Safeguarding and Child Protection Policy

PMT Education is committed to ensuring the personal safety and wellbeing of each student. We recognise our responsibility to safeguard the welfare of all children and young people, by committing to a practice which protects them. In line with our duty of care, we will do everything we can to ensure that we provide a safe and caring environment for the children and young people who use our services.

This Safeguarding and Child Protection Policy was developed in collaboration with the NSPCC. We are committed to reviewing our policy and good practice annually. This policy was last reviewed on: 12th September 2023

Safeguarding Principles and Policy Objectives

We recognise that:

• The welfare of the child/young person is paramount.
• All children, regardless of age, ability, gender identity, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse.
• Some children are particularly vulnerable because of the impact of previous experiences, their level of dependency, communication needs and/or other issues.
• Working in partnership with tutors, children, young people and their parents/carers is essential in promoting young people’s welfare.

The purpose of the policy:

• To provide protection for the children and young people who use our services.
• To provide tutors and staff with guidance on procedures they should adopt in the event that they suspect a child or young person may be experiencing, or be at risk of, harm.
• This policy applies to all individuals working on behalf of PMT Education, whether they be directors, tutors or administrative staff.

We will seek to safeguard children and young people by:

• Valuing them, listening to them and respecting them.
• Adopting child protection guidelines through the provision of up-to-date policies and procedures that reflect current safeguarding legislation and guidance.
• Providing safeguarding training for relevant staff.
• Adopting safe recruitment practices, including:
  • Identity checks: We require all applicants to submit evidence of their identity, in the form of either their passport or driving licence.
  • Conducting interviews with all applicants.
  • Issuing DBS badges on our platform exclusively to tutors who possess a valid enhanced DBS check issued within the past 3 years.
  • Recording all online tutoring sessions so that they can be revisited for safeguarding purposes, if necessary.
  • Developing and maintaining a culture of vigilance in relation to child safety.
  • Sharing information about safeguarding and good practice with children, parents, staff, and tutors.
  • Sharing Codes of Conduct for Students and Tutors to promote safe classroom environments.
  • Ensuring people feel able to raise safeguarding concerns and are confident that their concerns will be taken seriously.
  • Sharing information with agencies who need to know, and involving parents/carers and children appropriately.

PMT Education has a duty to ensure that all our tutors work with children and young people in a safe, professional and competent manner. Alongside our responsibilities to protect the children and young people using our services is the responsibility of the tutors who work to conduct themselves in a professional and considerate manner.

Tutors must familiarise themselves with the procedures they are legally obligated/obliged to follow, should they learn, or suspect, that a child is being abused or mistreated in any way. They should comply with the guidelines below.

Guidelines for Tutors

Tutors must give special consideration to ensuring that they do not put themselves in a position where an allegation can be made against them. Such consideration might involve, but is in no means limited to:

• Treating children with respect and dignity at all times, reflecting their age, background, culture and special needs;
• Retaining a professional approach to working with children, which will involve behaviour such as ensuring that there is no physical contact between themselves and their students, not divulging personal contact details or personal information, avoiding inappropriate familiarity, including discussing matters of a sexual nature, maintaining self-control and being sensitive to issues that can be misconstrued; and
• Seeking guidance on their own interactions with children if they have any concerns about their appropriateness or the possibility of them being misconstrued to either Gorkem Cavli or Michelle Wright, the PMT Education Safeguarding Officers.

Under no circumstances should a tutor ever:

• Fail to act upon and record any allegations made by a child;
• Make sexually suggestive comments to a child;
• Contact a student directly or engage in any social media interaction with them;
• Record audio or video or take any screenshots of an online tutoring session.

Tutors should be aware that online tutoring sessions are recorded and are available for review by students and parents. PMT Education may also review recordings in response to safeguarding concerns and/or randomly to ensure that the expected lesson quality is met.

These guidelines will always apply in the context of coming into contact with children, including students under the age of 18 years. It will also apply in situations involving vulnerable adults and is also likely to constitute best practice in situations involving all students over the age of 18.

Any tutor who comes into contact with children under the age of 18 is considered to be in a position of trust, whether or not they meet the strict legal definition. Any sexual activity between a tutor or student whom the tutor has come into contact through activities carried out in the course of tutoring will be treated as a very serious disciplinary matter. Anyone who meets the legal definition of “position of trust” under the Sexual Offences Act 2003 and who engages in any sexual activity with a person under 18 is also committing a criminal offence, and such cases will be reported to the Police.

PMT Education has a legal duty to report to the DBS any individual whom it believes ought to be placed on the list of individuals barred from working with children.

Dealing with a Safeguarding Concern

Tutors should be aware of the various types of safeguarding concerns. These may include:

• Alcohol and substance misuse
• Bullying or harassment
• Concealed pregnancy
• County Lines
• Criminal exploitation
• Culture within the organisation allowing poor behaviour
• Discrimination on any of the grounds in the Equality Act 2010
• Eating disorders
• Emotional abuse
• Female genital mutilation (FGM)
• Financial or material abuse
• Forced marriage and honour-based violence
• Negligent treatment
• Physical abuse
• Psychological abuse
• Radicalisation and extremism
• Trafficking or modern slavery
• Sexual harassment, abuse and exploitation
• Self-neglect or self-harm
• Suicide ideation or attempted suicide

Tutors may have suspicions that a person is either at risk of harm or suffering abuse or neglect because of behavioural, emotional and/or physical factors. A student may also disclose information that causes a concern for their or someone else’s safety and welfare.

This disclosure may come in the form of the student telling a tutor:

• They have been or are being abused
• They have concerns about someone else
• They are themselves abusing or likely to abuse someone else

This disclosure may be direct – i.e. making specific verbal statements about what has happened to them – or indirect – i.e. making ambiguous verbal statements which suggest something is wrong. They may also disclose information non-verbally, e.g. by writing letters, drawing pictures or trying to communicate in other ways (Source: NSPCC).

When information becomes available to a tutor that gives rise to concern for somebody’s welfare, the tutor should consider that information in context. For example, is the change in behaviour a result of illness, bereavement or exam stress? If a tutor cannot conclusively attribute it to one of these factors, they should err on the side of caution and follow the below procedure.

Protocol for Tutors Regarding Suspected Student Abuse

• Listen carefully to the child – Avoid expressing your own views on the matter. A reaction of shock or disbelief could cause the child to ‘shut down’, retract or stop talking.
• Let them know they’ve done the right thing – Reassurance can make a big impact on the child who may have been keeping the abuse secret.
• Tell them it’s not their fault – Abuse is never the child’s fault and they need to know this.
• Say you will take them seriously – A child could keep abuse secret in fear they won’t be believed. They’ve told you because they want help and trust you’ll be the person who will listen to and support them.
• Don’t talk to the alleged abuser – Confronting the alleged abuser about what the child has told you could make the situation a lot worse for the child.
• Don’t promise confidentiality – You have a legal obligation to report any safeguarding concerns. Be honest about your own position.
• Explain what you’ll do next –  If age appropriate, explain to the child you’ll need to report the abuse to someone who will be able to help.
• Record information – Use the child’s own words if possible, and ask the child whether what has been recorded accords with what they have said.
• Don’t delay reporting the abuse – The sooner the abuse is reported after the child discloses the better. Report as soon as possible so details are fresh in your mind and action can be taken quickly.

If a tutor believes the child to be in immediate danger, they should call the Designated Safeguarding Lead, Michelle Wright, on 0208 106 6898. If they do not believe the child to be in immediate danger, they should complete the Safeguarding Concern Form. They should do this as soon as is reasonably possible.

The Designated Safeguarding Lead will then discuss the allegation with the Deputy Safeguarding Officer and obtain further details of the allegation and the circumstances in which it was made. Should it be judged necessary, the Local Authority Designated Officer (LADO) may be contacted and/or other relevant authorities involved.

The Designated Safeguarding Lead shall report the outcome of the investigation to the person who reported the original concern.

Guidelines for Parents and the PMT Team

PMT Education recognises its duty to report concerns or allegations against tutors. There are several instances in which there is a legal duty to report a tutor. These are:

• A tutor has behaved in a way that has harmed, or may have harmed a child
• A tutor has possibly committed a criminal offence against, or related to, a child
• A tutor has behaved towards a child or children in a way that indicates they may pose a risk of harm to children
• A tutor has behaved in a way that indicates they may not be suitable to work with children.

Protocol for Addressing Suspicions of Tutor Misconduct Towards a Child

If a parent or member of the PMT Team suspects any of the above, they should:

• Report it as soon as reasonably possible to the Designated Safeguarding Lead by completing the Incident Report Form.
• The Designated Safeguarding Lead will then discuss the allegation with the Deputy Safeguarding Officer and obtain further details of the allegation and the circumstances in which it was made. Should it be judged necessary, the Local Authority Designated Officer (LADO) may be contacted and/or other relevant authorities involved.
• Safeguarding Officers will store any information relating to an allegation in a secure area and ensure that only authorised staff have access to this. They are also responsible for forwarding referrals to the Disclosure and Barring Service.
• For the period that an investigation is underway, the profile of the tutor concerned will be suspended. PMT Education will continue to support that individual. Should the concern be referred to outside authorities, an individual unconnected to the investigation will be nominated in order to keep the tutor updated with the progress of the investigation. The tutor will also be signposted to other support networks, such as the trade union Voice, their GP, or Samaritans.
• The Designated Safeguarding Lead shall report the outcome of the investigation to the person who reported the original concern.

Key Contacts and Resources

PMT Education’s Safeguarding Team

Michelle Wright
Designated Safeguarding Lead

Görkem Çavlı
Deputy Safeguarding Officer

Other Useful Helplines

• NSPCC – 0808 800 5000
• Stop It Now! UK and Ireland – 0808 1000 900
• Samaritans – 08457 90 90 90
• Childline – 0800 1111

Guidance and Legislation Underpinning this Policy

• Children Act 1989
• United Convention of the Rights of the Child 1991
• Data Protection Act 2018
• Human Rights Act 1998
• Sexual Offences Act 2003
• Children Act 2004
• Safeguarding Vulnerable Groups Act 2006
• Protection of Freedoms Act 2012
• Children and Families Act 2014
• Special Educational Needs and Disability (SEND) Code of Practice: 0 to 25 years
• Statutory guidance for organisations which work with and support children and young people who have special educational needs or disabilities; HM Government 2014
• Developed in collaboration with the National Society for the Prevention of Cruelty to Children (NSPCC)