1. Introduction- Who it is by and who it is for
1a. 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’.
1b. 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 vital.
1c. 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.
1d. As well as students, this applies to all Study Mind tutors and staff. 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.
1e. Study Mind recognises that there may be differences in safeguarding requirements between children with and without special educational needs and circumstances. These differences are addressed below.
1f. The Designated Safeguarding Lead is Daniela Prataviera, Senior Manager.
The requirements for this position are:
– Level 3 Safeguarding
– Self Harm Training
– Domestic Abuse Training
– Child Sexual Exploitation Training
Prevent and Anti-Radicalisation Training
Safer Recruitment 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
– DBS checks – Level 2 Safeguarding Training
– 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
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
- 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)
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.
- 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 2023.
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.
3a. Safeguarding and promoting the welfare of children is defined for the purposes of
this guidance as:
• protecting children from maltreatment
• 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. (KSCIE, 2023)
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, verbally or non-verbally conveying that they are unloved or worthless, but also witnessing the ill- treatment of somebody else and 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 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, 2023).
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, 2023).
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 or young person needs special educational provision they’re 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.
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 children.
4b. Study Mind management are responsible for:
4b.1- 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 and young people, 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 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.
4b.2- 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.
4b.3- 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.
4b.4- 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 safe.
- Contribute any local, contextual information that may support children’s 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 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, 2023).
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.
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 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
- 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 instructions.
- 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.
Student: when a student does not attend a pre-arranged or expected tutoring session, the procedure is as follows:
1. Study Mind admin will send out a message to the student themselves, to check why the lesson was missed. All information must be fed back to the safeguarding and senior management team.
2. If this is not responded to, then Study Mind will reach out to the assigned guardian on the account 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.
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 young people 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 share 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 2023, 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 or young adults 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
6a. Tutors and staff will follow the necessary child protection procedures if an incident occurs. They will be made aware that:
- Where a child is in immediate danger or at risk of harm, 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) 20 3305 9593 to report the incident. Study Mind staff will then be able to contact relevant authorities and, if needed, 999 in order to disclose the situation with access to the students’ personal information.
- Anyone can make a referral.
- Tutors should make a comprehensive written record of the incident immediately after the session including date, time, initials of the student and detailed notes regarding the event that was witnessed by the tutor, the disclosure made by the student or other party or safeguarding concern.
- Tutors should not assume that somebody else will take action/share information that might be critical in keeping children safe. All allegations are treated as serious and confidential.
- Tutors should remain calm and reassure the other person they are doing the right thing. Tutors may offer sympathy and comfort to the other party and listen to them attentively, asking open questions.
- Where referrals are not made by the Designated Safeguarding Lead, the Designated Safeguarding Lead should be informed, as soon as possible, that a referral has been made.
- 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.
- The DSL or deputy DSL will always be available to discuss safeguarding concerns.
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.
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 inquests 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.
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 protection referral to Children’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 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 Children’s 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 and young people in a school or college, the Study Mind team must inform the school’s Designated Safeguarding Lead/ Officer of any safeguarding concern.
7. Safeguarding Issues
All Study Mind staff should have an awareness of any safeguarding issues that can put children 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 , serious violence are all signs that children are at risk. Below are specific issues that Study Mind highlights as key issues
Child on Child Abuse
Study Mind believes that all children 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 2023). 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 challenge 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
● 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 seeks to eradicate the possibility of Child on Child abuse through:
– communication between students completely prohibited outside of Study Mind monitored group classes. Even in these scenarios, communication is limited and monitored (please see Online Safety Policy).
– never sharing or displaying contact details for other students
-only students from the same school booking are permitted to be in email chains, and this must be approved by the school
– all face to face student contact (in Live Days, Work Experience and so on) have a strict Code of Conduct, shared with students and guardians ahead of time and requiring signing.
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).
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 may not realise they are being exploited for example they believe they are in a genuine romantic relationship.
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 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
- 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.
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 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 the 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 PHSE 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.
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 with 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.
All staff should be aware of the indicators, which may signal children 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 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 KCSIE 2022 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 2023.
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 disclose to third party associations where necessary.
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 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 2022, Section 1: Part 355-356)
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) is /are at risk of harm from their continued contact with children. Refer to KCSIE 2022, Part 4: 379.
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.
8b. Any tutor who is reported for a 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 include 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 2022, Part 4: 402)
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]
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 2023) 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 2022, Part 4: 419-420)
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.
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.
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 writing 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.
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.
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. Please see the Whistleblowing policy for additional information.
The Study Mind Safeguarding Policy will be reviewed constantly in order to maintain its adequacy to meet current Safeguarding Standards.
This policy needs to be reviewed every 6 months for 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.
The last review took place on 29th September 2023.