Safeguarding and child protection policy.

1. Statement of Commitment

At ThorntonbyChelsea, the safety, welfare and wellbeing of every child are fundamental to the educational services we provide.

We are committed to safeguarding children and young people from abuse, neglect, exploitation and other forms of harm, whether tuition takes place in person or online.

We recognise that safeguarding is everyone's responsibility. All tutors working with ThorntonbyChelsea are expected to act professionally, maintain appropriate boundaries, remain alert to safeguarding concerns and report those concerns promptly.

ThorntonbyChelsea is an education consultancy and tuition service operated by Charlie Thornton as a sole trader. It is not a school or a registered educational institution.

This policy establishes the safeguarding standards expected of tutors and explains how concerns are identified, reported and addressed.

2. Scope of the Policy

This policy applies to:

Charlie Thornton, as the operator of ThorntonbyChelsea.

The Named Safeguarding Lead and any person providing safeguarding cover.

Freelance tutors and other specialists providing educational services through ThorntonbyChelsea.

Children and young people under 18 receiving services, whether based in the UK or internationally.

In-person tuition, online tuition and associated educational activities and communications.

The policy applies regardless of a child's background, nationality, disability, religion, sex or other personal characteristics.

Where services are delivered internationally, local safeguarding and reporting requirements must also be considered.

3. Safeguarding Responsibilities

ThorntonbyChelsea is committed to maintaining clear safeguarding responsibilities and procedures to protect the children and young people who access our services.

Safeguarding is a shared responsibility. All individuals working on behalf of ThorntonbyChelsea are expected to understand their obligations, maintain appropriate professional boundaries and report any concerns about a child's safety or wellbeing.

3.1 Business Operator

Charlie Thornton, as the sole-trader operator of ThorntonbyChelsea, retains overall responsibility for the business's safeguarding arrangements.

This includes:

Ensuring appropriate safeguarding policies and procedures are maintained.

Overseeing safer recruitment, including tutor identity verification, qualification checks, references and Enhanced DBS checks.

Ensuring tutors are informed of the safeguarding standards expected of them.

Supporting the Named Safeguarding Lead in responding to concerns and implementing necessary protective measures.

Reviewing safeguarding arrangements regularly to ensure they remain appropriate to the services provided.

3.2 Named Safeguarding Lead

Named Safeguarding Lead: Tabitha Wells

Email: tabitha@thorntonbychelsea.co.uk

Tabitha Wells is the Named Safeguarding Lead for ThorntonbyChelsea and serves as the primary point of contact for safeguarding concerns.

The Named Safeguarding Lead has completed safeguarding training.

Responsibilities include:

Receiving and responding promptly to safeguarding concerns raised by tutors, parents, guardians or students.

Maintaining accurate, confidential records of safeguarding concerns and actions taken.

Providing guidance to tutors on safeguarding matters and professional boundaries.

Assessing concerns and seeking advice from relevant safeguarding professionals or statutory services where appropriate.

Making or coordinating referrals to children's social care, the police or other relevant authorities when necessary.

Supporting the ongoing review and implementation of ThorntonbyChelsea's safeguarding procedures.

3.3 Safeguarding Cover

Safeguarding Cover: Charlie Thornton

Charlie Thornton provides safeguarding cover when the Named Safeguarding Lead is unavailable.

Where a safeguarding concern involves the Named Safeguarding Lead, the matter should be raised directly with Charlie Thornton or, where appropriate, the relevant statutory safeguarding authority.

Where a concern involves Charlie Thornton, it should be reported to the Named Safeguarding Lead or directly to the relevant statutory authority.

No safeguarding concern should be delayed because a particular individual is unavailable.

3.4 Responsibilities of Freelance Tutors

All freelance tutors working with ThorntonbyChelsea are expected to uphold the highest standards of professional conduct and child safeguarding.

Tutors are responsible for:

Familiarising themselves with and following ThorntonbyChelsea's safeguarding policy and procedures.

Maintaining appropriate professional boundaries with students and families.

Recognising potential indicators of abuse, neglect, exploitation or other safeguarding concerns.

Reporting concerns promptly to the Named Safeguarding Lead.

Cooperating with safeguarding enquiries and providing accurate information when required.

Respecting confidentiality and handling children's personal information appropriately.

Ensuring all routine communication about tuition takes place with the parent or guardian.

Tutors must not investigate suspected abuse independently or promise absolute confidentiality when a child discloses a safeguarding concern.

Where a child is in immediate danger, tutors must contact the relevant emergency services without delay and inform the Named Safeguarding Lead as soon as practicable.

4. Recognising Abuse, Neglect and Exploitation

Safeguarding concerns may arise through something a child says, a change in behaviour, an observed incident, information provided by another person or inappropriate conduct by an adult.

Relevant risks include:

Physical abuse: Deliberate physical harm or injury.

Emotional abuse: Persistent behaviour that harms a child's emotional development or wellbeing.

Sexual abuse: Sexual activity, grooming or exploitation involving a child, including online abuse.

Neglect: Persistent failure to meet a child's basic physical or emotional needs.

Child-on-child abuse: Bullying, harassment, violence or exploitation perpetrated by another child.

Exploitation: Criminal, sexual or other exploitation, including coercion and manipulation.

Online harm: Grooming, inappropriate contact, cyberbullying, image-based abuse, sextortion and other technology-facilitated harm.

Safeguarding concerns may involve several forms of harm simultaneously.

Tutors must remain attentive to the needs of children with disabilities, special educational needs or communication difficulties, who may face additional barriers to reporting abuse.

A child does not need to make a formal disclosure for a safeguarding concern to exist.

5. Safer Recruitment and Tutor Vetting

ThorntonbyChelsea applies academic and safeguarding checks before introducing tutors to families.

5.1 Interviews and identity verification

Prospective tutors undergo an interview and identity verification before being accepted to provide tuition.

Qualifications and references are also checked as part of the recruitment process.

5.2 Academic qualifications

Tutors must meet ThorntonbyChelsea's academic requirements:

A bachelor's degree awarded at First-Class or Upper Second-Class (2:1) level in their chosen teaching subject.

A or A* grades at A-Level.

These requirements support academic quality but do not replace safeguarding suitability assessments.

5.3 Enhanced DBS checks

All tutors are required to have an Enhanced Disclosure and Barring Service (DBS) check before being matched with a student.

ThorntonbyChelsea verifies the relevant certificate or, where applicable, checks its status through the DBS Update Service.

The appropriate level of check, including eligibility for a Children's Barred List check, is determined by the activities undertaken and applicable requirements.

A DBS certificate is one part of safer recruitment. It does not, by itself, establish that a person is suitable to work with children.

5.4 References and suitability

Tutor recruitment includes reference checks and consideration of professional suitability.

Concerns identified during recruitment must be considered before a tutor is approved to work with a family.

ThorntonbyChelsea may decline to engage or introduce a tutor where suitability cannot be established.

5.5 Safeguarding policy and reporting arrangements

Tutors must be informed of this policy, the reporting arrangements and the professional boundaries expected when working with children.

Tutors do not receive safeguarding training from ThorntonbyChelsea. All tutors are required to have an Enhanced DBS check before being matched with a student.

6. Professional Conduct and Boundaries

Tutors must maintain professional relationships with students and their families.

Tutors must not:

Establish inappropriate personal relationships with students.

Contact children privately through personal messaging applications or social media.

Share personal, confidential or inappropriate content with students.

Arrange unauthorised meetings or activities with students.

Take or distribute photographs, recordings or personal information about students without appropriate authorisation.

Engage in conduct that could compromise a child's safety or wellbeing.

All routine communication regarding lessons, scheduling, academic progress and educational arrangements must take place between the tutor and the parent or guardian.

Where direct communication with a student is necessary for an agreed educational activity, it must take place through an approved arrangement known to the parent or guardian.

7. In-Person Tuition

ThorntonbyChelsea requires a parent or guardian to remain on the premises during in-person tuition with children.

Tutors are expected to conduct lessons in an appropriate learning environment and maintain professional boundaries throughout.

Tutors must not transport children, arrange off-site activities or change supervision arrangements without prior authorisation and appropriate safeguards.

Any concern arising during an in-person lesson must be reported promptly in accordance with this policy.

8. Online Tuition and Digital Safety

ThorntonbyChelsea recognises that online tuition introduces additional safeguarding considerations.

Online lessons may be delivered using different teaching platforms, depending on the tutor and family arrangements.

The following principles apply to all online tuition:

Parents or guardians must know which platform is being used.

Lesson arrangements and communication channels must be agreed with the parent or guardian.

Tutors must use professional and appropriate online identities.

Private social media communication between tutors and children is prohibited.

Tutors must not share lesson links, student information or recordings with unauthorised individuals.

Any concerning online interaction must be reported promptly.

Implementation requirement: ThorntonbyChelsea will formalise its rules for approved platforms, parental access, lesson recording, storage and deletion of recordings, and responses to online safeguarding incidents.

Unless specifically authorised under an agreed policy, tutors must not record lessons or distribute images, screenshots or recordings of students.

9. Responding to Safeguarding Concerns

Any concern about a child's safety or wellbeing must be taken seriously.

Tutors should report concerns to the Named Safeguarding Lead as soon as possible.

Named Safeguarding Lead: Tabitha Wells

Email: tabitha@thorntonbychelsea.co.uk

Where a child discloses abuse or another safeguarding concern, the person receiving the disclosure should:

Remain calm and listen carefully.

Take the child seriously.

Avoid asking leading questions or conducting an investigation.

Avoid promising absolute confidentiality.

Explain, in an age-appropriate way, that information may need to be shared to keep the child safe.

Record the child's words and relevant observations as accurately as possible.

Report the concern promptly to the Named Safeguarding Lead.

Safeguarding concerns must not be dismissed because evidence is incomplete.

9.1 Immediate danger

If a child is in immediate danger, contact emergency services without delay.

United Kingdom: 999

Where necessary, contact the relevant local authority children's social care service.

The Named Safeguarding Lead should be informed as soon as it is safe and practicable to do so.

9.2 Referrals

The Named Safeguarding Lead will consider whether a concern requires:

Consultation with local authority children's social care.

A referral to children's social care.

Police involvement.

Contact with a school's safeguarding lead, where relevant.

Other appropriate safeguarding support or early intervention.

The Named Safeguarding Lead must not attempt to investigate suspected abuse independently where this could compromise a statutory investigation.

10. Allegations and Concerns About Tutors

Any allegation that a tutor has harmed a child, may have harmed a child, committed an offence against or relating to a child, or behaved in a way indicating a potential risk to children must be reported promptly.

The Named Safeguarding Lead and business operator will consider immediate protective action, including suspending new introductions or tuition arrangements while appropriate advice is sought.

Where an allegation meets the relevant threshold, ThorntonbyChelsea will contact the appropriate Local Authority Designated Officer (LADO) or equivalent authority.

Police and children's social care referrals will be made where appropriate.

ThorntonbyChelsea will cooperate with relevant statutory authorities and consider any applicable duty to refer an individual to the Disclosure and Barring Service.

Concerns about professional boundaries that do not appear to meet the threshold for significant harm must also be recorded and considered appropriately.

No allegation should be ignored solely because it appears minor or has not yet been substantiated.

11. Safeguarding Records and Confidentiality

Safeguarding concerns must be recorded factually and confidentially.

Records should include, where available:

The date and time of the concern.

The people involved.

A factual account of what was observed or disclosed.

Any immediate action taken.

Advice received and referrals made.

Subsequent decisions and follow-up actions.

Records must distinguish factual observations from opinions or assumptions.

Safeguarding information must be stored securely and accessed only by authorised individuals with a legitimate need to know.

Information may be shared with statutory authorities or other relevant safeguarding professionals where necessary and lawful to protect a child.

Data protection requirements must not be used as a reason to delay necessary safeguarding action.

12. Privacy and Data Protection

ThorntonbyChelsea is committed to protecting the personal information of children and families.

Personal information is handled in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Tutors should receive only the personal information reasonably necessary to provide the agreed educational services.

Personal information must not be shared, retained or used for unrelated purposes without an appropriate lawful basis.

Safeguarding records must be managed separately and securely, with appropriate access and retention arrangements.

Further information is provided in ThorntonbyChelsea's Privacy Policy.

13. International Students

ThorntonbyChelsea may provide educational services to children living outside the United Kingdom.

Safeguarding standards apply regardless of the student's location.

Where a concern involves a child overseas, the Named Safeguarding Lead will consider the appropriate local child protection authorities and emergency services in the country concerned.

ThorntonbyChelsea will seek appropriate advice where international reporting arrangements are unclear.

In an emergency, the relevant emergency services in the child's location should be contacted immediately.

14. Raising Concerns About Safeguarding Practice

Parents, guardians, tutors and others are encouraged to raise concerns about unsafe practice or failures to follow this policy.

Concerns may be reported to:

Tabitha Wells, Named Safeguarding Lead

tabitha@thorntonbychelsea.co.uk

Where the concern relates to the Named Safeguarding Lead, it may be raised with Charlie Thornton or directly with the appropriate statutory authority.

Where the concern relates to Charlie Thornton, it may be raised with the Named Safeguarding Lead or directly with the appropriate statutory authority.

A person who believes that a child remains at risk may contact children's social care or the police directly, regardless of whether a concern has already been reported internally.

15. Policy Governance and Review

Charlie Thornton, as the operator of ThorntonbyChelsea, is responsible for approving this policy and ensuring that its requirements are implemented.

The Named Safeguarding Lead is responsible for coordinating safeguarding practice, maintaining appropriate records and recommending updates.

This policy will be reviewed at least annually and sooner where:

Relevant legislation or guidance changes.

A significant safeguarding incident identifies a need for improvement.

ThorntonbyChelsea changes its services or operating arrangements.

New safeguarding risks are identified.

All tutors must be informed of relevant changes to safeguarding procedures.

16. Relevant Legislation and Guidance

This policy has been prepared with reference to the safeguarding framework applicable to private education and out-of-school provision in England, including, where relevant:

Children Act 1989 and Children Act 2004.

Safeguarding Vulnerable Groups Act 2006.

Data Protection Act 2018 and UK GDPR.

Department for Education guidance on keeping children safe in out-of-school settings.

Working Together to Safeguard Children.

Keeping Children Safe in Education, as a reference for relevant good practice in educational settings.

The statutory duties applying specifically to schools and colleges should not automatically be assumed to apply identically to ThorntonbyChelsea.