1. Policy Statement
Ember Learning Ltd (trading as Ember Tutors) is committed to the online safety of every student who participates in our sessions. Our entire delivery model is online, so online safety is central to every safeguarding decision we make. This Policy sets out how we create and maintain a safe, positive, and professional online environment across all sessions, communications, and related digital activity.
This Policy is informed by Keeping Children Safe in Education (DfE, 2025) Annex C, the Online Safety Act 2023, UK Council for Internet Safety guidance, and Working Together to Safeguard Children (HM Government, 2023). It must be read alongside the Child Protection and Safeguarding Policy (ET-CPSP-001).
2. Scope
This Policy applies to all tutors, Company directors and staff, and students participating in sessions. It covers all activity on the approved session platform — video, audio, chat, whiteboard, and screen-sharing — and any communications between tutors and students outside the platform, which are strictly prohibited.
3. Platform Safeguarding Features
Sessions are delivered via an approved virtual classroom platform with built-in safeguarding controls: automatic session recording (retained for safeguarding purposes only), in-session concern reporting, host controls for managing participants, and unique access links per student. The platform is configured at administrator level to control permissions. Student-to-student messaging is not supported and will not be enabled. A Data Processing Agreement with the platform provider is in place covering data residency, encryption, and breach notification.
4. Tutor Responsibilities
Before sessions: tutors must deliver from a professional setting with a neutral background, ensure their device is secure, and must not share session links or make independent recordings.
During sessions: tutors must keep sessions on topic, actively monitor chat, only share pre-reviewed content, never engage in private messaging with individual students, and remain alert to signs of online harm. They must immediately use host controls to mute or remove any participant whose conduct poses a risk.
After sessions: tutors must log any safeguarding concern via the platform and notify the DSL directly. They must not retain, download, or share any session content, and must not contact any student outside the platform.
5. Company Responsibilities
Ember Tutors ensures all tutors complete online safety training before delivering sessions, the DSL maintains current knowledge of online risks for the student age group, the platform is properly configured, session recordings are accessible only to the DSL and Deputy DSL, and Commissioners receive information to support parental communication.
6. Commissioner Responsibilities
Commissioning bodies (Local Authorities, Multi-Academy Trusts, and schools) are responsible for informing parents that sessions are online and recorded, obtaining consent prior to referral, ensuring students understand conduct expectations, ensuring students have appropriate devices and a safe space, and communicating the responsible adult recommendation to parents and carers.
7. Student Conduct
Students must use their own access credentials, not share session links, not record sessions, treat all participants with respect, not share inappropriate content, and not contact tutors or peers outside the session. Tutors may mute, warn, or remove a student whose conduct is disruptive or poses a risk to others.
8. Specific Online Risks
Ember Tutors recognises risks specific to online tutoring, including grooming and inappropriate contact, online child sexual exploitation, cyberbullying and peer harm, radicalisation via online channels, harmful or illegal content shared during sessions, and student mental health concerns linked to online harm. All associates are trained to recognise these risks and must report any concern to the DSL immediately.
9. Data Protection and Privacy
Student personal data is governed by the Data Processing Agreement. The Commissioner is the Data Controller; Ember Tutors is the Data Processor. Session recordings are retained exclusively for safeguarding and are accessible only to the DSL and Deputy DSL. Tutors must not retain student data on personal devices. Student data is never used for marketing purposes.
10. Responding to an Online Safety Incident
Online safety incidents include inappropriate tutor conduct, a student sharing harmful content, unauthorised recording or distribution of session content, reports of grooming or exploitation, suspected data breaches, and any contact between a tutor and student outside the platform. All incidents are reported to the DSL immediately. Where a potential criminal offence is involved, the DSL contacts the police without delay.
11. Training and Review
All tutors complete online safety training before commencing sessions. The DSL and Deputy DSL maintain current knowledge through annual update training. This Policy is reviewed annually and following any significant online safety incident, update to KCSIE or the Online Safety Act, or material change to the session platform.
The full policy document is available on request. Contact hello@embertutors.co.uk.