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Safeguarding Policy

Safeguarding Policy for Children and Young People

VersionUpdate Staff
2.003.10.2022Daniela Prataviera
3.008.12.2022Mohil Shah
3.517.08.2023Daniela Prataviera
4.029.09.2023Daniela Prataviera
5.016.04.2024Daniela Prataviera
6.019.09.2024Daniela Prataviera
7.031.10.2025

1. Introduction- Who it is by and who it is for 2

2. Legislative Framework 4

3. Definitions 5

4. Responsibilities 8

Low-Level Concerns 10

Absenteeism 11

5. Online Safety and Communication 12

6. Safeguarding procedures reporting and managing concerns about a child or young person 13

7. Safeguarding Issues 16

Child on Child Abuse 16

Procedures against Child on Child Abuse 18

Child Criminal Exploitation (CCE) 18

Child Sexual Exploitation (CSE) 20

Domestic Abuse 21

Female Genital Mutilation (FGM) 22

Mental Health 23

Serious Violence 24

7. Allegations Against Study Mind Tutors and Staff 24

8. Compliance, DBS Requirement and Duty to Report 25

9. Safeguarding Governance and Learning Lessons 26

10. Prevent, extremism and anti-radicalisation 27

11. Anti-Bribery 27

12. Whistleblowing 28

13. Children with Special Educational Needs and Disabilities 29

14. Safeguarding Vulnerable Groups 29

15. Face to Face Tuition 30

13. Review 32

Appendix A: Safeguarding Reporting Form 32

Appendix B: Key Contacts 35

1. Introduction- Who it is by and who it is for

This Safeguarding Policy is written in accordance with current legislative rules and maintained by members of the management team. This Policy applies to all students interacting with all services under the brand names ‘Study Mind’, ‘Medic Mind’, Oxbridge Mind’, ‘Dentist Mind’, ‘Law Mind’ ‘Vet Mind’ and any other part of this company. This applies to both direct students, referrals and groups coming from third party organisations. For ease of reference, this policy will refer to the business under the name ‘Study Mind’.

Statement of Intent

Study Mind is committed to protecting all students within the organisation, with a thorough and robust policy that is mandatory and integral to how Study Mind conducts business and trains all staff.

Study Mind acknowledges our legal duty to safeguard and promote the welfare of all children. Safeguarding is a collective responsibility, and everyone connected (including staff, tutors, directors, parents, families, and learners) plays a vital role in ensuring their safety and security.

Every student who participates in a Study Mind course should be able to do so in a safe and comfortable environment.  Study Mind is committed to providing the best possible level of safeguarding and the wellbeing and safety of each student is our primary consideration.  Study Mind is committed to the wellbeing and safety of all our learners. It underpins all areas of our provisions as we believe children have a right to feel safe.  Close monitoring and early identification of safeguarding issues is critical. 

Staff and tutors at Study Mind are encouraged to always consider the possibility of safeguarding issues, adopting a mindset of ‘it could happen here’. When there are concerns about a child or young person’s welfare, the priority is always to act in their best interests.

Study Mind is committed to the principle that the best interests of children and vulnerable adults are paramount. We believe that all children (defined as all children up to the age of 18 years whether living with their families, in state care or living independently) deserve to have their voices heard and their feelings and wishes considered. children of all ages, disabilities, genders, races, religions, beliefs, sexual orientations/identities are equally entitled to protection from harm and abuse.

At Study Mind, we strive to offer tuition services within a caring, positive, safe, and stimulating environment. This approach is designed to foster the academic, social, physical, and moral development of each child or young person. We emphasise creating and maintaining an environment where children and young people feel and are safe, where they are respected and encouraged to speak openly.

Our commitment includes ensuring that the wishes and feelings of children and young people are taken into account when deciding on safeguarding actions and services to provide.

All our staff are well-informed about safe professional practices and strictly adhere to our safeguarding policies.


Study Mind has a duty to ensure all service providers of Study Mind courses are given appropriate safeguarding measures and all lessons take place in a safe environment.


As well as students, this safeguarding policy is mandatory for all Study Mind tutors, staff, volunteers and agency workers. Appropriate measures are put in place to ensure that tutors are protected in terms of safety and wellbeing in all communications with Study Mind clients, staff and students.

The Designated Safeguarding Lead is Daniela Prataviera, Senior Manager.
The requirements for this position are:
– Level 3 Safeguarding from https://cpdonline.co.uk/course/safeguarding-children-level-3/
– FGM
– Self Harm Training
– Domestic Abuse Training
– Child Sexual Exploitation Training

– Prevent and Anti-Radicalisation Training

– Safer Recruitment Training
– Anti-Bullying Training
– Online Safety Training

The other members of the safeguarding team are:
– Aashir Akram, Senior Manager
– Dr Mohil Shah, Founder
– Dr Kunal Dasani, Founder


The training requirements for this team are:
– Study Mind Safeguarding Training
– Enhanced DBS checks – Level 2 Safeguarding Training from https://cpdonline.co.uk/course/safeguarding-children-level-2/
– FGM
– Self Harm Training
– Domestic Abuse Training
– Child Sexual Exploitation Training
– Prevent and Anti-Radicalisation
– Anti- Bullying Training
– Online Safety Training

The training requirements for this team are:
– Study Mind Safeguarding Training
– Enhanced DBS checks
– Anti-Bullying Training
– Online Safety Training
– Self Harm Training
– Safer Recruitment Training

2. Legislative Framework

2a. This Safeguarding Policy is to ensure all students on a Study Mind course are able to benefit from our services within the remits of the child safeguarding standards of the United Kingdom Law. This Policy is derived from a variety of legislative provisions and statutory guidance. In particular, it is based on good practice found in:

  • Children Act 1989
  • Human Rights Act 1998
  • United Nations Convention on the Rights of the Child, 1991
  • Sexual Offences Act 2003
  • Female Genital Mutilation Act 2003 (referred to as FGM 2003)
  • Children Act 2004
  • Safeguarding Vulnerable Groups Act 2006
  • The Forced Marriage (Civil Protection) Act 2007
  • The Equality Act 2010
  • Children and Families Act 2014
  • Anti-Social Behaviour, Crime and Policing Act 2014
  • Modern Slavery Act 2015
  • Counter Terrorism and Security Act 2015
  • Children and Social Work Act 2017
  • Data Protection Act 2018
  • Voyeurism (Offences) Act 2019
  • Domestic Abuse Act 2021
  • Children’s Code (issued under S125 DPA 2018, effective Oct 2021)
  • Mental Capacity Act 2005

2b. Our safeguarding policy and procedures comply with all of this guidance and are updated with agreement between the entirety of the Study Mind Management team.

2c. The following legislation is also incorporated into this policy:

  • The Children Act 1989 (and 2004 amendment), which gives a broad framework for the care and protection of children and includes provisions for Local Authority inquiries, care proceedings, and emergency provisions.
  • Female Genital Mutilation Act 2003 S 5B(11), as inserted by section 74 of the Serious Crime Act 2015 (referred to as FGM 2003 in this policy)
  • The Rehabilitation of Offenders Act 1974 outlines provisions for when people with criminal convictions can work with children.
  • ‘Regulated activity’ in relation to children is found in Schedule 4 of the Safeguarding Vulnerable Groups Act 2006.
  • Keep Children Safe in Education (KCSIE), update 2024.
  • Mental Capacity Act 2005, in recognition that this policy also covers any students over 16+ that come under the definitions in this policy.

2d. Where disclosures are pertaining to international students, Study Mind will seek to inform local authorities when working with organisations and schools so that they can deal with the matter in an appropriate manner. If it is an individual student booking, or there is no suitable responsible adult involved (for example, if the allegation is against the guardian we have on file), then Study Mind will attempt to share relevant information with international and UK authorities.

3. Definitions

3a. Safeguarding and promoting the welfare of children and young people is defined for the purposes of 

this guidance as:

• protecting children and young people  from maltreatment

• preventing the impairment of children and young people’ mental and physical health or development

• ensuring that children and young people  grow up in circumstances consistent with the provision of 

safe and effective care, and

• taking action to enable all children to have the best outcomes. (KSCIE, 2024)

3b. Abuse is a violation of a person’s human and civil rights by any other person.  It is where someone does something to another person, or to themselves, which puts them at risk of harm and impacts on their health and wellbeing.

Abuse comes in many forms and can often have a damaging effect on the health and wellbeing of an individual, the effects may be short term, or may last a long time.  The signs of abuse aren’t always obvious, and the victim may not tell anyone what is happening to them – sometimes they may not even be aware they are being abused.

Adults and children are potential victims and perpetrators, so Study Mind has an obligation to monitor and safeguard all interactions to ensure safety across all services.

3c. Abuse can be (but not limited to):

  • Emotional abuse: Continuous maltreatment of a child resulting in impairment of the child’s emotional development, self-esteem, and sense of self-worth. This may include, but is not limited to, belittling, berating, bullying (also cyberbullying), constantly criticising, rejecting, emotionally manipulating or ridiculing the child, depriving them of the opportunity to express their views, silencing them, imposing developmentally inappropriate expectations, or verbally or non-verbally conveying that they are unloved or worthless. It may also include witnessing the ill- treatment of somebody else or overprotecting the child, thus impeding their exploration and learning, as well as participation in social interactions. Whilst emotional abuse is usually present in all types of maltreatment of a child, it may also occur on its own. 
  • Psychological abuse: Psychological abuse involves the regular and deliberate use of a range of words and non-physical actions used with the purpose to manipulate, hurt, weaken or frighten a person mentally and emotionally; and/or distort, confuse or influence a person’s thoughts and actions within their everyday lives, changing their sense of self and harming their wellbeing. 
  • Physical abuse: This involves the hurting or injuring of a child by ways such as hitting, shaking, throwing, poisoning, burning or scalding, drowning and suffocating.May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
  • Sexual abuse: This involves forcing or persuading a child to take part in sexual activities. This could be directly – by touching a child – or indirectly, for example, making a child watch sexual activities or act in a sexualised way online. It includes grooming a child in preparation for abuse, often via the internet. Child sexual exploitation is a form of sexual abuse.
  • Female genital mutilation: FGM (also referred to as ‘female circumcision’, ‘cutting’, ‘initiation’, ‘sunna’, ‘infibulation’, ‘gudniin’, ‘halalays’, ‘tahur’, ‘megrez’, ‘khitan’) is a violent and abusive procedure involving alteration or partial or total removal of the external female genital organs, which is performed for non-medical reasons, e.g. control of female sexuality. It is often performed by medically unqualified individuals on young girls aged between infancy and 16 years old by the means of instruments such as knives, razor blades, glass, scalpels or scissors. FGM is recognised as a violation of the human rights of girls and women (WHO, 2014), and its practice is illegal in the UK. According to the NHS (2016), approximately 66,000 girls aged 13 and under are at risk of FGM in the UK. Those with FGM may suffer from very serious long-term physical, mental and psychosexual effects.
  • Child Sexual Exploitation (CSE): Where an individual or group uses an imbalance of power to coerce, manipulate or deceive a child into sexual activity.  In some cases, this is in exchange for something the victim wants and may benefit the perpetrator or facilitator (e.g. financially or through increased status).
  • Child Criminal Exploitation CCE:  Where an individual or group uses an imbalance of power to coerce, manipulate or deceive a child into criminal activity. In some cases, this is in exchange for something the victim wants and may benefit the perpetrator or facilitator (e.g. financially or through increased status). children and vulnerable adults might become part of street gangs for whom crime and violence is integral to their identity, organised criminal gangs for whom involvement in crime is their ‘occupation’ and is carried out for personal gain (e.g. financial), or a type of organised crime known as ‘county lines’, where urban gangs exploit young people into moving drugs from a hub (a large city) into other markets in suburban areas and coastal towns by using dedicated mobile phone lines. Children as young as 12 years old have been known to be exploited for drug-moving purposes. This may also include children being trafficked away from their home area and staying in short-term private rental accommodation or the home of a drug user.
  • Financial abuse: The act of exerting excessive financial control, harm or exploitation of another. This includes theft or financial exploitation, the misuse or misappropriation of possessions or benefits.
  • Domestic abuse:  This includes physical, sexual, emotional or psychological and financial abuse mentioned above. This may also include honour-based abuse. Children raised in households where there is domestic violence may suffer from long-term mental health problems.
  • Organisational abuse: A form of mistreatment caused by inadequate care or support within an institution, e.g. care homes, young offenders’ institutions, pupil referral units, services for those with learning difficulties, substance treatment centres
  • Neglect: A wide array of behaviours, including neglecting to care for one’s basic needs and well-being, e.g. personal hygiene, appropriate clothing, health or surroundings and includes behaviour such as hoarding.

3d. Children are considered to be abused or at risk of abuse by parents/carers when the basic needs of the child are not being met through acts of either commission or omission.  Children include everyone under the age of 18 (KCSIE, 2024). 

Knowing what to look for is vital to the early identification of abuse and neglect. It is imperative that staff at Study Mind are able to use their experience to identify signs. If staff are unsure, they should always speak to the designated safeguarding lead (or deputy).  

All staff are aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their own experiences as harmful (KCSIE, 2024).  

All staff should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and consensual and non-consensual sharing of nudes and semi-nudes images and/or videos can be signs that children and young people are at risk.

3e. Study Mind recognises that, whilst most definitions refer to adult to child abuse, child on child abuse is also applicable under any of these definitions (see below for more information). 

3f. Special Educational Needs (SEN) and students with disabilities may require additional other measures in place.
Not all SEN children are considered to be disabled. The Equality Act 2010 describes a disability as:

‘A physical or mental impairment, which has a long term (a year or more) and substantial adverse effect on their ability to carry out normal day to day activities’. 

This includes sensory impairments, such as those affecting sight or hearing, and long-term conditions such as asthma, epilepsy and cancer.

Children and young people with such conditions don’t necessarily have SEN, but there are significant overlaps between disabled children and young people  and those with SEN. 

If a disabled child, young people or adult needs special educational provision they are also covered by the SEN definition.

Study Mind’s aim is to treat each individual student with good quality care, and additional measures are considered for any student, not just students in this category.

4. Responsibilities

4a. Study Mind recognises that safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who comes into contact with  children and their parents or carers has a role to play in safeguarding them.

Study Mind has a robust and present Safeguarding Management Team in place, in order to ensure this policy is adhered to. One member of the Safeguarding Management Team must be on shift for 4 hours per day Monday to Friday or 1 hour per day on Saturday, Sunday and major holidays.

Daniela Prataviera – Designated Safeguarding Lead
Dr Mohil Shah – Deputy Safeguarding Lead
Dr Kunal Dasani – Cover Deputy Safeguarding Lead
Daniela Prataviera – Online Safety Lead
Dr Mohil Shah – Deputy Online Safety Lead

Designated Safeguarding Lead (DSL)
This person is responsible for the overall Safeguarding strategy, updating and organising. They are the key contact point for tutors and staff at Study Mind needing to report safeguarding concerns or receive relevant training. They are also a key liaison for all external organisations working with Study Mind in regards to safeguarding.

Deputy Safeguarding Lead
This person acts in a supporting role to the DSL, helping with maintenance of standards and ensuring that cover extends beyond just one person responsible. Their role is also to hold the DSL accountable should issues occur.

Cover Deputy Safeguarding Lead
This role is another supporting role, ensuring that the minimum presence is possible at all times and to ensure that other staff are also accountable.

Online Safety Lead/Deputy Online Safety Lead
This role specifically pertains to the organisation and implementation of our online safety protocol and ensuring that all aspects of our online safety policies, including but not limited to Prevent and Safer Recruitment, are properly handled by the team, any allegations investigated and training provided.

Please see the Role Description for Nominated Safeguarding Lead for more information on these roles.

4b. Study Mind management are responsible for:

  • Safer Recruitment

Study Mind complies with all legislation around safeguarding during recruitment and all senior management are required to attend Safer Recruitment and general safeguarding training as part of their role. 

Safer Recruitment measures at Study Mind include (but not limited to):

  • Requiring video interviews of all employees prior to recruitment.
  • Requiring references, which include explicit reference to suitability to work with children, from all administrative and management recruitment cycles. For tutors, who sometimes do not have explicit working experience, a history of working with young people in a supervised setting is required.
  • Requiring DBS checks (minimum Enhanced) and suitability checks on all employees prior to recruitment.
  • Yearly mandatory updates in training on safeguarding, in addition to regular training on topics such as online safety.
  • Clear procedures and reporting requirements for all tutors and staff. 
  • Anonymised methods for whistleblowing and feedback for all staff.
  • Communications monitoring

All communications between staff, students, parents, tutors and organisations are monitored by Study Mind staff to ensure that guidelines are followed. All chats are accessible by multiple members of staff to ensure additional security.

  • Allegations monitoring

Study Mind keeps detailed records of all and any allegations made against, to or by Study Mind to ensure that these are followed up correctly and monitored by the DSL. Where needed, these records are incorporated into training. All records are anonymised if made accessible to staff other than the senior management team.

  • Safeguarding training for all staff

Study Mind provides training to all employees on general safeguarding, reporting procedures and following the Code of Conduct.

4c. All Study Mind tutors are required to:

  • Observe and comply with the Study Mind Code of Conduct.
  • Attend all relevant training and development provided by Study Mind and be aware of all their responsibilities in line with Keeping Children Safe in Education 2019.
  • If a student discloses to a tutor that they are being abused, the tutor should report this to the Designated Safeguarding Lead (DSL) as soon as possible. The Designated Safeguarding Lead (DSL) is responsible for ensuring that  children are identified and the appropriate agency involved.
  • Know how to deal with a disclosure of self-harm, suicidal thoughts, suicide attempts, overdosing or eating disorders. The Designated Safeguarding Lead should be informed.
  • Report instances of actual or suspected child abuse or neglect to the Designated Safeguarding Lead, or in their absence, the Deputy, in line with the Child Protection Procedures and legal duty for reporting FGM as set out in this policy.
  • Know what to do in the event of an allegation made against someone working with  children. If such a disclosure is made, the tutor should report this to the DSL.
  • Be alert to the signs of harm and abuse, including issues that can manifest themselves due to peer on peer abuse. This is most likely to include, but not limited to: bullying (including cyber bullying), gender-based violence/sexual assaults and sexting.
  • Tutors should follow the Child Protection Procedures with regards to peer on peer abuse as outlined in this policy.
  • Know the Designated Safeguarding Lead’s name and contact details including telephone numbers and email.
  • Be aware of the early help process. This includes identifying emerging problems, liaising with the Designated Safeguarding Lead, sharing information with other professionals to support early identification and assessment and, in some cases, acting as the lead professional in undertaking an early help assessment.

4d. Study Mind will:

  • Assess the impact of this policy in keeping children and vulnerable adults safe.
  • Contribute any local, contextual information that may support children’ safety and welfare.
  • Receive and consider regular reports from tutors about the effectiveness of safeguarding and child protection at the company
  • Keep abreast of training to ensure that tutors have the skills, knowledge and understanding necessary to keep all children and vulnerable adults safe.

4e. Study Mind has a duty of care to tutors, who are often young people themselves. Study Mind will:

  • Educate and engage tutors on working rights in the UK, ensuring that tutors have clear information around work, fair and prompt payment and policies that ensure that no tutor is disadvantaged through their work at Study Mind.
  • Provide safe and open spaces for communication on grievances, so tutors are able to provide feedback on their experience at Study Mind. 
  • Ensure that no direct communication between tutors, students or guardians happens outside of the communication set up by Study Mind. At all times a member of Study Mind must be present (either through presence in a group chat or through recording) to review communication and ensure that no abuse takes place.
  • Operate a zero tolerance policy on any abuse towards any one associated with Study Mind. Abuse from Study Mind employees or clients will be investigated thoroughly by the DSL and, where necessary, may lead to an immediate termination of contracts, suspension of lessons and referral to local authorities.

4f. Any member of Study Mind staff disclosing, investigating or dealing with abuse allegations are given additional support and encouragement for leave if needed and urged to seek out mental health support.

4g. There are two categories of concerns: 

1. Concerns / allegations that may meet the harm threshold.

2. Concerns / allegations that do not meet the harm threshold – referred to for the 

purposes of this guidance as ‘low-level concerns’. (KSCIE, 2024).


Study Mind will create an environment in which there is no such thing as ‘low level concerns’. All allegations are treated seriously and by taking a zero tolerance approach, Study Mind seeks to create an environment in which abuse is spotted early and does not have any chance to embed itself or for toxic practices to go uninvestigated. As such, Study Mind will investigate all allegations in good faith.

Low-Level Concerns

A low-level concern is any concern that an adult (either Study Mind staff, tutor or other) has behaved in a way that:

  • is inconsistent with the Study Mind Code of Conduct. This includes inappropriate conduct both inside and outside of work, scheduled lessons and monitored communication.
  • does not meet the threshold of harm or is not considered serious enough for Study Mind 

to refer to the local authority.

  • Demonstrates a lack of awareness about ‘safe’ behaviour, whether malicious or not.

Low-level concerns include a spectrum of behaviours which may be

  • intentionally designed to facilitate abuse 
  • unintentional, inadvertent or thoughtless

The key is that the behaviour is inappropriate and not what Study Mind expects, as set out in our Code of Conduct and our Safeguarding Standards. It may take place across any part of our service, between staff, tutors, students and stakeholders.

Examples include (but are not limited to):

  • showing favouritism or special treatment
  • being over-friendly or displaying non-professional behaviour
  • using inappropriate language that is sexual, profane, intimidating or offensive
  • inappropriate touching or initiating hugging (if in person), or discussions of such
  • intimidation, punishment or degrading treatment 

Study Mind recognises that the appropriate reaction to this kind of low level concern is how escalation of behaviour to further abuse can be prevented. As such, Study Mind staff and tutors:

  • are clear about what is meant by appropriate behaviour and can distinguish this from 

concerning, problematic or inappropriate behaviour in themselves and others (the Code of Conduct)

  • can recognise the importance of professional boundaries and when to report concerns (through induction training, Code of Conduct and ongoing training in Safer Study Mind)
  • feel empowered to share any low-level concerns with the DSL and through the 

reporting system

  • know that the response will be measured and proportionate.

Low Level Concerns Procedure
Anyone at Study Mind suspecting or finding evidence of behaviour that fits into this category should take the following steps:

  • Complete a Safeguarding Report as per the Figure below.
  • If preferred, speak to the DSL first. It is their responsibility to address this with the individual staff member and this will be done completely anonymously. It is the responsibility of the DSL to decide how far to escalate the investigation, depending on the proof and allegation.
  • Any behaviour found or deemed to be malicious in intent, or part of a wider escalation in behaviour, will result in immediate dismissal from Study Mind and may lead to further investigation by the authorities.
  • Where the behaviour is deemed careless and/or due to a lack of awareness of correct procedure, the staff member will be suspended following further training.
  • In all cases of low level concern, additional training and monitoring will be available to all Study Mind staff to ensure that expectations are clear and there is no confusion. 

Absenteeism

Definition: when a student does not attend a pre-arranged or expected tutoring session. This can be either for online events or face to face events.

Study Mind recognizes that missing education can be a critical indicator that a child may be at risk of harm or neglect. We take unexplained absences seriously and will ensure that every student’s non-attendance is followed up. In the event of an unexplained or prolonged absence from a tuition session:

The procedure is as follows for online events:


1. Study Mind tutors and admin will send out a message to the student themselves, to check why the lesson was missed immediately. All information must be fed back to the safeguarding and senior management team. A follow up message (by two forms of contact information, such as email and phone) must be sent within 24 hours.


2. If this is not responded to within 24 hours, then the Study Mind admin will reach out to the assigned guardian on the account within 48 hours and ask them why the lesson was missed. All information must be fed back to the safeguarding and senior management team.


3. If this leads to any disclosures from either the student, their guardian or Study Mind staff, a Report Form will be completed and it will be followed up as a disclosure of abuse. It may be necessary for the DSL to contact local authorities/schools/police as required.


4. If the absence is noted as a ‘regular’ absence (in that, the session was simply forgotten, or the student was otherwise busy for legitimate reasons), the monitoring team will escalate that group in order to ensure that this is not a repeated pattern of behaviour. Repeated missed lessons, whether with seemingly ‘innocent’ or legitimate reasons, will be followed up on by senior management and may lead to a disclosure if any Study Mind member of staff suspects something warranting a disclosure. As per our policy, it is better to react to small actions than wait for ‘big’ danger.


Children Missing from Education (CME)



Definition: Children missing education (CME) is defined as those who are of a compulsory school age, but are either not registered at a school or else not receiving suitable education in place of a school setting. (SCIE: Department of Education, 2016).


Study Mind primarily operates online, but when operating in person events, has strict policies to ensure children and young people’s attendance is carefully monitored.

1. Attendance registers
For events such in person mocks, work experience events and in person group events, all bookings require the personal information of the student due to attend and confirmation from an adult that they are permitted to attend. Students must all have an emergency contact stated for the day. Where students cannot provide an adult or emergency contact, local authorities may be listed to ensure that students are safe and accounted for.
Study Mind staff on site are provided with a full register of all students booked in to attend. Students are marked as attending upon entry to the event.

2. Missing students
When a student is not in attendance, the first port of call will be for Study Mind staff to contact the student directly to check. In most cases, this is all the action required. Where there is no response, the emergency contact will be contacted.
If there is still no response, Study Mind will contact another 2 times over the next 72h. If there is no response from the student or emergency contact, the DSL may decide to contact local authorities for a welfare check.

School events
When students are taking part in a Study Mind event organised by a school, the school takes responsibility for ensuring that all students are in attendance as the event will take place on school grounds during the school day.

Missing children and vulnerable adults protocol

If a child is identified as missing, meaning their whereabouts are unknown and their absence is out of character, the following steps will be taken:

  • Immediate attempts will be made to contact the student and their guardian within the first 24 hours.
  • If no response is received, the case will be escalated to the Designated Safeguarding Lead (DSL), who will notify local safeguarding authorities to assess the situation.
  • In cases where there are serious concerns for the child’s safety, the police will be contacted immediately to conduct a welfare check.
  • All cases of children missing education for more than 5 days will be immediately reported to the relevant Local Authority. 
  • Study Mind staff will cooperate fully with law enforcement and other agencies to provide all necessary information, ensuring the child’s safe return.

Staff and tutors are reminded to maintain close communication with the safeguarding team and report any concerns immediately.


Safeguarding children and vulnerable adults with Special Educational Needs and Disabilities (SEND)


Study Mind recognises that there may be differences in safeguarding requirements between children and young people with and without special educational needs and circumstances. These differences are addressed on an individual level and may be subject to an individual plan in order to ensure full safety of the student.

Children and vulnerable adults with special educational needs and disabilities (SEND) face unique challenges in safeguarding. These children may be more vulnerable to abuse, neglect, and bullying due to difficulties in communication, dependence on carers, or being isolated from peers. Study Mind is committed to ensuring that:

  • All staff and tutors undergo specific training to recognise the signs of abuse or neglect in children and vulnerable adults with SEND, with additional guidance on how to support children and vulnerable adults who may have difficulty communicating their experiences.
  • Any safeguarding concern related to a student with SEND is handled with additional care, recognising that behaviour changes, physical signs of abuse, or emotional withdrawal might be misattributed to their condition, rather than potential harm.
  • Where appropriate, Study Mind will work closely with a child’s social worker, school’s Special Educational Needs Coordinator (SENCo), and family to ensure all safeguarding plans account for the child’s specific vulnerabilities.
  • We will ensure that children and vulnerable adults with SEND are not disproportionately affected by the safeguarding procedures and that their concerns and voices are heard and respected, providing additional support when required.

5. Online Safety and Communication 

5a. All Study Mind online communication is monitored and tracked for safety. These procedures are made clear in the tutor induction documents, Code of Conduct and this document. Study Mind has an Online Safety Policy that provides more in depth information on these policies.

5b. Social media safety is an integral part of this policy. Social media is defined as all methods of direct online communication, including (but not limited to) Facebook, Twitter, WhatsApp, Instagram and YouTube.

All social media coming from Study Mind must be approved by the management team and must not:

  • Include anything amounting to bullying or discrimination
  • Include any identifying information of Study Mind staff or students
  • Include any images without permission
  • Include anything amounting to abuse of any kind
  • Divulge any Study Mind intellectual property, policies not public or speak in a disparaging way about interactions
  • Misrepresent Study Mind, its services or staff members.

Staff and students must not under any circumstances, either during or after a booking, communicate or add each other on private or personal social media. Discovery of this will lead to immediate termination of contracts on both sides. In cases where staff and students knew each other personally prior to joining Study Mind, then employees must ensure that all communications abide by this policy.

5c. Photography policy- Study Mind recognises that it is vital to protect images of  children and vulnerable adults from misuse. 

  • Study Mind requires all lessons to be recorded for safety and monitoring purposes. Tutors are guided through the Code of Conduct to keep these recordings safe for no more than 3 months and never save them or share them. This means keeping them on their platform and only ever sharing recordings either directly with students within Study Mind’s messaging platform, via email through Study Mind or to Study Mind directly.
  • Any images or recordings used for promotional purposes must be approved by students and guardians and not have any identifying information about anyone involved.
  • Strong policies and procedures are clearly put in place where it is clear to all involved what is considered appropriate.

5d. As outlined in KCSIE 2024, Study Mind recognise the considerable breadth of issues classified within online safety, which have been categorised into the following four areas:

  • content: being exposed to illegal, inappropriate or harmful content, for example: pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism
  • contact: being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as children with the intention to groom or exploit them for sexual, criminal, financial or other purposes’
  • conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images (e.g., consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying; and
  • commerce – risks such as online gambling, inappropriate advertising, phishing and or financial scams. If anyone is at risk, please report it to the Anti-Phishing Working Group.

Study Mind will ensure that safety online is an embedded element of all our procedures, policies and services. 

5e. Tutors are all provided with safeguarding training as a part of their induction. This training is offered through the tutor induction programme, Safer Study Mind training each November and in the Tutor Training sessions throughout the year. 

5f. All online interaction between students is strictly limited. No contact details between students is ever shared by Study Mind, nor visible during group classes, classrooms or events. During group sessions, students are permitted to communicate only via the shared chat box (on Zoom or Teams), which is monitored at all times either by the tutor (for smaller classes or weekly events) or by a member of the safeguarding team for large scale webinars and one-off events, where comments are limited to only hosts to avoid issues.

6. Safeguarding procedures reporting and managing concerns about a child or young person

The process for recording safeguarding incidents, concerns and referrals in line with current legislation including Working Together to Safeguard Children 2015 for children and young people.

6a. Tutors and staff will follow the necessary child protection procedures if an incident occurs. 

Safeguarding Procedure

Figure 1: Safeguarding process

Step 1: Immediate Identification

Tutors are made aware through the induction training of signs of abuse. Any at risk students are additionally monitored by the Safeguarding Team through the Monitoring channels. It is everyone’s responsibility to keep children safe, and this must not be left up to anyone else.

Step 2: Contact Points
If an issue occurs, a referral should be made to the DSL immediately. Tutors can ring the direct number to the DSL in this document, or call the central office on +44 (0)2033059593 to report the incident. In an emergency, always contact the Police or emergency services on 999 for UK based students. For international students, numbers can be accessed on here: https://smartdriving.co.uk/Driving/Driving_emergencies/numbers.html

Step 3: External Referral
Study Mind are responsible for ensuring that any other responsible parties are involved, such as schools, guardians or local authorities.

Step 4: Report Form
Tutors and DSL will collaborate on the Safeguarding Report Form completion. This document may be shared with other parties, depending on the exact circumstances and gives written proof of what has happened and tracks the steps necessary.

Step 5: Await Next Steps
The incident must be fully investigated by Study Mind and other authorities in order to ensure the safety of the students involved. Tutors may or may not be contacted directly by other parties as needed in order to give further information, and Study Mind will offer the tutor additional support if needed. All updates must be noted on the Safeguarding Report Form to ensure that a full investigation takes place and all information is kept confidential.

Step 6: Feedback Loop
Every allegation must be followed up by an internal investigation to ensure that Study Mind’s procedures worked as intended and if any improvements can be made in how things were handled.

Step 7: Mandatory Reporting
Tutors are given yearly training during Safer Study Mind month (November) when they are tested on their understanding of their safeguarding role at Study Mind and reminded of their commitment to report all incidents, and that Study Mind is committed to the protection of children. The reporting of concerns relating to safety concerns, even if not currently ongoing (for example, historic abuse, Female Genital Mutilation (FGM), bullying outside of Study Mind lessons and so on) is mandatory.

6b. When a tutor  suspects that any student may have been subject to abuse, or a student has suggested that abuse has taken place either to themselves or another student, the allegation must be reported immediately to the Designated Safeguarding Lead (DSL). The DSL will ensure the allegation is acted on within the same day. It is best practice to ensure that all colleagues who are involved in the allegation are informed of the outcome, so there is closure or continual vigilance as necessary. Appendix A shows our Safeguarding Reporting Form

6c. Reporting

All Safeguarding concerns will be investigated within 24 hours of receiving the report. It is vital that incidences are reported as soon as possible to allow prompt investigation. 

To help the Safeguarding team respond and refer appropriately you should follow the guidance below.

  • Remember that concern forms are used in court cases and inquiries as evidence.
  • Reports should be objective and detailed.
  • Please alert the team as soon as possible. It can take several hours to deal with even urgent concerns and the earlier we start the better.

6d. Disclosures

What is a disclosure?
A Disclosure is an allegation of harm under any of the definitions above made against someone, whether or not they are connected with Study Mind. All disclosures must be treated seriously.

How to react to a disclosure
It is important remember the 3 R’s when dealing with a disclosure:

  • Receive: Listen carefully, quietly and patiently. Allow the child to explain everything with as little interruption and reaction from you as possible. It is key to not judge, get upset or angry, even if the disclosure is upsetting. Please speak to Study Mind about support for yourself later on.
  • Reassure: It may be helpful to the child to show some understanding, such as ‘I hear what you are saying’, or some sympathy, such as ‘I can hear how upsetting that was for you’. Try to avoid big reactions, or promising things that may not happen, such as convictions in a criminal court, or that ‘everything will be OK’. Remember to thank the student for their openness and commend their bravery in doing so.
  • Report: Ensure that you get as much accurate detail as possible down in any reporting, so it can be fully investigated and dealt with. Include dates, times and all details included by the student and their own words, including any slang or swear words. Do not destroy this- the DSL may require your original notes as an appendix for Safeguarding Form and external agencies like the Police may ask for this as evidence.

Once a disclosure has been made the Safeguarding Team will consider all the information and if necessary taking advice and will make a decision to either:

  • Make a child or adult protection referral to Children’s/Adult’s Social Care
  • Keep detailed records of the concern with no further action
  • Liaise with the host school’s Designated Safeguarding Lead

It is vital that where a child is likely to suffer from harm or is suffering that a referral to children’s or adult’s social care (and if appropriate the police) is made urgently 

Once the decision is made to make a referral the Safeguarding Team will contact the relevant Social Care Team and make a telephone referral. This must be followed up in writing within 24 hours.

6e. Emergency Response
Where a child is identified at immediate risk of harm then the tutor should urgently  contact the Designated Safeguarding Lead who will in turn contact the Police for the areas where the risk is located using 999.  This is especially important when the child  is being tutored at home and there is no school teacher present. For events such as the Work Experience, all Emergency Contracts, whether on site or not, must also be informed, but only once the proper authorities have been first called to deal with the emergency.

Within one working day of a referral being made, a local authority social worker should acknowledge receipt to the referrer and make a decision about the next steps and the type of response that is required.

Where tutors are delivering tuition to children in a school or college, the Study Mind team must inform the school’s Designated Safeguarding Lead/ Officer of any safeguarding concern.

6f. Storing Information Regarding Safeguarding Concerns

All safeguarding issues, discussions, decisions, and the reasoning behind these decisions, should be meticulously documented using the Study Mind Safeguarding Incident Report Form. These records must be promptly forwarded to the Designated Safeguarding Lead (DSL) via the [email protected] email address. Staff members unsure about the recording process should consult with the DSL for guidance.

Documentation should be completed as soon as possible following the incident or event. It should use the individual’s own words and be signed and dated by the staff member or tutor. Child/Adult protection records will strictly note facts and avoid personal opinions. If there are observed injuries, a body map should be included.

In cases of immediate concern, staff should consult with a DSL before filling out the form, as the reporting of urgent matters is a priority.

Safeguarding records for each individual will be kept separately from other records, stored in a dedicated ‘safeguarding’ folder on the company’s shared drive, accessible only to DSLs and Deputy DSLs (DDSLs).

These records will be kept confidential and secure, in line with data protection laws. They will be centrally and securely stored by the company.

Upon a child’s transfer to another school or college, safeguarding records will be sent under confidential and separate cover, in compliance with data protection legislation. These will be handed directly to the new DSL, and a receipt of delivery will be obtained.

The DSL at Study Mind will also assess whether it is appropriate to share any information with the DSL at the educational institution the child or young person attends.

When Study Mind receives child/adult protection files, the DSL will ensure that key staff are informed of relevant details as necessary.

6g. Local Safeguarding Children Partnership

Study Mind works with their local safeguarding children partner – Hillingdon Council to help protect children and young people.

7. Safeguarding Issues

All Study Mind staff should have an awareness of any safeguarding issues that can put children and vulnerable adults at risk of harm. Behaviours linked to issues such as drug taking/alcohol misuse, deliberately missing education, radicalisation, consensual and non-consensual sharing of nude and semi-nude images and/or videos , and serious violence are all signs that children and vulnerable adults are at risk. Below are specific issues that Study Mind highlights as key issues

Child on Child Abuse

Study Mind believes that all children and vulnerable adults have a right to study in a safe environment. Children should be free from harm, both from adults and other students in our sessions. Children may be harmed by other children or young people.

All Study Mind staff recognise that child on child abuse can happen inside and outside of school or college and online. All Study Mind staff should be clear as to the school or college’s policy that we are working with with regards to procedures on child-on-child abuse and the important role required in preventing and responding to this where they believe a child may be at risk.

All Study Mind staff are aware that even if there are no reports that they have seen regarding child on child abuse it does not mean it is not happening (KCSIE 2024). It may be the case that it is happening but is not reported therefore all Study Mind staff including tutors have a responsibility if they have any concerns at all regarding child on child abuse they should speak ot the DSL.

All Study Mind staff are aware how important challenging inappropriate behaviours between children is, many of which are listed below that are abusive in nature. Downplaying certain behaviours, for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of growing up” or “boys being boys” can lead to a culture of unacceptable behaviours, an unsafe environment for children and in worst case scenarios a culture that normalises abuse leading to children accepting it as normal and not coming forward to report it.

All staff recognise that children can abuse their peers and are trained to record any concerns during group sessions or disclosures to the DSL. All child on child abuse is unacceptable and will be taken seriously. For group events such as the Work Experience, these policies are laid out clearly to staff, students and guardians.

It is most likely to include, but is not limited to:

● Bullying (including cyberbullying);

● Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or

otherwise causing physical harm;

● Sexual violence, such as rape, assault by penetration and sexual assault;

● Sexual harassment, such as sexual comments, remarks, jokes and online

sexual harassment, which may be stand-alone or part of a broader pattern of

abuse;

● Sexting including pressuring another person to send a sexual image or video

content (also known as youth produced sexual imagery);

● Upskirting, which typically involves taking a picture under a person’s clothing

(not necessarily a skirt) without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm (upskirting is a criminal offence and may constitute sexual harassment). Anyone of any gender can be a victim;

● Teenage relationship abuse – defined as a pattern of actual or threatened acts of physical, sexual or emotional abuse, perpetrated against a current or former partner;

● Initiation/hazing – used to induct newcomers into an organisation such as sports team or school groups by subjecting them to a series of potentially humiliating, embarrassing or abusing trials which promote a bond between them; and

● Prejudiced behaviour – a range of behaviours which causes someone to feel powerless, worthless or excluded and which relates to prejudices around belonging, identity and equality, in particular prejudices linked to disabilities, special educational needs, ethnic, cultural and religious backgrounds, gender and sexual identity.

Bullying is a very serious issue that can cause children considerable anxiety and distress. At its most serious level, bullying can have a disastrous effect on a child’s well- being and in very rare cases has been a feature in the suicide of some young people. All incidences of bullying, including cyber-bullying and prejudice-based bullying should be reported to the DSL (where group sessions take place within a school, all concerns should be noted to the DSL before leaving the premises).

All Study Mind staff recognise that addressing inappropriate behaviour (even if it appears to be relatively unharmful) can be an important intervention that helps prevent problematic, abusive and/or violent behaviour in the future. 

Procedures against Child on Child Abuse

Study Mind takes a zero-tolerance approach to peer-on-peer abuse, recognizing that children and vulnerable adults can be harmed by their peers both inside and outside educational settings. This can include bullying, physical abuse, sexual violence, harassment, and harmful sexual behavior. Our policy ensures that:

  • All allegations of peer-on-peer abuse are taken seriously, investigated promptly, and managed according to our safeguarding procedures.
  • Any student who is found to have been involved in abuse will be dealt with in accordance with our behaviour policy, with appropriate sanctions, and support for the victim.
  • We will work closely with parents, guardians, and external agencies to support both the victim and perpetrator, recognizing that both may need intervention to prevent further harm.
  • Additional training will be provided to staff to recognize the signs of peer-on-peer abuse, including inappropriate sexualized behaviour, cyberbullying, and upskirting. Early intervention is critical to ensure the safety of all students.
  • Peer-on-peer abuse may occur within group settings, online platforms, or in person. All communications between students are monitored, and any form of bullying or inappropriate behaviour will be reported to the DSL.

Child Criminal Exploitation (CCE)

As stated earlier, CCE is where an individual or group uses an imbalance of power to coerce, manipulate or deceive a child into criminal activity. In some cases, this is in exchange for something the victim wants and may benefit the perpetrator or facilitator (e.g. financially or through increased status). 

CCE can also affect any vulnerable adult over the age of 18 years.

Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, or pickpocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Children can become trapped by this type of exploitation, as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the activity appears to be something they have agreed or consented to.

It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however Study Mind staff should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

Key indicators that children are at risk of CCE:

  • Child withdrawn from family;
  • Sudden loss of interest in school or change in behaviour. Decline in attendance or academic achievement (although it should be noted that some gang members will maintain a good attendance record to avoid coming to notice);
  • Being emotionally ‘switched off’, but also containing frustration / rage;
  • Starting to use new or unknown slang words;
  • Holding unexplained money or possessions;
  • Staying out unusually late without reason, or breaking parental rules consistently;
  • Sudden change in appearance – dressing in a particular style or ‘uniform’ similar to that of other young people they hang around with, including a particular colour;
  • New tattoos with gang style symbols
  • Dropping out of positive activities;
  • New nickname;
  • Unexplained physical injuries, and/or refusal to seek / receive medical treatment for injuries;
  • Graffiti style ‘tags’ on possessions, school books, walls;
  • Constantly talking about another young person who seems to have a lot of influence over them;
  • Breaking off with old friends and hanging around with one group of people;
  • Associating with known or suspected gang members, closeness to siblings or adults in the family who are gang members;
  • Starting to adopt certain codes of group behaviour e.g. ways of talking and hand signs;
  • Going missing;
  • Being found by Police in towns or cities many miles from their home;
  • Expressing aggressive or intimidating views towards other groups of young people, some of whom may have been friends in the past;
  • Being scared when entering certain areas; and
  • Concerned by the presence of unknown youths in their neighbourhoods.

Study Mind staff including Study Mind tutors should be aware of the risks of child criminal exploitation and immediately contact the DSL if any suspicion of CCE has arisen. 

Child Sexual Exploitation (CSE)

CSE is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by penetration (for example, rape or oral sex) or nonpenetrative acts such as masturbation, kissing, rubbing, and touching outside clothing. It may include non- contact activities, such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse including via the internet.

CSE can occur over time or be a one-off occurrence and may happen without the child’s immediate knowledge for example through others sharing videos or images of them on social media.

CSE can affect any child who has been coerced into engaging in sexual activities. This includes 16- and 17-year-olds who can legally consent to have sex. Some children and vulnerable adults may not realise they are being exploited for example they believe they are in a genuine romantic relationship.

CSE can also affect any vulnerable adult over the age of 18 years.

Study Mind safeguarding staff are provided with basic training in CSE in order to help with awareness and understanding of this complex behaviour and abuse. This training is designed to help support and provide guidance if CSE is suspected or part of a disclosure. 

Identification of CSE

CSE is often a hidden harm, and explicit evidence of exploitation may not be evident. Children and young people may not disclose their experiences. This can be out of fear of recriminations, feelings of shame and guilt or because they do not recognise their own exploitation or they fear they will not be believed. Equally when professionals are seen as reliable and consistent and are curious and confident about asking what is happening then young people will be more likely to disclose hence the need for Study Mind tutors to remain professional at all times. 

Study Mind tutors should always be open to the possibility that the children and vulnerable adults you work with might be affected.

There are inherent factors that make any child vulnerable to CSE. Some children display additional vulnerabilities. Find below a list of factors that make students more vulnerable to CSE:

  • Family breakdown
  • Domestic/sexual abuse or neglect
  • Bullying in or out of school
  • Family/peer involvement in CSE
  • Parents who themselves are at risk of abuse, neglect or who self-neglect
  • Looked after children – those living in children’s homes
  • Learning disabilities/difficulties
  • Poverty
  • Forced marriage
  • Social exclusion/isolation
  • Asylum/refugee children or young people with non-secure immigration rights

Study Mind staff recognise that CSE is a form of sexual abuse and any concerns related to CSE should immediately be reported to the DSL.




Upskirting and other sexual harassment

Definition:

Upskirting refers to the act of taking a photograph or video under someone’s clothing without their consent, primarily to capture intimate areas, with the intent of humiliation, distress, or sexual gratification. This practice is a criminal offence under UK law (Voyeurism Offences Act 2019).
Sexual harassment is any unwanted behavior of a sexual nature that violates a person’s dignity, makes them feel intimidated, degraded, or humiliated, or creates a hostile environment. It can include verbal, non-verbal, or physical actions and can occur in various settings such as workplaces, schools, or public spaces.

Examples of sexual harassment include:

  • Unwelcome sexual advances or requests for sexual favours
  • Inappropriate or sexually suggestive comments, jokes, or gestures
  • Unwanted physical contact, such as touching, grabbing, or groping
  • Displaying or sharing sexually explicit images or content
  • Staring or leering in a sexual manner
  • Sexual harassment can be targeted at individuals of any gender and is a violation of both personal and legal rights in many jurisdictions.

Study Mind has a zero-tolerance policy toward upskirting or any forms of sexual harassment. Any attempt to engage in or facilitate sexual harassment will result in disciplinary action and may be reported to the police.


Where Study Mind is not the host of an in-person event, such as taking part in a school talk, then Study Mind will use the existing policy of the host company/location.

Awareness and Education

Staff Training: All staff members must undergo annual safeguarding training that includes information on upskirting, recognising signs, and understanding how to report incidents.

Reporting

Immediate Action: If upskirting or any sexual harassment is suspected or reported, the incident must be reported to the Designated Safeguarding Lead (DSL) or on site staff member immediately. Study Mind will handle reports with sensitivity, ensuring the victim’s privacy and well-being are prioritised.

Investigations: A prompt and thorough investigation will be conducted, and appropriate action will be taken in line with Study Mind’s disciplinary policies.


Technology Management:

Restricted Use of Mobile Devices: Study Mind will enforce clear guidelines on mobile phone usage during events. Checks of mobile devices, in accordance with consent agreements, may be conducted to ensure inappropriate images or videos have not been taken or shared.

Reporting

If an upskirting or sexual harassment incident occurs, Study Mind will report the matter to the police, in accordance with legal obligations, and work with parents or guardians to ensure proper support for the victim.

Any staff member or student who suspects or witnesses upskirting must report it immediately to the Designated Safeguarding Lead (DSL).

Domestic Abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children and vulnerable adults can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn.

The Domestic Abuse Act 2021 introduces that a child who sees or hears, or experiences the effects of, domestic abuse and is related to the person being abused or the perpetrator, is also to be regarded as a victim of domestic abuse in their own right. This will help to ensure that locally commissioned services consider and address the needs of children affected by domestic abuse.

The definition from the Home Office is as follows:

“Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence and abuse between those aged 16 or over, who are or have been intimate partners or family members regardless of gender and sexuality.

This can encompass, but is not limited to, the following types of abuse:

  • Physical or sexual abuse
  • Violent or threatening behaviour
  • Controlling or coercive behaviour
  • Economic abuse
  • Psychological, emotional or other abuse
  • It does not matter whether the behaviour consists of a single incident or a course of conduct.

Controlling behaviour is a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour.

Coercive behaviour is: an act or a pattern of acts of assault, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten their victim.”

Study Mind tutors recognise the importance of domestic abuse as an important element of safeguarding and where there is any suspicion of domestic abuse, immediate contact should be made with Study Mind’s DSL. Study Mind safeguarding staff are provided with basic training in Domestic Abuse and how to help students as part of a disclosure. 

Female Genital Mutilation (FGM)

Female genital mutilation (FGM) comprises all procedures that involve partial or total removal of the external female genitalia, or other injury to the female genital organs for non-medical reasons. The practice is mostly carried out by traditional circumcisers, who often play other central roles in communities, such as attending childbirths. In many settings, health care providers perform FGM due to the belief that the procedure is safer when medicalised

FGM is recognised internationally as a violation of the human rights of girls and women. It reflects deep-rooted inequality between the sexes, and constitutes an extreme form of discrimination against women. It is nearly always carried out on minors and is a violation of the rights of children. The practice also violates a person’s rights to health, security and physical integrity, the right to be free from torture and cruel, inhuman or degrading treatment, and the right to life when the procedure results in death.

Factors indicating that girls are at risk of FGM

The most significant factor to consider when deciding whether a girl or woman may be at risk of FGM is whether her family has a history of practising FGM. In addition, it is important to consider whether FGM is known to be practised in her community or country of origin.

The age at which girls undergo FGM varies enormously according to the community. The procedure may be carried out when the girl is new-born, during childhood or adolescence, at marriage or during a first pregnancy.

Given the hidden nature of FGM, individuals from communities where it takes place may not be aware of the practice. Women and girls who have undergone FGM may not fully understand what FGM is, what the consequences are, or that they themselves have had FGM. Given this context, discussions about FGM should always be undertaken with appropriate care and sensitivity.

Study Mind safeguarding staff receive basic training in FGM to ensure that they are aware of it and can refer students to relevant services if it is part of a disclosure. 

It is believed that FGM may happen to girls in the UK as well as overseas. Girls of school age who are subjected to FGM overseas are likely to be taken abroad (often to the family’s country of origin) at the start of the school holidays, particularly in the summer, in order for there to be sufficient time for her to recover before returning to school.

There are a number of factors in addition to a girl’s or woman’s community, country of origin and family history that could indicate she is at risk of being subjected to FGM. Department of Health guidance on FGM risk and safeguarding include the following potential risk factors may:

  • Child or women’s mother has undergone FGM
  • Other female members have had FGM
  • Father comes from a community known to practice FGM
  • A female family elder is very influential within the family and is / will be involved in the care of the girl
  • The socio-economic position of the family and the level of integration within UK society can increase risk
  • Parents state that they or a relative will take the child out of the country for a prolonged period
  • Family not engaging with professionals i.e.: health or school
  • A child may talk about a long holiday (usually over the school summer holiday) to her country of origin or another country where the practice is prevalent
  • A child may confide to a Study Mind tutor or Study Mind staff that she is to have a ‘special procedure’ or to attend a special occasion
  • A Study Mind employee hears reference to FGM in conversation, for example a child may tell other children about it
  • Girl with draws from PSHE lessons
  • Any other safeguarding alert already associated with the family

If a Study Mind tutor or any Study Mind member of staff discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the individual must report this to the police.

Mental Health

All Study Mind staff including tutors should be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

In order to support spotting signs of severe mental health distress, relevant members of the Study Mind Safeguarding Team have basic training in self harm, to develop a basic awareness of spotting and supporting students and tutors.

Study Mind staff are not appropriately trained professionals to make a diagnosis of a mental health problem however if any staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken by speaking to the designated safeguarding lead or a deputy.


Mental Capacity

It is generally assumed that adults are capable of making informed choices about their own lives. However, if an individual is determined to lack the mental capacity to make decisions about their safety, these decisions will be made in their best interests, following the guidelines of the Mental Capacity Act (MCA) 2005 and its Code of Practice. This policy applies to individuals over 16, so is applicable to students identified as children (as in, under 18).

In cases where an individual with mental capacity chooses to stay in an abusive environment, it’s important to evaluate whether their decision is made without intimidation or coercion, with a clear understanding of the risks, and with access to relevant services in case they decide to seek help later. If there’s a concern that their decision has been compromised by threats or coercion, thus questioning its validity, their best interests must be considered, potentially overriding their consent to take further protective actions.

The MCA defines someone is lacking capacity, because of an illness or disability such as a mental health problem, dementia or a learning disability, who cannot do one or more of the following four things:

  • Understand information given to them about a particular decision
  • Retain that information long enough to be able to make the decision
  • Weigh up the information available to make the decision
  • Communicate their decision. 

Refer to the Mental Capacity Act Code of Practice, https://www.gov.uk/government/publications/mental-capacity-act-code-of-practice.

Study Mind will need to involve an advocate if the person lacks capacity to make decisions about a safeguarding concern.

Support and guidance will be sought from Study Mind should anyone have concerns regarding an individual’s capacity.

There are instances where the consent of an individual with mental capacity might need to be overridden, such as when there are risks to others, a threat of serious harm, or the occurrence or likelihood of a serious crime.

Individuals who are, or may be, victims of abuse should be provided with information, advice, and support in a manner they can comprehend. Their opinions should be taken into account in all decision-making processes concerning their lives.

Decisions made by professionals regarding an individual’s life should be prompt, reasonable, justifiable, proportionate, ethical, and thoroughly documented.


Mental Health and Safeguarding

Study Mind recognises that children’s mental health is a fundamental part of their overall wellbeing. Poor mental health can not only be a safeguarding concern in its own right but may also be a sign that a child is experiencing abuse, neglect, or exploitation. To this end, Study Mind will:

  • Ensure that all staff and tutors are given basic training to recognise signs of mental health issues, including anxiety, depression, self-harm, or suicidal ideation.
  • Provide a safe and supportive environment where students feel comfortable disclosing mental health concerns. All disclosures will be treated confidentially and will be escalated to the DSL where there are concerns about the student’s welfare or safety.
  • Actively support students by referring them to external mental health services where appropriate, including the child’s school counsellor, local mental health services, or national helplines.
  • Engage with parents, guardians, and schools to ensure that any concerns regarding a student’s mental health are approached holistically, ensuring a coordinated response from all parties involved in the child’s care.

Serious Violence

All staff should be aware of the indicators, which may signal children and vulnerable adults are at risk from, or are involved with, serious violent crime. These may include increased absence from school or college, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children and vulnerable adults have been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation.

Annexes A & B of KSCIE contains important additional information about specific forms of abuse and safeguarding issues. Study Mind requires all staff and tutors to read the annexes in conjunction with this policy and supporting procedures, including the updates for KSCIE 2024.

Prevent and Anti-Radicalisation

For more in depth information on our procedures and policy, please see the Prevent and Anti-Radicalisation Policy.

Radicalisation refers to the process by which individuals come to support terrorism and extremist ideologies associated with terrorist groups. It often targets vulnerable individuals, including children and young people, through a variety of means, such as social media, peer influence, or direct contact with radical groups. These individuals may be drawn into a dangerous path of extremism, potentially leading to criminal behaviour and terrorism-related activities.

The Prevent strategy is part of the UK government’s overall counter-terrorism strategy, known as CONTEST. Prevent aims to stop individuals from becoming involved in terrorism by providing support and safeguarding vulnerable people. It focuses on early intervention by identifying those at risk and offering appropriate support to divert them from the path of radicalisation.

Study mind recognises its responsibility to protect young people and all those that come into contact with our organisation. We have clear procedures and train all our staff in recognising radicalisation in our yearly training.

Channel Programme

Channel is a voluntary, confidential support program designed to provide early intervention to individuals identified as vulnerable to being drawn into terrorism. It operates through collaboration among local authorities, the police, statutory partners (such as the education sector, social services, youth services, and offender management services), and the community. The aim is to support individuals in diverting them away from the path of extremism before any criminal activity occurs.

Children and young people considered to be at risk of involvement or potential involvement in extremist activities will be referred to the Multi-Agency Safeguarding Hub (MASH) by the Study Mind safeguarding team. MASH will share these details with the Prevent lead police officer and the Local Authority’s Prevent coordinator. Once received, the referral is processed through the MASH information-sharing system, while the Prevent police officer conducts an initial screening. If concerns are substantiated, the Prevent police officer will refer the case to the Channel Practitioner for further support and intervention.

7. Allegations Against Study Mind Tutors and Staff

7a. Study Mind recognises its duty to report concerns or allegations against its directors, staff, or tutors. All directors, staff and tutors must comply with the relevant Code of Conduct when performing their role in order to promote safer working practices.

7b. Allegations of abuse against directors, staff or tutors can be made by either a child or an adult and should be made immediately to the DSL. Allegations made against the DSL should instead be made to another member of the leadership team who will inform the other team members. Another suitable senior member of staff will then be appointed to take the place of the DSL in response to the allegation.

7c. All allegations of abuse made against tutors must be brought to the attention of the Study Mind immediately. All investigations will be investigated thoroughly and may involve disclosure to third party associations where necessary. If advised by LADO, Study Mind will refer to DBS or Teachers services to indicate potential prohibition from teaching.

7d. Study Mind is committed to holding any staff member to account and all incidences of abuse allegations, whether confirmed or not, must be accompanied by a full company investigation into the culture and situation that led to it, to ensure that lessons are learned and that policies and procedures are improved.

7e. Study has clear Code of Conduct documents and disciplinary measures in place in order to ensure that clear expectations are set for working with Study Mind.

7f. This guidance should be followed when any Study Mind representative has:

  • behaved in a way that has harmed a child, or may have harmed a child and/or
  • possibly committed a criminal offence against or related to a child, and/or
  • behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children, and/or
  • behaved or may have behaved in a way that indicates they may not be suitable to work with children. This includes in and outside responsibilities at Study Mind (KCSIE 2023, Section 1: Part 355-356 and updated in KCSIE 2024)

7g. Study Mind will deal appropriately and promptly with all allegations or concerns and refer all safeguarding concerns or allegations about its directors, staff or tutors immediately to the appropriate local authority designated officer (LADO) in accordance with local safeguarding procedures and practical guidance, in accordance with the statutory guidance Working Together to Safeguard Children, 2018.

7h. Study Mind will consider immediate suspension (without prejudice) if a safeguarding allegation is made against any director, staff member or tutor pending investigation when there is cause to suspect that another child(ren) are at risk of harm from their continued contact with children (KCSIE 2024)

7i. Suspension will also be considered even if the allegation is not linked to their role or activity with Study Mind.

8. Compliance, DBS Requirement and Duty to Report

8a. All tutors and students using Study Mind’s services have a responsibility to familiarise themselves with the Safeguarding Policy.
As a part of this, all tutors must have an active, current DBS (Enhanced) which must be kept up to date. Tutors are responsible for signing up to the update service themselves, but Study Mind requires that a current updated DBS is attached to their tutor profile in order to be active on the system. Study Mind also reserves the right to do checks on profiles, before assigning them to students or at random, and any tutor found with a nearing expiry DBS is suspended temporarily to allow time to get this sorted. Anyone with an expired DBS is instantly terminated from working at Study Mind. Tutors are recommended to join the update service to avoid issues with expiration.
International police checks (bar Scotland or Ireland) are not permitted for administrative reasons.

8b. Any tutor who is reported for a serious breach of the Safeguarding Policy will be suspended from Study Mind tutoring effective immediately. The final decision for a minor breach will be the responsibility of Study Mind. 

8c. Any tutor reported for illegal activity whilst using Study Mind services will be reported to policy and appropriate authorities including the General Medical Council and General Dental Council if necessary. This also includes tutoring students independently outside of Study Mind contracted hours and sharing of materials without notifying Study Mind.

8d. Staff found to be not following this policy will be subject to disciplinary measures and may also be reported if they fail to undertake the duties to the best of their ability. There may also be penalties in place for responsible staff members who are found to have not disclosed information that was vital to an investigation or to withholding information. 

8e. Under legal duties to make referrals to the Disclosure and Barring Service, Study Mind will report any concerns about unsafe practice by any of its directors, staff or tutors to the Disclosure and Barring Service (DBS). This applies where an individual has engaged in conduct that has either harmed (or is likely to harm) a child; or if a person otherwise poses a risk of harm to a child. (KCSIE 2024)

8f. If at any time Study Mind dismisses a director, member of staff or tutor due to relevant conduct, risk of harm or receiving a caution or conviction for a relevant offence (or the person has resigned or left that post in circumstances where they may have been removed), then a referral to the Disclosure and Barring Service will be made by the DSL.

9. Safeguarding Governance and Learning Lessons

9a. Safeguarding is the responsibility of everyone in Study Mind. The senior management team are however responsible for ensuring that procedures are followed, clear and that records are kept up to date.

Designated Safeguarding Lead:

Name: Daniela Prataviera

Role: Senior Manager

Email: [email protected]

Number: +447721280003 

9b. Study Mind is committed to quality assurance of the Safeguarding procedures and policy. All disclosures are reviewed as part of regular updates to this policy. One full review is completed each year (next one due October 2025) and smaller updates are added throughout the year to ensure that this policy is fit for purpose. The senior management team at large are responsible for this oversight to ensure that it is kept to a high standard.

9c. Study Mind is committed to learning any lessons, alongside support and guidance with the LADO to determine whether there are any improvements to be made to our procedures, or to help prevent similar events in the future. This includes lessons learned about suspension, reinstatement after suspension. (KCSIE 2024)

10. Prevent, extremism and anti-radicalisation

10a. Radicalisation is defined as the introduction of extreme views that are detrimental to society to any member of the public. Vulnerable groups such as students are especially susceptible.

10b. Study Mind has a specific Prevent and anti-radicalisation policy that details the measures and procedures in place to protect students, staff and partners. In summary, this policy forms part of the overall provision of safeguarding support and any disclosures are made under the same procedures as in this document.

10c. Study Mind has an Anti-Radicalisation risk assessment in Annex A on the Prevent policy.

11. Anti-Bribery

Bribery is the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust. Bribery is a criminal offence.

Study Mind operates a zero tolerance policy for any form of bribery from staff, students and organisations. 

11a. Offence

It is a criminal offence to:

  • offer a bribe
  • accept a bribe
  • bribe a foreign official
  • as a commercial organisation,
  • to fail to prevent a bribe

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. Study Mind could also face prosecution and be liable to pay a fine.

11b. Definitions of Bribery and Corruption

Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business giving or receiving money, gifts, meals, entertainment or anything else of value as an inducement to a person to do something which is dishonest or illegal.

11c. Gifts and Hospitality

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. However, as an online based business dealing with high stakes educational services, Study Mind has opted to err on the side of caution.

No employee of Study Mind is permitted to accept gifts from any client or organisation that is or has purchased a service from Study Mind. 

Clients that wish to demonstrate appreciation in the form of gifts may approach Study Mind as an organisation to discuss what they would like to. Study Mind recommends that customers consider donations towards their charitable work and write positive online reviews.

Employees may accept gifts from Study Mind as a company, who reserves the right to send tokens of thanks for high performance to staff. These do not come under this policy, as they do not fit the criteria above.

11d. Policy

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact [insert name/position] so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to contact a member of senior management. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules. Study Mind will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately. Any incidences of bribery or corruption are taken very seriously and may lead to termination.

12. Whistleblowing

12a. Study Mind is committed to protecting any member of the staff, clients, or public that chooses to disclose a purposeful breach of this policy from ramifications.

Study Mind is committed to creating an open and honest environment in which no one is afraid to discuss issues as they see fit, and committed to addressing all issues, big or small, to ensure a fair and safe workplace. Concerns can be raised externally with The NSPCC Whistleblowing Advice Line on 0800 028 0285 [email protected]. Please see the Whistleblowing policy for additional information.

13. Children and vulnerable adults with Special Educational Needs and Disabilities

Study Mind is committed to the well-being and safety of all our learners including those with special educational needs and disabilities (SEND). It underpins all areas of our provisions as we believe children and vulnerable adults have a right to feel safe.  Close monitoring and early identification of safeguarding issues is critical. 

Study Mind recognises the unique safeguarding challenges faced by children and vulnerable adults with special educational needs and disabilities (SEND) or specific health conditions. These children and vulnerable adults might have a reduced ability to identify, resist, or escape from abusive situations.

We understand that children and vulnerable adults with SEND may experience communication difficulties and obstacles in reporting or managing abuse. We commit to providing appropriate support to these children, ensuring their concerns and experiences are heard and responded to effectively.

Our Designated Safeguarding Lead (DSL) will collaborate extensively with other agencies and Special Educational Needs Coordinators (SENCo) to tailor support as necessary.

Students with SEND often have increased vulnerability to abuse, bullying and social isolation, emotional and psychological challenges, and may have difficulty expressing concerns. This awareness extends to understanding that these challenges may not always be immediately apparent.

Staff members are urged to be vigilant and considerate in identifying potential signs of abuse, such as changes in behaviour or unexplained injuries. It is important not to automatically attribute these signs to the child’s disability. Additionally, staff should be aware that children and vulnerable adults with SEND or certain health conditions may be more vulnerable to issues like bullying, which might not always manifest in visible or expected ways.

Mechanisms are in place for learners to freely discuss any emotional/physical concerns, including external issues and we instil confidence In them that they will be heard and taken seriously. They know whom to address these to.

14. Safeguarding Vulnerable Groups

Study Mind acknowledges that some students might be living under circumstances that increase their vulnerability to abuse, neglect, or adverse outcomes. These students may require assistance or intervention from Early Help Services, CSSW, or other agencies to address their challenges or ensure their safety.

Children and vulnerable adults Who Have a Social Worker:

Study Mind recognises that children and vulnerable adults who are receiving social work services from CSSW, especially those under child in need or child protection plans, are likely to have experienced abuse, neglect, and trauma. Such experiences can adversely affect their behaviour and academic performance.

To support these children’s education and welfare, Study Mind will collaborate with social workers to effectively implement the child’s plan. A knowledgeable member of the Study Mind team, familiar with the child, will join the professional network, sharing information about safeguarding risks and attending planning meetings. In cases where this individual cannot attend, a competent colleague will substitute, or a comprehensive written report will be submitted.

Looked After Children (LAC):

Study Mind recognises that children and vulnerable adults often become looked after due to experiences of abuse or neglect, and that those who were previously in care continue to be vulnerable.

For looked after children, the Designated Safeguarding Lead (DSL) at Study Mind will maintain contact details of the child’s social worker and the name of the virtual school head in the authority responsible for the child.

15. Face to Face Tuition

We understand contextual safeguarding and recognise that children and vulnerable adults can be at risk of harm outside the home environment (in the community, at school etc). Our practice puts measures in place to identify and minimise these risks. 

Before beginning tuition, Study Mind carries out detailed risk assessments to incorporate any safeguarding risks.  

They are also given further tutor guidance which covers the following points:

  • Tutors should carry proof of their Enhanced DBS check along with a photo ID, such as a driving licence or passport, on their initial visit to a new student.
  • When working in schools or other educational settings, tutors may be asked to provide the institution with a copy of their Enhanced DBS check and photo ID. This information will be entered into the establishment’s Single Central Record (SCR) and removed after the tutoring assignment concludes.
  • They are not responsible for the physical welfare of the child, for example, a tutor cannot restrain a learner having a meltdown. 
  • Tutors must verify the presence of another adult, like a teacher, caregiver, parent, or another adult responsible for the child, before entering the tuition venue. If no such adult is present, the tutor should not enter and must explain this to the student or young person. In this situation, the tutor should promptly contact the DSL at Study Mind.
  • All communication MUST be through a parent/carer or alternative provision lead.  
  • They are not permitted to communicate directly with learners outside of tuition. 
  • Tutors are aware that they should not touch a student i.e. they should not place a hand on their shoulder, tap their back or leg even to say ‘well done’.  These actions can be misinterpreted and give rise to allegations. 
  • Tutors are expected to dress appropriately for tuition sessions, considering the setting and respecting the religious and cultural backgrounds of those they may meet during tuition.
  • All positive feedback must be given verbally or by written comment. If tutoring in a community setting, and the learner becomes unwell tutors must contact the parent/carer immediately who will advise arrangements for them to return home. The tutor then should inform Study Mind.

Tutors ensure that as part of tuition, they present opportunities to support learners in identifying safe and unsafe behaviours in a variety of situations. (incl. online safety), so they feel safe and can keep themselves & others safe at all times.

Suitable Environment for Tuition

Tutors need to conduct sessions in a suitable environment. The setting should allow the door to be kept ajar and be within hearing range of other adults. If the tutor is concerned about the appropriateness or safety of the environment, they should immediately report it to their Tuition Coordinator at Study Mind. If there’s a potential risk of harm to the child/young person or the tutor, they should inform the DSL straight away.

Tuition must NOT take place in the home unless a responsible adult is in situ.  This also applies to online sessions. 

Tuition cannot take place in a bedroom unless a responsible adult is present in the same room throughout the session.  

The area for tuition should be set up as a professional workspace, complete with a table, chair, adequate lighting, and necessary equipment. Distractions like mobile phones and TVs/radios should be turned off, and there should be no pets or smoking in the area.

13. Review

The Study Mind Safeguarding Policy will be reviewed annually (at a minimum) in order to maintain its adequacy to meet current Safeguarding Standards and will update it as needed, to ensure it is kept up to date with safeguarding issues as they emerge including any lessons learnt. 

Revisions to the policy will be made following any changes in national or local policies, significant local child protection issues, or alterations to our own procedures.

This policy needs to be reviewed at least every 12 months. Every 6 months there is a mini-review, which will coincide with operational staff training reviews. A full review will be completed each year. Other reviews may also take place as required throughout the year as required. 

All members of our team, including tutors and temporary staff, will receive a copy of this policy along with KCSIE 2024 updates. This policy will also be accessible on the Study Mind website.

Parents and carers will be provided with a summary of Study Mind’s Safeguarding & Child Protection Policy. We will inform them that the complete policy is available on our website or upon request.

The Designated Safeguarding Lead and Managing Director at Study Mind will regularly report on safeguarding activities and systems to the board of directors. These reports will not include specific details about individual learners or identifiable information about families, maintaining confidentiality as part of their oversight role. Please see the Nominated Safeguarding Lead Role Description for more information.

Study Mind is committed to maintaining the highest safeguarding standards. To ensure continuous improvement and accountability:

  • A review of all safeguarding incidents will be conducted regularly by the Safeguarding Team, identifying areas where policies and procedures could be enhanced based on lessons learned.
  • After every safeguarding incident, a formal debrief will take place with relevant staff members to assess the effectiveness of the response and whether further training or policy changes are required.
  • We will work in partnership with local safeguarding authorities and external experts to ensure that our practices are aligned with national standards and best practices.
  • Safeguarding governance will be reviewed by senior management at least annually to ensure compliance with legislation, with an interim review every six months to address any urgent updates.

Appendix A: Safeguarding Reporting Form

To be completed as fully as possible if you have concerns regarding a child and pass the information onto the Designated Safeguarding Lead (DSL). The DSL for Study Mind is Daniela Prataviera. The DSL will then look at the information and start to plan a course of action and if necessary contact the relevant organisations. 

This form is to be completed by the staff member who wishes to report the concern. The returned form will be sent directly to the DSL and Safeguarding team. It is not shared with other staff at Study Mind unless this is key to the resolution of the situation. Once completed, return to [email protected]

IF YOU THINK A CHILD OR ADULT WITH CARE AND SUPPORT NEEDS IS IN IMMEDIATE DANGER, DIAL 999 AND ASK FOR THE APPROPRIATE EMERGENCY SERVICE.

Section 1. Details of the childA child is anyone who has not yet reached their 18th birthday
Name of child 
Date of birth
Approx. age if date of birth not known
Gender
Section 2. Details of the incident or concern
Details of the incident or concerns:
Please indicate the abuse type if known (leave blank if uncertain)
Domestic abuseChoose an item.Sexual abuseChoose an item.Child traffickingChoose an item.
NeglectChoose an item.Online abuseChoose an item.Harmful sexual behaviourChoose an item.
Physical abuseChoose an item.Emotional abuseChoose an item.Bullying and cyberbullyingChoose an item.
Child sexual exploitationChoose an item.Female Genital MutilationChoose an item.
Have you spoken to the child?                                         If yes, what was said?
Have you spoken to the parent/carer(s)?                           If yes, what was said?
Are there any other children at risk?                                   If yes, add details and describe the risks that remain and action you are taking:
Section 3. Details of alleged abuser/suspect 
NameTitle
Address
PostcodePhone
Relationship to the child?Click or tap here to enter text.
If provider, please add the provider’s nameClick or tap here to enter text.
Does the abuser/suspect live with the child?                                          Click or tap here to enter text.
Section 4. Details of person reporting this incident/concern
Name******Title*******
Job Role Email*******
Team
PhoneDate/time referral completedClick or tap here to enter text.
Relationship to child (if applicable)
Are you reporting your own concerns or responding to concerns raised by someone else?          
If someone else please give their details (name, organisation/department, relationship to child (if relevant) and contact details)
Does the referrer consent to their details being shared with third parties?         
Section 5. Additional Information
Is there any other information you believe we need to know?
Signed: 
Date: 
OFFICE USE ONLY
Section 6. Sharing the concerns (to be completed by DSL)
Details of contact with social services where the child lives 
Details of contact with child’s school or any other agencies 
Details of the outcome of this concern


Appendix B: Key Contacts

Designated Safeguarding Lead: Daniela Prataviera

Email: [email protected]

Number: +44 7721 280003  (9am-5pm Monday-Friday)

Deputy Designated Safeguarding Lead: Mohil Shah

Email: [email protected]

Number: +447443022232 (Out of Hours)

Hillingdon MASH (Multi Agency Safeguarding Hub)

Number: 01895 556644

Email: [email protected]

Local Authority Designated Officer for Sheffield: Andrew Adedoyin

Email: [email protected]

Number: 0114 273 4850

Local Authority Designated Officer for Hillingdon: Hannah Ives

Email: [email protected]

Number: 01895 250975

Local Authority Designated Officer for Suffolk

Email: [email protected] or 

Number: 0300 123 2044

Local Authority Designated Officer for Worcestershire: 

Number:  01905 822666
Email (LADO): [email protected]
Further information: https://www.safeguardingworcestershire.org.uk/report-it/

Police (in an emergency) – 999

NSPCC – 0808 800 5000