1. Policy Statement
Ember Learning Ltd (trading as Ember Tutors) 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. We believe the welfare of every child is paramount, all children have the right to be protected from harm, and every member of our organisation shares responsibility for safeguarding.
This Policy is informed by Keeping Children Safe in Education (DfE, 2025), Working Together to Safeguard Children (HM Government, 2023), and all applicable legislation. Although Ember Tutors 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, employees, self-employed tutors, and any volunteer or observer present during a session. Self-employed status does not reduce any individual's safeguarding obligations. The Policy covers all tutoring sessions delivered via the approved online platform and all related administrative activity.
3. Key Personnel
The Designated Safeguarding Lead (DSL) holds responsibility for safeguarding policy and practice, is the point of contact for all concerns, makes referral decisions, and maintains safeguarding records. The Deputy DSL acts in the DSL's absence and is trained to the same level. The DSL must be contactable during all scheduled session hours.
4. Types of Abuse and Neglect
All staff and associates must be aware of the four main categories of abuse: physical abuse, emotional abuse, sexual abuse, and neglect. Associates must also be alert to child sexual exploitation, child criminal exploitation, domestic abuse, FGM, forced marriage, honour-based abuse, radicalisation, county lines, children missing from education, online harms, and mental health concerns that may indicate abuse.
5. Recognising Abuse in an Online Context
In online tutoring, indicators may include unexplained absences, a student appearing distressed or withdrawn, visible injuries on screen, direct or indirect disclosures, significant changes in behaviour, a student appearing to be in an inappropriate location or in the presence of an adult causing concern, and signs of radicalisation or exploitation. Associates are not expected to investigate — their role is to notice, record, and report.
6. Reporting a Safeguarding Concern
Tutors follow a three-level escalation framework. Level 1 (concern noted, no immediate risk): log via the platform within one hour of the session ending. Level 2 (urgent concern): contact the DSL by telephone immediately. Level 3 (student in immediate danger): call 999 first, then contact the DSL. Reports must be factual, dated, and include the student's exact words where a disclosure was made.
Associates must not investigate, promise confidentiality, contact the student's family without DSL authorisation, or delay reporting because a concern seems minor.
7. The DSL's Role
On receipt of a concern, the DSL assesses it, decides whether to refer to children's social care or the police, notifies the Commissioner's safeguarding contact within 24 hours, and maintains a written record of all actions and decisions. The DSL will not wait for certainty before making a referral if the threshold of reasonable suspicion is met. Information is shared with statutory agencies on the principle that child welfare overrides data protection considerations.
8. Allegations Against Staff (LADO Referral)
Any allegation that a staff member or tutor has harmed or may have harmed a child, committed a criminal offence against a child, or may not be suitable to work with children must be referred to the Local Authority Designated Officer (LADO) within one working day. The Company does not investigate internally before making a LADO referral.
9. Prevent Duty
Ember Tutors is committed to protecting students from radicalisation and extremist ideology. Signs of radicalisation are reported to the DSL, who considers whether a referral to the Channel programme is appropriate.
10. Safer Recruitment
No individual may deliver sessions or access student data without completing the mandatory safer recruitment process: enhanced DBS check with barred list check, two satisfactory references, identity verification, employment history review, and mandatory safeguarding training. These requirements apply to all tutors regardless of self-employed status.
11. Training
The DSL and Deputy DSL complete DSL-level training refreshed every two years and read KCSIE in full annually. All tutors complete mandatory safeguarding awareness training before delivering any session, renewed annually, and read KCSIE Part One each year.
12. Tutor Supervision and Oversight
The DSL conducts a minimum of one session recording spot-check per active tutor per month. Monthly group meetings provide a pastoral check-in and safeguarding supervision forum where tutors can raise concerns. Tutors are informed at induction that spot-checks are a routine part of safeguarding oversight.
13. Whistleblowing
Concerns about safeguarding practice can be raised safely and without fear of retaliation. If internal channels are exhausted, individuals may report to the NSPCC Whistleblowing Advice Line (0800 028 0285), the relevant LADO, or Ofsted.
14. Policy Review
This Policy is 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.