. In these circumstances, tutors must report the concern to the DSL immediately and seek advice before speaking with parents. The DSL will determine what information should be shared, with whom and at what stage, taking into account: • the child's safety and welfare; • parental responsibility; • statutory safeguarding guidance; • advice from Children's Social Care, the Police or other safeguarding agencies where appropriate. The welfare and safety of the child will always be the overriding consideration when deciding how information should be shared. Students Although safeguarding responsibilities primarily rest with adults, Primary Tutor Project encourages children and young people to play an active role in creating a safe learning environment. Students are encouraged to: • Treat tutors and other students with kindness and respect. • Behave appropriately during online lessons. • Tell a trusted adult if something makes them feel worried, uncomfortable or unsafe. • Use online learning platforms responsibly. • Report inappropriate behaviour or online activity. • Respect the privacy and wellbeing of others. Every child has the right to be listened to and taken seriously. Primary Tutor Project is committed to creating an environment where children feel safe to speak up and know their concerns will be acted upon appropriately.

Primary Tutor Project is committed to safer recruitment practices and recognises that robust recruitment procedures play an essential role in safeguarding children. No tutor will be permitted to deliver tuition through Primary Tutor Project until all required recruitment and safeguarding checks have been satisfactorily completed. As part of our recruitment process, we will: • Verify the tutor's identity. • Verify relevant teaching qualifications and professional experience. • Obtain satisfactory professional references. • Review employment history where appropriate. • Verify the tutor's right to work in the UK where applicable. • Obtain evidence of an Enhanced DBS Certificate or DBS Update Service status. • Where a tutor is not subscribed to the DBS Update Service, require an Enhanced DBS Certificate dated within the previous twelve months. • Require tutors to complete safeguarding training prior to delivering tuition. • Require tutors to read and agree to Primary Tutor Project's Safeguarding Policy, Tutor Code of Conduct and Professional Standards. • Ensure tutors understand their safeguarding responsibilities before working with children. Primary Tutor Project reserves the right to refuse or withdraw registration where safeguarding concerns arise or where recruitment checks are unsatisfactory.

Primary Tutor Project believes that effective safeguarding depends upon well-trained, confident and informed tutors. All tutors are therefore required to complete recognised safeguarding training before delivering tuition through Primary Tutor Project. Tutors are expected to: • Complete safeguarding training before teaching. • Refresh safeguarding training at least every two years. • Complete Prevent Duty awareness training. • Read and understand this Safeguarding Policy before teaching. • Keep up to date with safeguarding developments through regular professional learning. • Participate in any safeguarding updates provided by Primary Tutor Project. The Designated Safeguarding Lead will: • Maintain enhanced DSL safeguarding training. • Refresh DSL training at least every two years. • Undertake regular continuing professional development. • Keep up to date with changes to safeguarding legislation and statutory guidance. • Share relevant safeguarding updates with tutors where appropriate. Safeguarding training is regarded as an ongoing professional responsibility rather than a one-off requirement.

At Primary Tutor Project, safeguarding underpins every aspect of our work. We believe that: • The welfare of the child is paramount. • Every child has the right to learn in a safe, supportive and respectful environment. • Every child should be listened to and taken seriously. • Safeguarding is everyone's responsibility. • Early identification of concerns can prevent children from coming to harm. • Building trusted relationships with children and families supports effective safeguarding. • Parents and carers are important partners in promoting children's welfare. • Professional curiosity and vigilance are essential. • It is always better to report a concern than to assume someone else will. • Safeguarding decisions should always be guided by the best interests of the child. We recognise that safeguarding extends beyond identifying abuse and includes promoting children's emotional wellbeing, mental health, online safety and overall welfare.

All tutors are expected to maintain the highest standards of professional conduct and recognise the position of trust they hold when working with children. Tutors must: • Behave professionally at all times. • Maintain appropriate professional boundaries. • Treat all children with dignity and respect. • Promote children's wellbeing throughout every lesson. • Follow Primary Tutor Project's safeguarding procedures. • Report safeguarding concerns promptly. • Maintain accurate records where safeguarding concerns arise. • Dress appropriately for online lessons. • Teach from a professional environment that is free from inappropriate distractions wherever reasonably possible. • Use only approved communication channels provided or authorised by Primary Tutor Project. • Communicate with parents in a professional, respectful and transparent manner. Tutors must not: • Share personal telephone numbers or private email addresses with students. • Exchange personal social media accounts with students. • Communicate with students through personal messaging services or social media. • Develop inappropriate personal relationships with students. • Meet students outside authorised tuition arrangements. • Accept gifts or payments directly from students or families without prior agreement from Primary Tutor Project. • Ask children to keep secrets. • Use language or behaviour that could reasonably be considered intimidating, discriminatory, humiliating, sexually suggestive or inappropriate. • Ignore safeguarding concerns or assume someone else will report them. • Investigate safeguarding concerns themselves. • Continue a lesson where there is an immediate safeguarding risk to a child or another individual. Tutors are expected to exercise professional judgement at all times and seek advice from the DSL whenever they are unsure how to respond to a safeguarding concern.

Primary Tutor Project recognises that online tuition presents unique safeguarding opportunities and responsibilities. We are committed to providing a safe online learning environment through robust safeguarding procedures and clear expectations for tutors, students and parents. To promote children's safety, Primary Tutor Project will: • Deliver tuition using secure online learning platforms. • Record all live online lessons. • Store lesson recordings securely. • Restrict access to recordings to the DSL and other individuals authorised by the DSL for safeguarding, legal, regulatory or complaint investigation purposes. • Automatically delete lesson recordings after 30 days unless they are required for safeguarding, legal or complaint investigations. • Require tutors to maintain professional conduct throughout online sessions. • Encourage younger children to learn in a shared family space wherever possible. • Encourage parents and carers to remain nearby during lessons for younger children. • Promote safe and responsible use of online technology. Tutors should ensure that: • Cameras remain switched on throughout lessons unless otherwise agreed. • Their teaching environment is professional and appropriate. • Backgrounds are suitable for working with children. • Their own privacy and the privacy of students are protected. • Any inappropriate online behaviour is addressed promptly. Tutors should remain alert to signs of: • cyberbullying; • online grooming; • inappropriate online communication; • radicalisation; • exploitation; • self-harm; • exposure to harmful online content; • inappropriate use of screen sharing, chat or messaging functions. Any online safeguarding concern should be reported to the DSL immediately.

Safeguarding concerns may arise in many different ways and are not always immediately obvious. As tutors often work with children on a one-to-one basis over an extended period, they may be well placed to notice changes in a child's behaviour, presentation, emotional wellbeing or engagement. Tutors should remain professionally curious and alert to any indication that a child may be at risk of harm. Safeguarding concerns may include, but are not limited to: • Physical abuse • Emotional abuse • Sexual abuse • Neglect • Domestic abuse • Child criminal exploitation (CCE) • Child sexual exploitation (CSE) • Grooming • Peer-on-peer abuse • Harmful sexual behaviour • Bullying or cyberbullying • Online abuse • Radicalisation • Self-harm • Suicidal ideation • Eating disorders • Mental health concerns • Forced marriage • Female Genital Mutilation (FGM) • Honour-based abuse • County lines exploitation A safeguarding concern may arise through: • a direct disclosure by a child; • changes in behaviour or presentation; • repeated comments made over time; • observations during lessons; • information shared by parents or schools; • online interactions; • lesson recordings; • concerns raised by another tutor or professional. Tutors should remember that no single sign is likely to confirm abuse. However, several small concerns may indicate that a child requires support or protection. If in doubt, tutors should always report the concern to the Designated Safeguarding Lead.

Children may choose to disclose information about abuse, neglect or harm to a trusted tutor. If a child makes a disclosure, tutors should: • remain calm and listen carefully; • allow the child to speak freely; • reassure the child that they have done the right thing by telling someone; • explain that the information cannot be kept secret because adults sometimes need to share information to help keep children safe; • avoid expressing shock, disbelief or judgement; • avoid asking leading or investigative questions; • only ask open questions where clarification is absolutely necessary; • make a clear, factual record of what has been said as soon as possible; • report the concern immediately to the DSL. Tutors must never: • promise confidentiality; • investigate the concern themselves; • contact alleged perpetrators; • confront parents or carers without advice from the DSL where safeguarding concerns exist; • delay reporting because they are uncertain whether abuse has occurred. The tutor's role is to listen, reassure, record and report.

All safeguarding concerns, regardless of how minor they may initially appear, must be reported to the Designated Safeguarding Lead as soon as possible. Primary Tutor Project operates on the principle that it is always better to report a concern than not to report one. Safeguarding concerns should be reported immediately where: • a child makes a disclosure; • a tutor observes signs of abuse or neglect; • there are concerns about a child's safety or welfare; • concerning behaviour is observed during lessons; • there are concerns regarding online safety; • concerns arise about a parent, family member, tutor or another professional. Reports should include, where possible: • the date and time; • the child's name; • the names of anyone else involved; • a clear factual account of the concern; • the exact words used by the child where appropriate; • observations made by the tutor; • any immediate actions taken. Tutors should distinguish clearly between: • factual observations; • information shared by others; • their own professional opinion. Records should be completed as soon as reasonably practicable while details remain fresh. Refer to Appendix 1 at the end of this document to see a flowchart of this process. Action by the Designated Safeguarding Lead On receiving a safeguarding concern, the DSL will: • assess the level of risk; • consider the child's immediate safety and welfare; • review any previous safeguarding concerns or relevant information; • determine whether immediate action is required; • record all decisions and the rationale for those decisions; • seek advice from Children's Social Care or other safeguarding agencies where appropriate; • determine whether information should be shared with parents, schools or other professionals; • make referrals to Children's Social Care, the Police, the Local Authority Designated Officer (LADO), the Disclosure and Barring Service (DBS), the Prevent/Channel programme or other agencies where appropriate; • continue to monitor concerns until an appropriate outcome has been reached. Where appropriate, Primary Tutor Project will work collaboratively with parents, carers, schools and safeguarding professionals to ensure children receive appropriate support. However, where informing parents may place a child at increased risk of harm or compromise a safeguarding investigation, information will only be shared following advice from the appropriate safeguarding agency. The safety and welfare of the child will always take precedence over all other considerations. Refer to Appendix 2 at the end of this document to see a flowchart of this process. Immediate Risk of Harm If a tutor believes that a child or another person is in immediate danger and the DSL cannot be contacted without causing delay, the tutor should contact emergency services by calling 999 or contact the relevant Children's Social Care team directly. The tutor must notify the DSL as soon as possible after emergency action has been taken.

Primary Tutor Project encourages an open and transparent culture in which concerns about professional conduct can be raised without fear of criticism. A low-level concern is any concern about the behaviour of a tutor, staff member or contractor that does not meet the threshold for a safeguarding allegation but may be inconsistent with the organisation's Code of Conduct or expected professional standards. Examples may include: • inappropriate professional boundaries; • concerning communication with students or parents; • inappropriate use of technology; • behaviour that causes discomfort or concern; • repeated minor incidents that may indicate an emerging pattern; • failure to follow safeguarding procedures. All low-level concerns should be reported to the DSL. The DSL will: • record the concern; • assess any safeguarding implications; • identify patterns of behaviour where relevant; • determine whether further action or support is required. Primary Tutor Project believes that early reporting of low-level concerns helps prevent more serious safeguarding issues from developing.

Primary Tutor Project is committed to ensuring that all allegations or concerns relating to the conduct of tutors, staff or contractors are managed fairly, consistently and in accordance with safeguarding guidance. Any allegation that a tutor, staff member or contractor has: • behaved in a way that has harmed, or may have harmed, a child; • committed or may have committed a criminal offence against a child; • behaved towards a child in a way that indicates they may pose a risk of harm; or • behaved in a way that may make them unsuitable to work with children, must be reported to the Designated Safeguarding Lead immediately. The DSL will: • ensure the immediate safety of the child where necessary; • assess the information received; • seek advice from the Local Authority Designated Officer (LADO) where appropriate; • liaise with the Police or Children's Social Care where required; • maintain accurate and confidential records; • determine whether temporary suspension from tutoring is necessary while enquiries are undertaken. Where required by law, Primary Tutor Project will make referrals to the Disclosure and Barring Service (DBS) and any other relevant regulatory bodies. All allegations will be managed fairly, objectively and confidentially, with due regard to the welfare of children and the rights of all individuals involved.

Primary Tutor Project recognises its responsibility to help safeguard children from radicalisation, extremism and terrorism. Tutors are expected to remain alert to indicators that a child may be vulnerable to radicalisation or extremist influences and to report any concerns promptly to the DSL. Primary Tutor Project is equally committed to protecting children from online harms, recognising that many safeguarding concerns now arise through digital technology. Tutors should remain vigilant to: • online grooming; • cyberbullying; • extremist content; • inappropriate online relationships; • exposure to harmful or illegal content; • online exploitation; • coercive or controlling online behaviour. All Prevent or online safety concerns must be reported to the DSL without delay. Where appropriate, referrals will be made to the Prevent/Channel programme or other relevant agencies.

Accurate record keeping is an essential part of effective safeguarding. All safeguarding records maintained by Primary Tutor Project will: • be factual, objective and accurate; • distinguish between observation, professional opinion and fact; • include dates, times and those present; • record actions taken; • record decisions made and the rationale for those decisions; • include details of referrals made or decisions not to refer; • be stored securely; • be accessible only to the DSL and those authorised by the DSL where necessary; • be retained in accordance with Primary Tutor Project's data retention procedures and legal obligations. Safeguarding information will always be handled sensitively and in accordance with the Data Protection Act 2018 and UK GDPR.

Effective safeguarding depends upon timely and appropriate information sharing. Primary Tutor Project is committed to working collaboratively with parents, schools and safeguarding agencies wherever this promotes the welfare of a child. Sharing information with parents As parents and carers retain parental responsibility, Primary Tutor Project believes they should normally be kept informed of concerns relating to their child's wellbeing, engagement or welfare. Tutors are encouraged to communicate professionally with parents regarding matters that support the child's learning, development and wellbeing. However, where there is reason to believe that informing a parent may: • place a child at increased risk of harm; • compromise a safeguarding investigation; • prejudice advice from Children's Social Care or the Police; or • place another person at risk, tutors must not share safeguarding information directly with parents. Instead, the concern should be referred immediately to the DSL, who will determine what information should be shared and when. Sharing information with schools Where appropriate and in the best interests of the child, Primary Tutor Project may share safeguarding information with a child's school. This may include: • safeguarding concerns; • concerns affecting attendance or engagement; • information supporting the child's welfare; • information requested by safeguarding professionals. Where appropriate, Primary Tutor Project may also seek relevant safeguarding information from schools in order to better support a child. Sharing information with external agencies Where necessary to protect a child, Primary Tutor Project will share relevant information with: • Children's Social Care; • Police; • Local Authority Designated Officers (LADO); • Prevent/Channel; • health professionals; • schools; • other safeguarding partners. Information will only be shared on a need-to-know basis and in accordance with safeguarding legislation and statutory guidance. The safety and welfare of the child will always take precedence over confidentiality where there is a safeguarding concern.

Primary Tutor Project is committed to maintaining a culture of openness, honesty and accountability. Tutors and staff are encouraged to raise concerns where they believe: • safeguarding procedures are not being followed; • a child may be at risk; • another adult's behaviour gives cause for concern; • professional standards are not being maintained. Concerns should normally be raised with the DSL. No individual who raises a genuine safeguarding concern in good faith will suffer disadvantage or retaliation.

Safeguarding is an ongoing responsibility. The DSL will monitor safeguarding practice across Primary Tutor Project to ensure policies remain effective and reflect current legislation, statutory guidance and best practice. This policy will be reviewed: • annually; • whenever safeguarding legislation or statutory guidance changes; • following significant safeguarding incidents where learning is identified; • following significant operational changes within Primary Tutor Project. Last Reviewed: July 2026 Next Review Due: July 2027