Last Update: 1 August 2026

Designated Safeguarding Lead	Sara Gelsthorpe  •  sara@studymind.co.uk  •  +44 (0)7817 032628
Deputy DSL	Claire Winward  •  ap@studymind.co.uk  •  +44 (0)20 7189 2799
Out of hours	Dr Mohil Shah  •  business@medicmind.co.uk  •  +44 (0)7443 022232
Report a concern	sara@studymind.co.uk  •  Central office +44 (0)20 3305 9593
Emergency	If a child is in immediate danger, always dial 999

Document Control

Version	Date	Updated by
2.0	03.10.2022	Daniela Prataviera
3.0	08.12.2022	Mohil Shah
3.5	17.08.2023	Daniela Prataviera
4.0	29.09.2023	Daniela Prataviera
5.0	16.04.2024	Daniela Prataviera
6.0	19.09.2024	Daniela Prataviera
7.0	30.09.2025	Daniela Prataviera
8.0	12.01.2026	Sara Gelsthorpe
9.0	24.07.2026	Sara Gelsthorpe

Version 9.0 is to reflect Keeping Children Safe in Education 2026 (in force 1 September 2026), Working Together to Safeguard Children 2026, the Children’s Wellbeing and Schools Act 2026, the Department for Education’s statutory guidance on alternative provision (including Arranging Alternative Provision: A Guide for Local Authorities and Schools, 2025) and the national standards for non-school alternative provision (2025).

This policy is reviewed at least annually, with a mini-review every six months. Next full review: September 2027.

1. Introduction, Scope and Statement of Intent

1.1 Who this policy is for

This Safeguarding and Child Protection Policy is written in accordance with current legislation and statutory guidance and is maintained by the Study Mind management team. It applies to all students interacting with any service delivered under the brand names ‘Study Mind’, ‘Medic Mind’, ‘Oxbridge Mind’, ‘Dentist Mind’, ‘Law Mind’, ‘Vet Mind’ and any other part of the company. This includes direct students, referrals, and students commissioned by third-party organisations, including local authorities, schools and multi-academy trusts. For ease of reference, this policy refers to the business as ‘Study Mind’.

This policy is mandatory for all Study Mind tutors, staff, directors, volunteers and agency workers. Appropriate measures are also in place to protect the safety and wellbeing of tutors in all communications with Study Mind clients, staff and students.

1.2 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 with Study Mind – staff, tutors, directors, parents, families and learners – plays a vital role in keeping children safe.

Every student who participates in a Study Mind course should be able to do so in a safe and comfortable environment, free from discrimination as defined in our Inclusion, Equality and Diversity Policy. The wellbeing and safety of each student is our primary consideration and underpins all areas of our provision. 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.

We believe that all children (defined as anyone who has not yet reached their 18th birthday, 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 and sexual orientations or identities are equally entitled to protection from harm and abuse. Our commitment includes ensuring that the wishes and feelings of children and young people are taken into account when deciding on safeguarding actions and the services we provide.

1.3 The safeguarding team

The Designated Safeguarding Lead (DSL) is Sara Gelsthorpe. The Deputy Designated Safeguarding Lead (DDSL) is Claire Winward. Dr Mohil Shah and Dr Kunal Dasani act as Cover Deputy Safeguarding Leads, providing out-of-hours capacity. Sara Gelsthorpe is also the Online Safety Lead, with Claire Winward as Deputy Online Safety Lead.

The training requirements for the DSL are: Level 3 Safeguarding Children; FGM awareness; self-harm training; domestic abuse training; child sexual exploitation training; Prevent and anti-radicalisation training; safer recruitment training; anti-bullying training; and online safety training. DSL training is refreshed at least every two years, with knowledge and skills updated at regular intervals (at least annually) in line with Keeping Children Safe in Education (KCSIE) 2026.

The training requirements for the wider safeguarding team are: Study Mind safeguarding training; an Enhanced DBS check; Level 2 Safeguarding Children training; FGM awareness; self-harm training; domestic abuse training; child sexual exploitation training; Prevent and anti-radicalisation training; anti-bullying training; online safety training; and safer recruitment training.

2. Legislative and Statutory Framework

2.1 Statutory guidance

This policy ensures all students on a Study Mind course benefit from our services within the child safeguarding standards of United Kingdom law. It is written with regard to the following statutory guidance:

• Keeping Children Safe in Education (KCSIE) 2026 – in force from 1 September 2026. All staff and tutors are required to read Part One of KCSIE (the previous Annex A condensed version has been withdrawn).
• Working Together to Safeguard Children 2026 – the multi-agency framework for helping, supporting and protecting children, including the Family Help model and multi-agency child protection arrangements.
• Alternative Provision statutory guidance and Arranging Alternative Provision: A Guide for Local Authorities and Schools (DfE, 2025) – setting out the duties of commissioners and the assurances providers such as Study Mind must be able to give.
• National standards for non-school alternative provision (DfE, 2025) – Study Mind aligns its safeguarding, attendance and quality assurance arrangements with these standards (see Section 12).
• Prevent duty guidance under the Counter-Terrorism and Security Act 2015.
• The SEND Code of Practice: 0 to 25 years (2015) and Working Together to Improve School Attendance (July 2026 edition).

2.2 Legislation

This policy is derived from, and complies with, the following legislative provisions:

• Children Act 1989 and Children Act 2004
• Education Act 1996 (including section 19 duties on local authorities) and Education Act 2002
• Human Rights Act 1998 and the United Nations Convention on the Rights of the Child 1991
• Sexual Offences Act 2003
• Female Genital Mutilation Act 2003 (including section 5B(11), as inserted by section 74 of the Serious Crime Act 2015)
• Mental Capacity Act 2005
• Safeguarding Vulnerable Groups Act 2006 (including the definition of ‘regulated activity’ in Schedule 4)
• The Forced Marriage (Civil Protection) Act 2007
• Equality Act 2010 (supported by the Study Mind Inclusion, Equality and Diversity Policy)
• Children and Families Act 2014
• Anti-Social Behaviour, Crime and Policing Act 2014
• Modern Slavery Act 2015 and Counter-Terrorism and Security Act 2015
• Children and Social Work Act 2017
• Data Protection Act 2018 and UK GDPR (including the Children’s Code issued under section 125 DPA 2018)
• Voyeurism (Offences) Act 2019
• Domestic Abuse Act 2021
• Police, Crime, Sentencing and Courts Act 2022 (the Serious Violence Duty)
• Health and Care Act 2022 (offences of virginity testing and hymenoplasty)
• Online Safety Act 2023
• Children’s Wellbeing and Schools Act 2026
• Crime and Policing Act 2026 (the mandatory duty to report child sexual abuse, and the new offence of preventing a report)
• The Rehabilitation of Offenders Act 1974

The Children’s Wellbeing and Schools Act 2026 strengthens safeguarding oversight, including statutory multi-agency child protection teams, local authority registers of children not in school, a Single Unique Identifier for children to support information sharing, and new regulation of unregistered educational settings. Study Mind will cooperate fully with local authorities in implementing these measures and will update this policy as the relevant regulations and statutory guidance come into force.

2.3 The mandatory duty to report child sexual abuse

The Crime and Policing Act 2026, which received Royal Assent on 29 April 2026, introduces a new statutory duty for anyone in regulated activity with children to report child sexual abuse when they become aware of it – including where a child discloses abuse to them, or where they witness abuse occurring. A report must be made to the police or local authority as soon as reasonably practicable; where there is a risk to the child’s life, this may be delayed by no more than seven days to manage that immediate risk. The Act also creates a new criminal offence, punishable by up to seven years’ imprisonment, of attempting to prevent someone from making a report under this duty. Failure to comply with the duty may itself lead to a referral to the DBS for barring consideration.

At Study Mind, staff and tutors fulfil this duty by reporting immediately to the DSL, who ensures the report reaches the police or local authority within the statutory timeframe; this does not replace or delay the DSL’s existing duty to act on any disclosure, but reflects that failing to report is now itself a matter of individual legal liability, not only an internal policy expectation. Detailed operational guidance will be issued once the Home Office publishes its implementation guidance for this duty.

2.4 Local safeguarding arrangements

Study Mind operates in alignment with the Local Safeguarding Children Partnership (LSCP) relevant to each learner’s place of residence. We commit to adhering to the specific multi-agency safeguarding arrangements and thresholds of the relevant local authority, including local Family Help arrangements under Working Together 2026. A directory of local partnership contacts and referral pathways is maintained in Appendix C.

Where disclosures relate 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 appropriately. 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), Study Mind will attempt to share relevant information with the appropriate international and UK authorities.

3. Roles and Responsibilities

3.1 Safeguarding is everyone’s responsibility

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. Study Mind maintains a robust and present safeguarding team: one member of the safeguarding team must be on shift for four hours per day Monday to Friday, and one hour per day on Saturdays, Sundays and major holidays.

3.2 Safeguarding roles

Role	Responsibility
Designated Safeguarding Lead (DSL)	Responsible for the overall safeguarding strategy, its updating and organisation. Key contact for tutors and staff reporting concerns or receiving training, and key liaison for all external organisations, commissioners and statutory agencies.
Deputy Safeguarding Lead (DDSL)	Supports the DSL, helps maintain standards, ensures cover extends beyond one person, and holds the DSL accountable should issues occur.
Cover Deputy Safeguarding Leads	Ensure the minimum safeguarding presence is maintained at all times, including out of hours, and provide additional accountability.
Online Safety Lead / Deputy	Organise and implement the online safety protocol, ensure all aspects of online safety policy (including Prevent and safer recruitment online elements) are properly handled, investigate allegations and provide training.

Please see the Role Description for the Nominated Safeguarding Lead for further information on these roles. Full contact details for the safeguarding team appear on the cover page and in Appendix C.

3.3 Study Mind management responsibilities

Study Mind management is responsible for safer recruitment (Section 11), allegations monitoring, and safeguarding training for all staff. Detailed records are kept of all allegations made against, to or by Study Mind, ensuring they are followed up correctly and monitored by the DSL. Where needed, anonymised records are incorporated into training. All communications between staff, students, parents, tutors and organisations are monitored by Study Mind staff, and all chats are accessible by multiple members of staff to ensure additional security.

Study Mind will assess the impact of this policy in keeping children safe, contribute local contextual information that may support children’s safety and welfare, receive and consider regular reports from tutors about the effectiveness of safeguarding, and keep abreast of training so that tutors have the skills, knowledge and understanding necessary to keep all children safe.

3.4 Tutor responsibilities

All Study Mind tutors are required to:

• Observe and comply with the Study Mind Code of Conduct, including the inclusion and language standards set out in the Inclusion, Equality and Diversity Policy.
• Attend all relevant training and development provided by Study Mind and be aware of their responsibilities in line with KCSIE 2026, including reading Part One.
• Report any disclosure of abuse to the Designated Safeguarding Lead (DSL) as soon as possible. The DSL is responsible for ensuring that children are identified, the appropriate agency is involved, and any allegation against an adult is reported to the relevant Local Authority Designated Officer (LADO).
• Know how to respond to a disclosure of self-harm, suicidal thoughts, suicide attempts, overdosing or eating disorders, informing the DSL immediately.
• Report instances of actual or suspected child abuse or neglect to the DSL or, in their absence, the Deputy, in line with the procedures in this policy and the legal duty to report FGM.
• Report any concern that a child is carrying or using a weapon, or has expressed an intention to do so, to the DSL (or a deputy), who will assess the risk and take appropriate action (KCSIE 2026).
• Be alert to the signs of harm and abuse, including child-on-child abuse such as bullying (including cyberbullying), gender-based violence, sexual harassment and the sharing of nudes and semi-nudes.
• Know the DSL’s name and contact details, including telephone number and email.
• Be aware of the early help and Family Help processes: identifying emerging problems, liaising with the DSL, and sharing information with other professionals to support early identification and assessment.

3.5 Duty of care to tutors

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 clear information around work, fair and prompt payment, and policies that ensure no tutor is disadvantaged through their work. We provide safe and open channels for raising grievances and feedback. No direct communication between tutors, students or guardians may happen outside of the communication channels set up by Study Mind; at all times a member of Study Mind must have oversight (through presence in a group chat or through recording) to review communication and ensure that no abuse takes place.

Study Mind operates a zero-tolerance policy on abuse towards anyone associated with Study Mind. Abuse from Study Mind employees or clients will be investigated thoroughly by the DSL and, where necessary, may lead to immediate termination of contracts, suspension of lessons and referral to the appropriate authorities. Any member of staff disclosing, investigating or dealing with abuse allegations is given additional support, encouraged to take leave if needed, and urged to seek mental health support.

4. Definitions

4.1 Safeguarding

Safeguarding and promoting the welfare of children is defined, in line with KCSIE 2026, as: protecting children from maltreatment, whether inside or outside the home (including online); preventing the impairment of children’s mental and physical health or development; ensuring that children 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. A child is anyone who has not yet reached their 18th birthday.

4.2 Abuse

Abuse is a form of maltreatment of a child and a violation of a person’s human and civil rights by any other person. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Harm can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused in a family, institutional or community setting by those known to them or, more rarely, by others. They may be abused by an adult or adults, or by another child or children (child-on-child abuse). The signs of abuse are not always obvious, and a child may not tell anyone what is happening to them; they may not even recognise their own experiences as abusive.

The four categories of abuse (KCSIE 2026)

• Physical abuse: hurting or injuring a child by hitting, shaking, throwing, poisoning, burning or scalding, drowning or suffocating. It also includes Fabricated or Induced Illness (FII), where a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
• Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on their emotional development. This includes conveying to a child that they are worthless, unloved or inadequate, as well as cyberbullying, silencing, and the use of misinformation or conspiracy theories to manipulate a child’s world view.
• Sexual abuse: forcing or enticing a child to take part in sexual activities, including non-contact activities such as involving children in looking at, or in the production of, sexual images (including nudes and semi-nudes, and images generated using artificial intelligence), or watching sexual activities. It includes online grooming and the exploitation of children via digital platforms.
• Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. This includes failing to provide adequate food, clothing and shelter; failing to protect a child from physical and emotional harm or danger; and failing to ensure access to appropriate medical care or education.

Specific safeguarding issues

• Domestic abuse: any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members. Under the Domestic Abuse Act 2021, children who see, hear or experience the effects of domestic abuse are victims in their own right.
• Child sexual exploitation (CSE) and child criminal exploitation (CCE): forms of abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual or criminal activity (such as ‘county lines’ drug trafficking). Exploitation can occur even where activity appears consensual, and is closely linked to modern slavery and trafficking.
• Female genital mutilation (FGM): a form of child abuse and violence against women and girls, comprising all procedures involving partial or total removal of the external female genitalia for non-medical reasons. Teachers and tutors have a statutory mandatory reporting duty to report known cases of FGM in under-18s directly to the police.
• Child-on-child abuse: when a child is victimised by their peer(s), including bullying, sexual violence, sexual harassment, upskirting and the non-consensual sharing of nudes and semi-nudes. Study Mind maintains a zero-tolerance approach: it is never dismissed as ‘banter’ or ‘part of growing up’.
• Financial abuse: exerting excessive financial control or exploitation, including the theft or misappropriation of a child’s possessions, benefits or earnings.
• Organisational abuse: mistreatment, neglect or poor care standards within a setting (such as a school, care home or tuition setting) that violates a child’s dignity or represents a lack of protection.

4.3 Special educational needs and disabilities (SEND)

Students with special educational needs (SEN) and disabilities may require additional measures. Not all children with SEN are disabled. The Equality Act 2010 defines a disability as ‘a physical or mental impairment which has a long-term (a year or more) and substantial adverse effect on the ability to carry out normal day-to-day activities’. This includes sensory impairments and long-term conditions such as asthma, epilepsy and cancer. There are significant overlaps between disabled children and those with SEN, and if a disabled child needs special educational provision they are also covered by the SEN definition. Study Mind’s aim is to treat each individual student with high-quality care; the Inclusion, Equality and Diversity Policy provides the practical reasonable adjustments that tutors must follow.

5. Identifying Concerns: Signs, Indicators and Vulnerability

Knowing what to look for is vital to the early identification of abuse and neglect. Staff must use their experience and training to identify signs and, if unsure, always speak to the DSL or a deputy. All staff are aware that children may not feel ready, or know how, to tell someone they are being abused, exploited or neglected, and may not recognise their experiences as harmful.

Behaviours linked to issues such as drug taking, alcohol misuse, deliberately missing education, being persistently absent from education, and the consensual and non-consensual sharing of nudes and semi-nudes can be signs that children are at risk. In line with KCSIE 2026, staff recognise that being absent from education, as well as missing from it, can be a warning sign of a range of safeguarding concerns, including abuse, neglect, sexual exploitation and criminal exploitation (see Section 9).

5.1 Children who may be at greater risk

• Children with SEND or certain health conditions: additional barriers can exist when recognising abuse, including assumptions that indicators relate to the child’s condition, communication barriers, greater dependency on adults for care, and increased vulnerability to bullying and isolation. Any safeguarding concern relating to a student with SEND is handled with additional care, and behaviour changes, physical signs or withdrawal are never automatically attributed to their condition. Where appropriate, Study Mind works with the child’s social worker, the school’s SENCo and the family to ensure safeguarding plans account for the child’s specific vulnerabilities.
• Children who have a social worker: children receiving statutory social care support, especially under child in need or child protection plans, are likely to have experienced adversity or trauma. Study Mind collaborates with social workers to implement the child’s plan, joining the professional network, sharing information about safeguarding risks and attending planning meetings (or providing a comprehensive written report where attendance is not possible).
• Looked after and previously looked after children: the DSL maintains the contact details of the child’s social worker and the name of the virtual school head in the responsible authority.
• Children questioning their gender: in line with KCSIE 2026, Study Mind takes a cautious, individualised approach centred on the child’s welfare and best interests, is appropriately professionally curious about the child’s wider experiences and potential vulnerabilities, does not initiate social transition, and involves the DSL, the commissioning school and parents or carers as appropriate.
• Children in vulnerable circumstances: including young carers, children in kinship care, children affected by parental imprisonment or substance misuse, asylum-seeking and refugee children, and children experiencing poverty or homelessness.

6. Responding to Concerns: Safeguarding Procedures

This section sets out the process for recording safeguarding incidents, concerns and referrals in line with Working Together to Safeguard Children 2026 and KCSIE 2026.

Immediate notification requirement: in any instance where a child is identified as being at risk of significant harm, the relevant local Multi-Agency Safeguarding Hub (MASH), multi-agency child protection team or front door service must be notified immediately by telephone, following the local authority’s protocols. This verbal notification must be followed by a formal written referral (for example an IARF or online referral form) within 24 hours.

6.1 Categorising concerns: the harm threshold

To ensure a consistent and robust response, Study Mind categorises concerns about adults into two distinct areas, in line with KCSIE 2026:

• Concerns that meet the harm threshold: allegations that an adult has behaved in a way that has harmed, or may have harmed, a child; has possibly committed a criminal offence against or related to a child; has behaved towards a child in a way that indicates they may pose a risk of harm to children; or has behaved in a way that indicates they may not be suitable to work with children. These are managed under Section 10 and referred to the LADO.
• Concerns that do not meet the harm threshold (low-level concerns): any concern – no matter how small – that an adult’s behaviour is inconsistent with the Study Mind Code of Conduct or demonstrates a lack of awareness of safe professional boundaries.

Low-level concerns

A low-level concern is any concern that an adult (Study Mind staff, tutor or other) has behaved in a way that is inconsistent with the Code of Conduct (inside or outside of work), does not meet the threshold of harm, or demonstrates a lack of awareness about safe behaviour, whether malicious or not. Examples include showing favouritism or special treatment; being over-friendly or displaying non-professional behaviour; using language that is sexual, profane, intimidating or offensive; inappropriate touching or initiating hugging (if in person), or discussion of such; and intimidation, punishment or degrading treatment.

Study Mind recognises that responding well to low-level concerns is how escalation to abuse is prevented. Staff and tutors are clear about what appropriate behaviour looks like (via the Code of Conduct), recognise the importance of professional boundaries, feel empowered to share any low-level concern with the DSL, and know that the response will be measured and proportionate.

Low-level concerns procedure: anyone suspecting or finding evidence of such behaviour should complete a Safeguarding Report (Appendix A) or speak to the DSL first; concerns can be raised confidentially. The DSL decides how far to escalate, depending on the evidence and the allegation, and records all low-level concerns to identify patterns. Behaviour found to be malicious in intent, or part of a wider escalation, will result in immediate dismissal from Study Mind and may lead to investigation by the authorities. Where behaviour is careless or reflects a lack of awareness, the individual will be suspended pending further training. In all cases, additional training and monitoring is made available so that expectations are clear.

Local thresholds, Family Help and the continuum of need

While our internal assessments are guided by KCSIE 2026 and Working Together to Safeguard Children 2026, the threshold for external intervention is determined by the Local Safeguarding Children Partnership where the learner resides. Study Mind adheres to the continuum of need model used by local authorities. Under Working Together 2026, targeted early help and section 17 ‘child in need’ support are increasingly delivered through a single Family Help model, with a lead practitioner and a co-produced Family Help plan; the DSL will consult the relevant local authority’s published threshold guidance to determine the appropriate level of referral, from community-based early help through Family Help to statutory child protection intervention. In all cases of doubt, the DSL will prioritise the child’s best interests and default to a higher level of protective action.

6.2 The Study Mind reporting procedure

Figure 1: The Study Mind safeguarding process

• Step 1 – Immediate identification: tutors are made aware through induction training of the signs of abuse. At-risk students are additionally monitored by the safeguarding team through monitoring channels. It is everyone’s responsibility to keep children safe; this must never be left to someone else.
• Step 2 – Contact points: if an issue occurs, refer to the DSL immediately by ringing the direct number in this document or the central office on +44 (0)20 3305 9593. In an emergency, always contact the police or emergency services on 999 for UK-based students; for international students, contact the local emergency services for the student’s country (112 operates across the EU and many other countries).
• Step 3 – External referral: the DSL will identify the learner’s local authority and follow the specific referral pathway for that area (for example SPOA, MASH, multi-agency child protection team or front door service), consulting the directory in Appendix C to ensure the correct local thresholds and contact methods are used. For every learner on a school-commissioned placement, the DSL (or DDSL) will also ensure the student’s home school DSL is informed of the concern within the same working day, via secure email or telephone followed by written confirmation, including a copy of the completed Safeguarding Report Form, details of the actions taken by Study Mind and the contextual information the school needs to fulfil its statutory duty. All such sharing is conducted in accordance with UK GDPR, on the basis that fear of sharing information must never stand in the way of the need to promote the welfare and protect the safety of children (Working Together 2026).
• Step 4 – Report form: tutors and the DSL collaborate to complete the Safeguarding Report Form (Appendix A), which provides a written record and tracks the steps taken. It may be shared with other parties depending on the circumstances.
• Step 5 – Await next steps: the incident must be fully investigated by Study Mind and, where relevant, by statutory agencies. Tutors may be contacted directly by other parties for further information; Study Mind will offer the tutor additional support. All updates are recorded on the Safeguarding Report Form and kept confidential.
• Step 6 – Feedback loop: every allegation is followed by an internal review to ensure Study Mind’s procedures worked as intended and to identify improvements.
• Step 7 – Mandatory reporting: tutors receive annual training during Safer Study Mind month (November), when they are tested on their understanding of their safeguarding role and reminded of their commitment to report all incidents. Reporting concerns – including historic abuse, FGM and bullying outside Study Mind lessons – is mandatory.

When a tutor suspects that a student may have been subject to abuse, or a student suggests that abuse has taken place (to themselves or another student), the allegation must be reported immediately to the DSL. The DSL will ensure the concern is acted on within the same day and, where it concerns an adult, will report it to the relevant LADO. It is best practice to ensure that colleagues involved are informed of the outcome, so there is closure or continued vigilance as necessary.

6.3 Responding to disclosures: the 3 Rs

• Receive: listen carefully, quietly and patiently. Allow the child to explain everything with as little interruption and reaction as possible. Do not judge or become visibly upset or angry, even if the disclosure is distressing. Speak to Study Mind afterwards about support for yourself.
• Reassure: it may help to show understanding (‘I hear what you are saying’) or sympathy (‘I can hear how upsetting that was for you’). Avoid big reactions and never promise things that may not happen (such as convictions, or that ‘everything will be OK’). Thank the student for their openness and acknowledge their bravery.
• Report: record as much accurate detail as possible, including dates, times and the student’s own words (including any slang or swear words). Do not destroy your original notes – the DSL may require them as an appendix to the Safeguarding Form, and external agencies such as the police may ask for them as evidence.

Once a disclosure has been made, the safeguarding team will consider all the information, take advice if necessary, and decide either to: make a child protection referral to children’s (or adults’) social care; keep detailed records of the concern with no further action at this stage; and/or liaise with the host school’s Designated Safeguarding Lead. Where a child is suffering, or is likely to suffer, harm, a referral to children’s social care (and if appropriate the police) is made urgently. Telephone referrals are followed up in writing within 24 hours. Within one working day of a referral, a local authority social worker should acknowledge receipt and decide on next steps.

6.4 Emergency response

Where a child is identified as at immediate risk of harm, the tutor should urgently contact the DSL, who will contact the police for the area where the risk is located using 999. This is especially important where the child is being tutored at home with no teacher present. For in-person events such as work experience programmes, all emergency contacts (whether on site or not) must also be informed, but only once the proper authorities have first been called. Where tutors deliver tuition in a school or college, the Study Mind team must inform that setting’s Designated Safeguarding Lead of any safeguarding concern.

6.5 Safeguarding categorisation and tracking

To ensure effective individual tracking and to identify patterns of concern, all safeguarding reports are categorised using standardised tags within the Study Mind management system, which trigger specific workflows and inform termly reporting to the DSL and the Board.

Category tag	Definition and indicators	Threshold / action
Low-Level Concern (LLC)	Behaviour inconsistent with the Code of Conduct but not meeting the harm threshold, e.g. over-friendliness, favouritism, use of personal devices outside of policy.	Logged in the tracker; reviewed for patterns of behaviour.
Prejudicial Incident (PI)	Any incident perceived to be motivated by hostility or prejudice based on a protected characteristic (race, religion, disability, sexual orientation, gender identity, etc.).	Logged as a discriminatory incident; requires educational intervention for the perpetrator.
Prevent / Radicalisation (PRV)	Concerns related to extremist views, susceptibility to radicalisation, or use of extremist materials or narratives.	Immediate referral to the DSL; potential completion of the national Prevent referral form.
Child-on-Child Abuse (CCA)	Peer-to-peer harm, including sexual harassment, physical bullying or online shaming.	Requires individual safety plans for both the victim and the alleged perpetrator.

Every tag is recorded against the individual’s profile, creating a safeguarding chronology that allows the DSL to see whether a low-level concern is recurring and should be escalated to a formal allegation. A high-level overview identifies students or staff with multiple tags, triggering a multi-agency review where needed, and staff compliance with the educational requirements linked to these categories (for example Prevent training completion) is tracked.

6.6 Recording and storing safeguarding information

All safeguarding issues, discussions and decisions – and the reasoning behind them – are documented on the Study Mind Safeguarding Incident Report Form and forwarded promptly to the DSL via safeguarding@studymind.co.uk. Documentation is completed as soon as possible after the incident, uses the individual’s own words, and is signed and dated by the staff member or tutor. Records note facts and avoid personal opinion. If there are observed injuries, a body map should be included (Appendix B). In cases of immediate concern, staff should consult a DSL before completing the form, as urgent reporting takes priority.

Safeguarding records are kept separately from other records, in a dedicated safeguarding folder on the company’s shared drive accessible only to the DSL and DDSLs. Records are kept confidential and secure in line with data protection law. Upon a child’s transfer to another school or college, safeguarding records are sent under confidential, separate cover directly to the new DSL, and a receipt obtained. In line with KCSIE 2026, where a child moves setting the DSL will also consider whether information beyond the child protection file should be shared, for example where the child may pose a risk to themselves or others. When Study Mind receives child protection files, the DSL ensures key staff are informed of relevant details as necessary.

7. Specific Safeguarding Issues

All Study Mind staff should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to drug taking, alcohol misuse, deliberately missing education, radicalisation, the consensual and non-consensual sharing of nudes and semi-nudes, and serious violence can all be signs that children are at risk. Annexes A and B of KCSIE 2026 contain important additional information about specific forms of abuse; Study Mind requires all staff and tutors to read Part One of KCSIE 2026 in conjunction with this policy.

7.1 Child-on-child abuse

All children have a right to learn in a safe environment, free from harm from adults and from other children. Child-on-child abuse can happen inside and outside of any setting and online. Even where there are no reports, this does not mean it is not happening; it may simply be unreported. Any concern at all should be raised with the DSL. Where Study Mind works within a school or college, staff must be clear on that setting’s child-on-child abuse procedures and their role in preventing and responding to it.

Child-on-child abuse includes, but is not limited to:

• Bullying (including cyberbullying and prejudice-based bullying) and 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;
• Pressuring another person to send, or sharing, nudes and semi-nudes (youth-produced sexual imagery), including imagery generated or manipulated using AI;
• Upskirting – taking a picture under a person’s clothing without their knowledge, to obtain sexual gratification or cause humiliation, distress or alarm. Upskirting is a criminal offence and anyone of any gender can be a victim;
• Teenage relationship abuse – a pattern of actual or threatened acts of physical, sexual or emotional abuse against a current or former partner;
• Initiation and hazing-type violence or rituals; and
• Prejudiced behaviour – behaviours which cause someone to feel powerless, worthless or excluded, linked to prejudices around disability, SEN, ethnicity, culture, religion, gender or sexual identity.

Bullying can cause children considerable anxiety and distress and, at its most serious, has been a feature in the suicide of some young people. All incidences of bullying, including cyberbullying and prejudice-based bullying, must be reported to the DSL (where sessions take place within a school, concerns should be raised with that school’s DSL before leaving the premises). Downplaying harmful behaviour – dismissing sexual harassment as ‘just banter’, ‘just having a laugh’ or ‘boys being boys’ – is prohibited: it creates a culture that normalises abuse. Addressing inappropriate behaviour, even where it appears relatively harmless, is an important intervention that helps prevent problematic, abusive or violent behaviour in future.

Procedures against child-on-child abuse

• All allegations are taken seriously, investigated promptly and managed under our safeguarding procedures, with a zero-tolerance approach.
• Any student found to have been involved in abuse is dealt with in accordance with our behaviour expectations, with appropriate sanctions and support for the victim. Children who cause harm still receive a safeguarding response, in line with Working Together 2026: we work with them to understand their experiences and reduce the likelihood of further harm.
• We work closely with parents, guardians, commissioning schools and external agencies to support both the victim and the child who has caused harm, recognising both may need intervention; where appropriate, individual safety plans are put in place for each.
• Staff receive training to recognise the signs of child-on-child abuse, including harmful sexual behaviour, cyberbullying and upskirting; early intervention is critical.
• All communications between students on Study Mind platforms are monitored, and any bullying or inappropriate behaviour is reported to the DSL.

7.2 Child criminal exploitation (CCE)

CCE occurs where an individual or group uses an imbalance of power to coerce, manipulate or deceive a child into criminal activity, sometimes in exchange for something the victim wants, or for the gain of the perpetrator, and can affect vulnerable adults over 18. Forms of CCE include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, pickpocketing, vehicle crime or threatening or committing serious violence. Children can become trapped, as perpetrators may threaten victims and their families with violence or entrap them in debt, and children may carry weapons for a sense of protection. Because exploited children often commit offences themselves, their victimhood is not always recognised by adults and professionals; they may still have been criminally exploited even if the activity appears consensual. Exploitation of this kind is also a form of modern slavery, and the DSL will consider a referral to the National Referral Mechanism where appropriate.

The experience of girls who are criminally exploited can be very different to that of boys, and indicators may differ; both boys and girls at risk of CCE are also at higher risk of sexual exploitation. Key indicators include:

• Withdrawal from family, or being emotionally ‘switched off’ while containing frustration or rage;
• Sudden loss of interest in education, decline in attendance or achievement (though some children maintain attendance to avoid notice);
• New or unknown slang, a new nickname, or adopting group codes of behaviour such as hand signs;
• Unexplained money, possessions or gifts, or new tattoos with gang-style symbols;
• Staying out unusually late, breaking parental rules consistently, or going missing;
• A sudden change in appearance or dressing in a particular style or ‘uniform’;
• Unexplained injuries and/or refusal to seek medical treatment;
• Graffiti-style tags on possessions or books;
• Constantly talking about another person who has significant influence over them, breaking off old friendships, or associating with known or suspected gang members;
• Being found by police far from home, fear of entering certain areas, or concern about unknown youths in their neighbourhood;
• Expressing aggressive or intimidating views towards other groups of young people.

Any suspicion of CCE must be reported to the DSL immediately.

7.3 Child sexual exploitation (CSE)

CSE is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by penetration or non-penetrative acts, and 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 sexually inappropriate behaviour, or grooming in preparation for abuse, including online. CSE can occur over time or be a one-off occurrence, and may happen without the child’s immediate knowledge, for example through the sharing of videos or images on social media. CSE can affect any child, including 16- and 17-year-olds who can legally consent to sex, and some children may not realise they are being exploited – for example, believing they are in a genuine romantic relationship. Working Together 2026 also strengthens the response to group-based child sexual exploitation, and the DSL will share information with local partners where organised or group-based exploitation is suspected.

CSE is often a hidden harm, and explicit evidence may not be apparent. Children may not disclose out of fear, shame or guilt, because they do not recognise their own exploitation, or because they fear they will not be believed. When professionals are reliable, consistent, curious and confident in asking what is happening, young people are more likely to disclose – hence the need for Study Mind tutors to remain professional and open to the possibility that any child could be affected. Factors that can increase vulnerability to CSE include: family breakdown; domestic or sexual abuse or neglect; bullying; family or peer involvement in CSE; parents at risk themselves; living in residential care; learning disabilities or difficulties; poverty; forced marriage; social exclusion or isolation; and being an asylum-seeking or refugee child. Any concern related to CSE must be reported immediately to the DSL.

7.4 Sexual violence, sexual harassment and upskirting

Study Mind has a zero-tolerance approach to all forms of sexual violence and sexual harassment, in line with KCSIE 2026 (which now incorporates the DfE’s advice on sexual violence and sexual harassment between children). Sexual harassment is any unwanted behaviour of a sexual nature that violates a person’s dignity, makes them feel intimidated, degraded or humiliated, or creates a hostile environment. Examples include unwelcome sexual advances or requests; sexually suggestive comments, jokes or gestures; unwanted physical contact; displaying or sharing sexually explicit images or content (including AI-generated content); and staring or leering in a sexual manner. Upskirting is a criminal offence under the Voyeurism (Offences) Act 2019.

Any suspected or reported incident must be reported immediately to the DSL (or the on-site staff member at events), and reports are handled with sensitivity, prioritising the victim’s privacy and wellbeing. A prompt and thorough investigation will follow, with action taken in line with our disciplinary policies, and the matter will be reported to the police where legal obligations require. At in-person events, Study Mind enforces clear guidelines on mobile phone use and may, in accordance with consent agreements, check devices to ensure inappropriate images have not been taken or shared. Where Study Mind is not the host of an in-person event (for example a school talk), the host setting’s policy applies.

7.5 Violence against women and girls (VAWG)

While anyone can be a victim of sexual violence and harassment, women and girls are disproportionately affected by specific types of harm. In line with KCSIE 2026, staff must be alert to behaviours rooted in inequality and discrimination against women and girls, including online misogyny; Study Mind maintains a zero-tolerance approach to any behaviour that normalises or trivialises violence against girls, and recognises that girls with SEND or from minority backgrounds may face increased vulnerability. Identified forms of VAWG in our context include sexual harassment and violence (including upskirting); FGM; teenage relationship abuse; grooming and exploitation (CSE and the specific ways girls are targeted in CCE); and exposure to content promoting misogyny or the objectification of women.

Virginity testing and hymenoplasty: under the Health and Care Act 2022, both virginity testing (any examination of female genitalia intended to establish whether vaginal intercourse has occurred, which has no scientific or clinical merit) and hymenoplasty (surgical reconstruction of the hymen) are illegal in the UK, and it is a criminal offence for UK nationals or residents to carry out or facilitate these practices abroad. These practices are forms of VAWG, often linked to so-called honour-based abuse, coercive control and forced marriage. Any concern must be treated as a high-level safeguarding concern and reported immediately to the DSL, who will contact the MASH and/or police.

7.6 Domestic abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. It can be psychological, physical, sexual, financial or emotional. The statutory definition covers any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members, regardless of gender or sexuality, including physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, and psychological or emotional abuse. Controlling behaviour is designed to make a person subordinate or dependent; coercive behaviour is an act or pattern of acts of assault, threats, humiliation and intimidation used to harm, punish or frighten a victim.

Under the Domestic Abuse Act 2021, 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 a victim of domestic abuse in their own right. Children may also suffer domestic abuse within their own intimate relationships (teenage relationship abuse). All of this can have a detrimental and long-term impact on health, wellbeing, development and learning. Under Working Together 2026, the police are under a new duty to notify education settings where they have reasonable grounds to believe a child may be a victim of domestic abuse (building on Operation Encompass); where Study Mind receives such information from a commissioning school or local authority, the DSL will ensure lessons are delivered with appropriate care and information is handled sensitively. Any suspicion of domestic abuse must be reported immediately to the DSL.

7.7 Female genital mutilation (FGM)

FGM comprises all procedures involving partial or total removal of the external female genitalia, or other injury to the female genital organs, for non-medical reasons. It is recognised internationally as a violation of the human rights of girls and women, is nearly always carried out on minors, and is child abuse. Girls of school age subjected to FGM overseas are often taken abroad at the start of the school holidays, particularly in the summer, allowing time to recover before returning to school. Given the hidden nature of FGM, discussions should always be undertaken with care and sensitivity.

The most significant risk factor is a family history of practising FGM, alongside whether FGM is known to be practised in the girl’s community or country of origin. Additional potential risk factors include: the child’s mother or other female family members having undergone FGM; the father coming from a community known to practise FGM; an influential female family elder involved in the girl’s care; the family’s level of integration within UK society; parents stating they will take the child out of the country for a prolonged period, or the child talking about a long holiday to a country where the practice is prevalent; the family not engaging with professionals; the child confiding that she is to have a ‘special procedure’ or attend a special occasion; staff hearing reference to FGM in conversation; withdrawal from PSHE-type learning; or any other safeguarding alert associated with the family.

Mandatory reporting duty: if a Study Mind tutor or member of staff discovers that an act of FGM appears to have been carried out on a girl under 18, they must personally report this to the police, and inform the DSL.

7.8 Serious violence and weapons

All staff should be aware of the indicators that children may be at risk from, or involved with, serious violent crime. These include increased absence from education, 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, signs of assault or unexplained injuries, and unexplained gifts or new possessions (which may indicate approaches by individuals associated with criminal networks or gangs and risk of criminal exploitation). In line with KCSIE 2026, staff must report any concern about a child using or carrying a weapon, or expressing an intention to do so, to the DSL (or a deputy), who will assess the risk and take appropriate action, including police contact where necessary.

7.9 Mental health

All staff 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. Study Mind staff are not trained mental health professionals and must not attempt to make a diagnosis; however, staff are well placed to observe children day-to-day and identify possible early signs, including changes in behaviour, mood, attendance or engagement, anxiety, low mood, self-harm, disordered eating or suicidal ideation. Relevant members of the safeguarding team receive basic training in self-harm awareness to help them spot and support students and tutors.

If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken by speaking to the DSL or a deputy. In line with KCSIE 2026, if staff believe a child is in danger – for example at immediate risk of suicide or serious self-harm – they must call 999 or ensure the child is taken to A&E immediately (or call 111 where it is urgent but not an emergency), informing the DSL as soon as possible. Study Mind provides a safe and supportive environment where students feel able to disclose mental health concerns; disclosures are treated sensitively and escalated to the DSL where there are welfare or safety concerns. We actively support students by engaging with parents, guardians and schools and, where appropriate, signposting to external mental health services, school counsellors and national helplines, ensuring a coordinated response.

Mental capacity

It is generally assumed that adults are capable of making informed choices about their own lives. If an individual is determined to lack the mental capacity to make decisions about their safety, decisions will be made in their best interests, following the Mental Capacity Act 2005 and its Code of Practice. This applies to individuals aged 16 and over, so is relevant to some Study Mind students. The MCA defines a person as lacking capacity where, because of an illness or disability such as a mental health problem, dementia or a learning disability, they cannot understand information given to them about a particular decision, retain that information long enough to decide, weigh up the information available, or communicate their decision.

Where an individual with capacity chooses to remain in an abusive environment, it is important to evaluate whether their decision is made free from intimidation or coercion, with a clear understanding of the risks and access to services should they later seek help. If there is concern that their decision has been compromised, their best interests must be considered, potentially overriding their consent in order to take protective action. Consent may also be overridden where 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 given information, advice and support in a way they can understand, and their views taken into account in all decisions. Study Mind will involve an advocate where a person lacks capacity to make decisions about a safeguarding concern, and support will be sought from the safeguarding team wherever there are concerns about capacity.

7.10 Radicalisation, Prevent and Channel

Radicalisation is the process by which individuals come to support terrorism and extremist ideologies. It often targets vulnerable individuals, including children, through social media, peer influence or direct contact with radical groups. The Prevent strategy is part of the government’s counter-terrorism strategy (CONTEST) and aims to stop individuals becoming involved in terrorism through early intervention and safeguarding. Study Mind recognises its responsibilities under the Prevent duty, trains all staff annually in recognising radicalisation, and maintains a separate Prevent and Anti-Radicalisation Policy (including a risk assessment) that should be read alongside this document.

If anyone has a concern that an individual is susceptible to radicalisation, they must refer to the DSL immediately. The DSL will refer children considered at risk to the local authority (via the MASH or equivalent front door), which shares details with the Prevent lead police officer and the local Prevent coordinator; where concerns are substantiated, the case may be referred to Channel, the voluntary, confidential multi-agency support programme providing early intervention for individuals vulnerable to being drawn into terrorism. Referrals may also be made using the national Prevent referral form, available on GOV.UK (‘Get help if you’re worried about someone being radicalised’).

8. Online Safety and Communication

8.1 Monitored communication and recording

All Study Mind online communication is monitored and tracked for safety. These procedures are made clear in tutor induction documents, the Code of Conduct and this policy; the standalone Online Safety Policy provides more depth. All lessons are recorded and stored on Microsoft SharePoint for safety and monitoring purposes. Tutors are guided through the Code of Conduct and the Bring Your Own Device (BYOD) Policy not to download recordings to personal devices; sharing settings are disabled, and students can access recordings only with Study Mind’s permission.

All online interaction between students is strictly limited. Contact details are never shared by Study Mind, nor visible during group classes or events. During group sessions, students may communicate only via the shared chat box (on Microsoft Teams), which is monitored at all times by the tutor (for smaller classes) or by a member of the safeguarding team (for large-scale webinars and one-off events, where comments are limited to hosts only).

8.2 The four areas of online risk

As outlined in KCSIE 2026, online safety risks are categorised into four areas:

• Content: being exposed to illegal, inappropriate or harmful content, for example pornography, fake news, racism, misogyny, self-harm, suicide, antisemitism, radicalisation and extremism, including harmful content generated by artificial intelligence.
• Contact: being subjected to harmful online interaction with other users, for example peer pressure, commercial advertising, and adults posing as children with the intention to groom or exploit them for sexual, criminal, financial or other purposes. This now includes harmful interactions with generative AI applications that simulate human interaction, such as AI chatbots and companion-style systems.
• Conduct: personal online behaviour that increases the likelihood of, or causes, harm, for example making, sending and receiving explicit images (including the consensual and non-consensual sharing of nudes and semi-nudes, and images created or manipulated using AI) and online bullying.
• Commerce: risks such as online gambling, inappropriate advertising, phishing and financial scams. Any concern should be reported to the DSL, who will advise on onward reporting (for example to Action Fraud).

Study Mind ensures online safety is an embedded element of all procedures, policies and services. In line with KCSIE 2026, the Online Safety Lead ensures that the effectiveness of our filtering and monitoring arrangements is reviewed at least once every academic year, with checks documented (when they were conducted, what was tested, issues identified and actions taken). Where Study Mind uses generative AI tools in its services, it does so with regard to the DfE’s guidance on generative AI in education and its product safety expectations. Tutors receive online safety training as part of induction, through the annual Safer Study Mind training each November, and via tutor training sessions throughout the year, and are encouraged to talk to parents and carers about children’s online activity away from lessons.

8.3 Social media

Social media is defined as all methods of direct online communication, including (but not limited to) Facebook, X (Twitter), WhatsApp, Instagram, TikTok and YouTube. All social media published by Study Mind must be approved by the management team and must not: include anything amounting to bullying or discrimination (as defined in the Inclusion, Equality and Diversity Policy); include identifying information about Study Mind staff or students; include any images without permission; include anything amounting to abuse of any kind; divulge Study Mind intellectual property or non-public policies, or disparage others; or misrepresent Study Mind, its services or its staff.

Staff and students must not, under any circumstances, either during or after a booking, communicate with or add each other on private or personal social media. Discovery of this will lead to immediate termination of contracts on both sides. Where staff and students knew each other personally before joining Study Mind, all communication must still abide by this policy.

8.4 Photography and images

Study Mind recognises that it is vital to protect images of children from misuse. Any images or recordings used for promotional purposes must be approved by students and guardians and must not include identifying information about anyone involved. Clear procedures ensure that all involved understand what is considered appropriate. Staff must never take photographs of a child’s injuries (see Appendix B).

9. Children Absent or Missing from Education

Study Mind recognises that missing education – and persistent absence from it – can be a critical indicator that a child may be at risk of harm, neglect or exploitation. We take unexplained absences seriously and follow up every student’s non-attendance.

9.1 Absence from tuition sessions (online)

The detailed, step-by-step procedure for responding to an unexplained absence – including the exact timings – is set out in the Attendance Policy (Section 9), which is the single source of truth for this process and is followed for every session, online or face-to-face. In summary: 

1. Study Mind tutors and admin immediately message the student to check why the lesson was missed, within 5 minutes of the session start. The student is marked absent on the management system, triggering an email to the DSL, who ensures the absence is reported to the commissioning school or local authority in line with the placement’s reporting requirements.
2. If there is no response within 15 minutes of the session start, the absence is logged and automatically flagged to the DSL, who attempts to contact the assigned guardian by telephone. All information is logged on the management system and fed back to the safeguarding and senior management teams.
3. If this leads to any disclosure from the student, their guardian or Study Mind staff, a Report Form is completed and the matter is followed up as a disclosure of abuse. The DSL may need to contact local authorities, schools or the police as required.
4. If the absence is a ‘regular’ absence (the session was forgotten, or the student was legitimately busy), the monitoring team escalates that group to ensure it does not become a repeated pattern. Repeated missed lessons, even with seemingly innocent explanations, are followed up by senior management and may lead to a safeguarding referral, in line with the Attendance Policy’s ‘Eyes On’ protocol. It is better to react to small signs than to wait for ‘big’ danger.

9.2 In-person events

Attendance registers: for in-person events such as mocks, work experience and group events, all bookings require the student’s personal information and confirmation from an adult that they are permitted to attend. Every student must have a stated emergency contact for the day; where a student cannot provide one, the local authority may be listed to ensure the student is safe and accounted for. On-site staff hold a full register and mark students as attending on entry.

Missing students: where a student is not in attendance, staff first contact the student directly. If there is no response, the emergency contact is contacted. If there is still no response, Study Mind contacts the relevant local authority to request a welfare check, continues attempting to contact the guardian and student twice more over a 48-hour period, and continues to liaise with the local authority. When students take part in a Study Mind event organised by a school on school grounds during the school day, the school takes responsibility for attendance.

9.3 Missing child protocol and children missing education (CME)

Children missing from education are those of compulsory school age who are not registered at a school and not receiving suitable education otherwise. If a child is identified as missing – their whereabouts unknown and the absence out of character – the following steps are taken: immediate attempts to contact the student and their guardian within 15 minutes of the missed lesson, in line with Section 9.1 and the Attendance Policy; escalation to the DSL if no response is received, who will notify local safeguarding authorities; immediate police contact for a welfare check where there are serious concerns for the child’s safety; onward reporting to the relevant local authority for any child missing education for more than five days; and full cooperation with law enforcement and other agencies to ensure the child’s safe return. Study Mind will also support local authorities in the operation of their children-not-in-school registers under the Children’s Wellbeing and Schools Act 2026, providing information about provision delivered where required.

10. Allegations Against Study Mind Tutors and Staff

Study Mind recognises its duty to act on concerns or allegations against its directors, staff or tutors. All must comply with the Code of Conduct to promote safer working practices. This guidance is followed when any Study Mind representative has:

• behaved in a way that has harmed a child, or may have harmed a child;
• possibly committed a criminal offence against or related to a child;
• behaved towards a child or children in a way that indicates they may pose a risk of harm to children; or
• behaved, or may have behaved, in a way that indicates they may not be suitable to work with children – including behaviour inside and outside of their responsibilities at Study Mind.

Allegations can be made by a child or an adult and should be made immediately to the DSL. Allegations against the DSL should instead be made to another member of the leadership team, who will inform the other team members and appoint a suitable senior member of staff to act in the DSL’s place for that allegation.

If an allegation meets the harm threshold, the DSL will contact the relevant Local Authority Designated Officer (LADO) within one working day (or sooner where local protocols require) – KCSIE’s own wording, used consistently across this policy and the Managing Allegations About Staff Policy – and will not investigate ahead of LADO advice. Study Mind will consider immediate suspension (without prejudice) pending investigation where there is cause to suspect that a child or children are at risk of harm from continued contact, and suspension will be considered even where the allegation is not linked to the individual’s role at Study Mind. If advised by the LADO, Study Mind will refer to the DBS and, where relevant, to the Teaching Regulation Agency and professional regulators (including the General Medical Council or General Dental Council where applicable).

All allegations, whether substantiated or not, are followed by a full internal review of the culture and circumstances that led to them, so that lessons are learned and policies improved – including lessons about suspension and reinstatement. Staff found not to be following this policy are subject to disciplinary measures, and there may be penalties for staff found to have withheld information vital to an investigation.

10.1 Duty to refer to the DBS

Under its legal duties, Study Mind will report concerns about unsafe practice by any director, staff member or tutor to the Disclosure and Barring Service where the individual has engaged in conduct that has harmed (or is likely to harm) a child, or otherwise poses a risk of harm to a child. If Study Mind dismisses or removes an individual due to relevant conduct, risk of harm, or a caution or conviction for a relevant offence – or the person resigns or leaves in circumstances where they would otherwise have been removed – a referral to the DBS will be made by the DSL.

11. Safer Recruitment, DBS and Suitability

Study Mind is committed to safeguarding and promoting the welfare of children and expects all staff and volunteers to share this commitment. We adhere to the statutory guidance set out in KCSIE 2026 (Part Three) and Working Together to Safeguard Children 2026. All senior management and staff involved in recruitment undergo safer recruitment training to identify and deter individuals who may be unsuitable to work with children. Our safer recruitment measures include (but are not limited to):

• Identity and suitability checks: all employees and tutors undergo rigorous identity verification and suitability checks prior to any appointment being confirmed.
• Enhanced DBS checks: a minimum of an Enhanced DBS check with children’s barred list information is mandatory for all staff in regulated activity.
• Single Central Record (SCR): Study Mind maintains a single central record of pre-appointment checks for all staff, including tutors and agency workers.
• Structured video interviews: for all shortlisted candidates, to assess their motives and suitability for working with young people.
• Robust referencing: at least two written references, including a specific statement on the applicant’s suitability to work with children. For tutors with limited professional experience, we require a documented history of working with young people in a supervised setting.
• Online searches: in line with KCSIE 2026, Study Mind carries out online searches (including social media) on shortlisted candidates as part of pre-recruitment due diligence, to identify publicly available information which might suggest the candidate is unsuitable to work with children. Candidates are informed that these checks take place, and any findings are discussed at interview where relevant.
• Mandatory safeguarding training: all staff, tutors, contractors and volunteers undergo safeguarding and child protection training (including online safety and Prevent) at induction, refreshed annually through a formal mandatory update, so staff remain clear on referral pathways, local thresholds and emerging risks. Regular safeguarding updates are provided at least termly via email, briefings or bulletins. Completion is centrally tracked, and staff are not permitted to engage with learners until their certification is current.
• Whistleblowing and accountability: we maintain anonymised and secure channels for whistleblowing, ensuring staff feel empowered to raise concerns about any adult’s conduct in line with our low-level concerns approach (see Section 13).

11.1 DBS requirements for tutors

All tutors must hold an active, current Enhanced DBS which must be kept up to date and attached to their tutor profile in order to be active on the system. Tutors are responsible for registering with the DBS Update Service, and are strongly recommended to do so to avoid issues with expiry. Study Mind reserves the right to check profiles before assigning tutors to students, or at random; any tutor found with a DBS nearing expiry is suspended temporarily to allow time to renew, and anyone with an expired DBS is immediately removed from working at Study Mind. Overseas police checks are considered in line with KCSIE 2026 where applicants have lived or worked abroad.

Any tutor reported for a serious breach of this policy will be suspended from tutoring with immediate effect. For a minor breach, the final decision rests with Study Mind, and the tutor may be reinstated after an initial suspension period while the incident is investigated. Any tutor reported for illegal activity while using Study Mind services will be reported to the police and appropriate authorities, including professional regulators where relevant. Tutoring Study Mind students independently outside contracted hours, or sharing materials without notifying Study Mind, is also a breach of this policy.

12. Alternative Provision Placements and Face-to-Face Tuition

12.1 Our commitments as a non-school alternative provision provider

Study Mind delivers tuition commissioned by local authorities and schools as non-school (unregistered) alternative provision. We understand contextual safeguarding and recognise that children can be at risk of harm outside the home environment; our practice puts measures in place to identify and minimise these risks. In line with the DfE’s statutory guidance on alternative provision, Arranging Alternative Provision: A Guide for Local Authorities and Schools (2025), and the national standards for non-school alternative provision (2025), Study Mind commits to:

• Providing commissioners, before and during a placement, with written confirmation of the safeguarding checks held for all staff working with their pupils, including Enhanced DBS certificates and entries on our single central record;
• Maintaining the required policies – this child protection and safeguarding policy, behaviour expectations and a staff code of conduct – and making them available to commissioners on request;
• Ensuring the commissioner always knows where the child is during provision hours, including the actual address of any venue used;
• Reporting attendance daily (or as contractually agreed) and notifying the commissioner of any absence on the same day, recognising that absence from provision can itself be a safeguarding indicator;
• Notifying the home school DSL and/or local authority commissioning team of any safeguarding concern within the same working day (see Section 6.2);
• Supporting placement reviews, quality assurance visits and local authority quality assurance frameworks, and working towards reintegration or positive post-16 destinations for every learner; and
• Carrying out detailed risk assessments before tuition begins, incorporating any safeguarding risks specific to the learner, venue or arrangement.

Reporting to commissioners: in accordance with local protocols and commissioning requirements, the DSL ensures immediate information sharing with the local authority commissioning team and the MASH where a child is at risk of harm or where an incident involves commissioned services. This rapid notification ensures a coordinated multi-agency response, allows immediate review of the provision, and upholds our duty to work transparently with local partners.

12.2 Face-to-face tuition

Tutors delivering face-to-face tuition are given further guidance which covers the following points:

• Tutors should carry proof of their Enhanced DBS check and photo ID (such as a driving licence or passport) on their initial visit to a new student. When working in schools or other settings, tutors may be asked to provide a copy of their Enhanced DBS and photo ID for entry into the setting’s single central record, removed after the assignment concludes.
• Tutors are not responsible for the physical welfare of the child; for example, a tutor must not restrain a learner in crisis unless they have undergone the appropriate training.
• Tutors must verify the presence of another adult – a teacher, caregiver, parent or other adult responsible for the child – before entering the tuition venue. If no such adult is present, the tutor must not enter, should explain this to the student, and must promptly contact the DSL.
• All communication must be through a parent or carer or the alternative provision lead. Tutors are not permitted to communicate directly with learners outside of tuition.
• Tutors must not touch a student – for example placing a hand on their shoulder or tapping their back, even to say ‘well done’ – as such actions can be misinterpreted and give rise to allegations. All positive feedback is given verbally or in writing.
• Tutors are expected to dress appropriately for tuition sessions, considering the setting and respecting the religious and cultural backgrounds of those they may meet.
• If tutoring in a community setting and the learner becomes unwell, tutors must contact the parent or carer immediately, who will advise on arrangements for the learner to return home; the tutor then informs Study Mind.
• As part of tuition, tutors present opportunities to support learners in identifying safe and unsafe behaviours in a variety of situations (including online safety), so they feel safe and can keep themselves and others safe.

Suitable environment for tuition

Sessions must be conducted 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 report it immediately to their Tuition Coordinator; if there is a potential risk of harm to the child or the tutor, they must inform the DSL straight away. Tuition must not take place in the home unless a responsible adult is present – 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 tuition area should be set up as a professional workspace with a table, chair, adequate lighting and necessary equipment; distractions such as mobile phones and TVs should be turned off, and there should be no pets or smoking in the area.

13. Whistleblowing

Study Mind is committed to protecting any member of staff, client or member of the public who discloses a purposeful breach of this policy from ramifications, and to creating an open, honest environment in which no one is afraid to raise issues. All concerns, big or small, will be addressed to ensure a fair and safe environment. Concerns can also be raised externally with the NSPCC Whistleblowing Advice Line on 0800 028 0285 or help@nspcc.org.uk. Please see the standalone Whistleblowing Policy for further information.

14. Anti-Bribery, Gifts and Hospitality

Bribery is the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something dishonest, illegal or a breach of trust, and is a criminal offence. Study Mind operates a zero-tolerance policy on any form of bribery from staff, students or organisations. It is prohibited, directly or indirectly, to offer, give, request or accept any bribe – in cash or any other form of inducement – to gain commercial, contractual or regulatory advantage for the company, or personal advantage for an individual, in a way that is unethical. This includes conduct intended to influence a foreign public official. Individuals found guilty of bribery can face up to 10 years in prison and/or an unlimited fine, and Study Mind could also face prosecution.

While proportionate, properly recorded gifts and hospitality can form part of positive relationships, Study Mind has opted to err on the side of caution as a provider of high-stakes educational services. No employee is permitted to accept gifts from any client or organisation that is purchasing, or has purchased, a service from Study Mind. Clients wishing to show appreciation may approach Study Mind as an organisation; we recommend donations towards our charitable work or positive online reviews. Employees may accept tokens of thanks from Study Mind itself, which fall outside this policy.

If you are offered a bribe, or a bribe is solicited from you, do not agree to it unless your immediate safety is in jeopardy, and immediately report the matter to the DSL or a member of senior management. If you suspect that an act of bribery, or attempted bribery, has taken place – even if you are not personally involved – you are expected to report it to senior management; you may be asked to give a written account of events. Appropriate checks are made before engaging suppliers or third parties, and all transactions, including sponsorship or charitable donations, are made transparently and legitimately. Incidents of bribery or corruption are taken very seriously and may lead to termination.

15. Governance, Quality Assurance and Review

Safeguarding is the responsibility of everyone at Study Mind; the senior management team is responsible for ensuring procedures are followed, clear, and that records are kept up to date. The DSL and Managing Director report regularly on safeguarding activities and systems to the board of directors. These reports do not include identifiable information about individual learners or families.

Study Mind is committed to learning lessons, alongside support and guidance from the LADO, to determine whether improvements can be made to our procedures or to help prevent similar events in future. A review of all safeguarding incidents is conducted regularly by the safeguarding team; after every safeguarding incident, a formal debrief takes place with relevant staff to assess the effectiveness of the response and whether further training or policy change is required. We work in partnership with local safeguarding authorities and external experts to align our practice with national standards.

This policy is reviewed at least annually (next full review: September 2027), with a mini-review every six months coinciding with operational staff training reviews, and further updates whenever national or local policy changes, significant child protection issues arise, or our own procedures alter. All members of the team, including tutors and temporary staff, receive a copy of this policy together with the KCSIE 2026 updates, and the policy is accessible on the Study Mind website. Parents and carers are provided with a summary and informed that the complete policy is available on our website or on request.

Appendix A: Safeguarding Reporting Form

To be completed immediately, and as fully as possible, if you have concerns regarding a child, and passed to the Designated Safeguarding Lead (DSL), Sara Gelsthorpe. The DSL will review the information, plan a course of action and, if necessary, contact the relevant organisations. This form is completed by the staff member reporting the concern and returned to safeguarding@studymind.co.uk. It is sent directly to the DSL and safeguarding team and is not shared with other staff unless key to the resolution of the situation.

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

Section 1: Details of the child

A child is anyone who has not yet reached their 18th birthday.

Name of child
Date of birth (approx. age if unknown)
Gender
Home school / commissioning organisation

Section 2: Details of the incident or concern

Details of the incident or concern (facts, dates, times, the child’s own words)
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, the risks that remain and action you are taking

Please indicate the abuse type if known (leave blank if uncertain):

Domestic abuse	☐	Sexual abuse	☐	Child trafficking / modern slavery	☐
Neglect	☐	Online abuse	☐	Harmful sexual behaviour	☐
Physical abuse	☐	Emotional abuse	☐	Bullying / cyberbullying	☐
Child sexual exploitation	☐	Female genital mutilation	☐	Child criminal exploitation	☐
Radicalisation / extremism	☐	Mental health / self-harm	☐	Other (specify below)	☐

Section 3: Details of alleged abuser/suspect (if applicable)

Name and title
Address and postcode
Phone
Relationship to the child
If a provider, the provider’s name
Does the abuser/suspect live with the child?

Section 4: Details of the person reporting this incident/concern

Name and title
Job role and team
Email and phone
Date/time referral completed
Relationship to child (if applicable)
Are you reporting your own concerns or responding to concerns raised by someone else? If someone else, give their details (name, organisation, relationship to child, 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

Section 6: Office use only – sharing the concerns (to be completed by the DSL)

Details of contact with social services where the child lives
Details of contact with the child’s school or any other agencies
Details of the outcome of this concern

Appendix B: Recording Physical Injuries (Body Map)

A body map should be used to document and illustrate visible signs of harm or physical injuries. Rules for recording:

• NEVER take photographs of a child’s injuries.
• Use a black pen to mark the exact site of the injury on the diagram.
• Include the exact site, size (in cm), shape, colour, and whether the skin is broken.
• Record the child’s own words describing how the injury occurred.
• Key indicators for non-accidental injury (NAI): areas of concern include the cheeks, ears, neck, shoulders, chest, stomach, inner arms and genitals.

The body/skin map template is held in the central policies folder and is available from the DSL.

Appendix C: Key Contacts

Study Mind safeguarding team

Designated Safeguarding Lead: Sara Gelsthorpe	sara@studymind.co.uk • +44 (0)7817 032628 (9am–5pm Mon–Fri)
Deputy Designated Safeguarding Lead: Claire Winward	ap@studymind.co.uk • +44 (0)20 7189 2799 (9am–5pm Mon–Fri)
Deputy Designated Safeguarding Lead (out of hours): Dr Mohil Shah	business@medicmind.co.uk • +44 (0)7443 022232
Safeguarding reports	safeguarding@studymind.co.uk • Central office +44 (0)20 3305 9593

National contacts

Police (in an emergency)	999
NSPCC	0808 800 5000
NSPCC Whistleblowing Advice Line	0800 028 0285 • help@nspcc.org.uk
National Prevent referral	GOV.UK: ‘Get help if you’re worried about someone being radicalised’ – national referral form

Local authority directory

The DSL must consult this directory to ensure the correct local thresholds and contact methods are used for the learner’s home authority. This directory is reviewed termly and expanded as new contracts commence.

Local authority	Contacts and referral pathway
Hillingdon	MASH: 01895 556644 • lbhmash@hillingdon.gov.uk • LADO: lado@hillingdon.gov.uk • 01895 250975
Suffolk	LADO: LADO@suffolk.gov.uk • 0300 123 2044
Somerset	MASH (children): 0300 123 2224 (Mon–Fri 8am–6pm) • scc@somerset.gov.uk (FAO: MASH Safeguarding) • Out of hours: 0300 123 2327 • Adult safeguarding: 0300 123 2224 • LADO: 0300 123 2224 (ask for the LADO Duty Officer)
Worcestershire	Front Door: 01905 822666 • Out of hours EDT: 01905 768020 • LADO: LADO@worcschildrenfirst.org.uk • 01905 822666 • Refer to the Worcestershire and Herefordshire Joint Levels of Need guidance • safeguardingworcestershire.org.uk/report-it
Brighton & Hove	LADO: ladoenquiries@brighton-hove.gov.uk • 01273 290400
Hampshire	CRT/MASH professional line (immediate concerns): 01329 225379 (Mon–Thu 8:30–17:00, Fri 8:30–16:30) • Public line: 0300 555 1384 • Out of hours EDT: 0300 555 1373 • Professional referrals via the online Inter-Agency Referral Form (IARF) on the Hampshire SCP website
East Sussex (Pan-Sussex SPoA)	01323 464222 • Referral via the East Sussex online portal

For any authority not listed, the DSL will identify the relevant front door service (MASH, SPOA, multi-agency child protection team or equivalent) via the local authority’s website and record the details here at the next review.