Keystone Tutors Limited carries out activities which bring our employees and self-employed tutors into regular unsupervised contact with children and/or vulnerable adults. This includes providing tutoring and educational services in the students' home and elsewhere. Keystone Tutors Limited takes its responsibilities to safeguard and protect the interests of all young children very seriously.
This policy is non-contractual but indicates the way in which Keystone Tutors Limited intends to deal with such matters.
Scope of this policy
This policy applies to all self-employed tutors, employees, workers or volunteers whose duties bring them into contact with children and/or vulnerable adults.
Aims of this policy
This policy aims to create and maintain the safest possible environment for the children and vulnerable adults with whom we deal, as well as for our self-employed tutors, employees and workers, and all reasonable steps will be taken to prevent all parties from harm.
There is a considerable body of legislation designed to ensure that children and vulnerable adults are protected and it is important to understand that everyone is responsible for their safety. The main acts include:
- the Protection of Freedoms Act 2012
- Safeguarding Vulnerable Groups Act 2006 (VBS)
- Conduct of Employment Agencies and Employment Business Regulations 2003
- Protection of Children Act 1999/Criminal Justice and Court Services Act 2000
- Care Standards Act 2000
- The Police Act 1997
- The Children (Protection from Offenders) (Miscellaneous Amendments) Regulations 1997
- The United Nations Convention on the Rights of the Child
- the Rehabilitation of Offenders Act 1974
- Health and Safety at Work etc Act 1974 (HASAWA)
A "child" is anyone under the age of 18.
A "vulnerable adult" is a person aged 18 years or over who is:
- in residential accommodation provided in connection with care or nursing or receiving care or nursing at home
- receiving health care
- in lawful custody or under the supervision of a probation officer
- receiving a welfare service of a prescribed description or direct payments from a social services authority
- receiving services, or taking part in activities, aimed at people with disabilities or special needs because of his/her age or state of health.
It may be a person who is unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation. He/she may be elderly or frail, have learning disabilities, suffer from mental illness, have a physical disability, be a substance misuser, be homeless or in an abusive relationship.
Those who are involved in work situations where they have sustained or prolonged unsupervised access to children or vulnerable adults are exempt from the Rehabilitation of Offenders legislation. This means that prospective employees, self-employed contractors and volunteers must declare all criminal convictions, however long ago; and these will be taken into account when deciding on their suitability for working with children or vulnerable adults. No-one will be permitted to undertake a role which involves regular contact with children or vulnerable adults without a satisfactory Disclosure and Barring Service (DBS) check.
However, a criminal record may not prevent a person from working for Keystone Tutors Limited in any other capacity: if that person is then asked to undertake tasks which will bring him/her into unsupervised contact with children or vulnerable adults, such as work experience placements, any record must be declared to a Keystone Tutors' Director who will take appropriate advice where necessary and will decide whether this task should be allocated to another member of staff or freelancer.
Planning and supervision
All activities or assignments involving children or vulnerable adults should be planned in advance to ensure they take into account the age range and ability of the participants. Staff, volunteers or freelancers supervising assignments involving children/vulnerable adults should be competent to do so. Supervision should take account of the age, gender, nature of the activity and any special needs of the individuals. Where appropriate, a risk assessment will be undertaken and documented.
All workers should avoid working alone with a child or vulnerable adult wherever possible. If it is not avoidable they should plan their work so that at least one other adult is present at any time. If possible, the worker should also move to a workstation where he/she and the child/vulnerable adult can both be seen by other colleagues or other adult and/or the door should be left open.
This guidance applies also to transport in vehicles - workers must not offer to transport a child or vulnerable adult anywhere unless accompanied by a further person or as part of a formal arrangement.
On no account should any self-employed tutor, employee, worker or volunteer have any physical contact with a child or vulnerable adult unless it is to prevent accident or injury to themselves or anyone else (eg to prevent a fall), or in the case of medical assistance being needed (eg to administer first aid), or to provide nursing or other general care, in which case the prior consent of the affected person should be requested where possible. Where appropriate, consent from parents or those with parental or caring responsibility should be obtained.
If a child/vulnerable adult is hurt or distressed, the worker should do his/her best to comfort or reassure the affected person without compromising his/her dignity or doing anything to discredit the person's own behaviour.
When a tutor or any Keystone employee is in direct contact with students (for example via email or other electronic communication) it is vital that the parent or guardian is included in all correspondence. Tutors should have no direct contact with students that parents or guardians are not party to.
Communication with children/vulnerable adults is vital in establishing relationships built on trust. Those working with children or vulnerable adults should listen to what they are saying and respond appropriately. Children and vulnerable adults are entitled to the same respect as any self-employed tutors, employees, workers and volunteers. It should also be made clear to them what standards of behaviour and mutual respect are expected from them.
Those working with children/vulnerable adults should behave appropriately, ensure that language is moderated in their presence and should refrain from adult jokes or comments which are clearly unsuitable. Workers should also note that what may be acceptable language to their friends may not be regarded as such by those of an older generation.
Behaviour and abuse
We should all aim to promote an environment of trust and understanding. Those working with children/vulnerable adults should not tolerate unsociable behaviour but should try to ensure good working relationships.
All self-employed tutors, employees, workers and volunteers at Keystone Tutors Limited have a strict duty never to subject any child/vulnerable adult to any form of harm or abuse. This means that it is unacceptable, for example, to treat a child/vulnerable adult in any of the following ways:
- to cause distress by shouting or calling them derogatory names
- to slap
- to hold them in such a way that it causes pain, or to shake them
- to physically restrain them except to protect them from harming themselves or others
- to take part in horseplay or rough games
- to allow or engage in inappropriate touching of any kind
- to do things of a personal nature for the person that they can do for themselves (this includes changing clothing, or going to the toilet with them unless another adult is present)
- to allow or engage in sexually suggestive behaviour within a person's sight or hearing, or make suggestive remarks to or within earshot
- to give or show anything which could be construed as pornographic
- to seek or agree to meet them anywhere outside of the normal workplace without the full prior knowledge and agreement of the parent, guardian or carer.
- to engage with them online in an unacceptable manner.
Suspicions of abuse
Any worker who witnesses or suspects abusive behaviour towards a child/vulnerable adult should record the details and report it to a Keystone Tutors' Director. It is NOT the individual's responsibility to investigate his/her suspicions - this requires expertise he/she is not expected to have.
Any allegations of abuse made against anyone working for Keystone Tutors Limited will be thoroughly investigated and dealt with through our disciplinary procedure for employees. Serious breaches may lead to dismissal (for employees) or termination of any agreement (for self-employed tutors, workers or volunteers).
A Keystone Tutors' Director will appropriately record an allegation or reported incident. He/she will be responsible for contacting the statutory child protection agency such as the Local Safeguarding Children Board or the police if necessary.
The safety of the people we work with is paramount and we are committed to providing a safe environment within which to work. Those working with children/vulnerable adults should ensure all appropriate risk assessments and security checks have been carried out prior to any assignment.
If transporting children/vulnerable adults, the transport should be checked to ensure it is roadworthy and adequate for the purpose. Any equipment used must be safe and only used for the purpose for which it is intended. Users should be adequately trained. Appropriate insurance should be up to date and adequate to cover such assignments.
All personal information regarding children/vulnerable adults is highly confidential and should only be shared with appropriate people on a need to know basis. Information will be stored in the Keystone offices at 5 Blythe Mews, access limited to employees who are required to access it to fulfil their duties and will only be kept for as long as is needed.
Anyone who is likely to have access to confidential material regarding children or vulnerable adults, or any of the bodies on behalf of whom Keystone Tutors Limited is working, may be required to sign a non-disclosure agreement. The requirement for confidentiality is emphasised.
Contact outside of work
Contact should not be made with any of the children/vulnerable adults with whom we are working for any reason unrelated to the particular work. In particular, our self-employed tutors and employees are required to maintain our reputation for integrity and responsibility in dealing with such people, and should not enter into any social or other non-work related arrangements with them.
Gifts and inducements
On no account should anyone from Keystone Tutors Limited give a child/vulnerable adult a gift or buy refreshments etc which could be in any way considered as a bribe or inducement to enter into a relationship with the Keystone Tutors Limited person or give rise to any false allegations of improper conduct against the individual.
Communicating this policy and concerns
All employees, workers and volunteers at Keystone Tutors Limited will be made aware of this policy and a copy will be available via the Keystone Tutors website.
Furthermore, a copy of this policy will be made available to all relevant bodies with whom we work and will be made available to parents and carers of children/vulnerable adults with whom we plan to work.
Any concerns about the assignment or people involved should be addressed with a Keystone Tutors' Director.
Breach of this policy
Failure to follow the guidelines in this policy is considered a serious offence and will be investigated thoroughly and dealt with through our disciplinary procedure for employees. Serious breaches may lead to dismissal (for employees) and termination of any agreement (for self-employed tutors, workers or volunteers).
Implementation, monitoring and review of this policy
Ed Richardson has overall responsibility for implementing and monitoring this policy, which will be reviewed on a regular basis following its implementation (at least annually) and additionally whenever there are relevant changes in legislation or to our working practices.
Any queries or comments about this policy should be addressed to Ed Richardson. In Ed's absence queries should be directed to Josh Pull.
Keystone Tutors maintains a strict policy of client and tutor confidentiality and we are committed to protecting and safeguarding your personal data. As part of this commitment this policy aligns with the General Data Protection Regulation (GDPR). This policy relates to all information you provide to Keystone Tutors and all data that Keystone Tutors holds in relation to your use of the site. It supplements and is in addition to the Terms and Conditions and should be read in conjunction with them.
What do we collect?
In line with data protection laws we are only able to process personal data where we have a valid reason to do so.
Registration and student details (for Clients): This includes details such as your name, email address, address, telephone number, your child’s name, your child’s school year and your child’s educational background.
Details (for Tutors): Name, telephone number, email address and details of relevant teaching / tutoring experience. We may also store your bank details for the purpose of making payments to you for work done through Keystone Tutors.
What do we do with your information?
We will use your personal data to fulfil tutoring requests, meet our contractual obligations, and deliver a high quality service to clients and tutors.
Sharing information with third parties
Clients: After clients have registered with us we will share the broad requirements of the assignment on an anonymous basis with our tutor pool so that relevant tutors can apply for the job. If a tutor applies for a job, Keystone Tutors may send a link to that tutor’s profile to the client. If a client chooses to proceed with a tutor we will pass on the specific registration and student details to the tutor so that the tutor knows where the tutoring will happen, so that the tutor can prepare for the assignment and the tutor can contact the client to arrange lessons. Other than sharing information with our tutor pool on the basis outline above we will keep your personal information confidential within our group of companies and not pass it on to any 3rd parties unless we are required to do so by law.
Tutors: The information that you provide to Keystone Tutors forms the basis of a tutor profile.This includes the following information: a photograph, the subjects that you teach, your teaching experience, personal biography, your personal teaching approach, and testimonials. This profile will be published on the Keystone website only if you have ticked the “I would like my profile published on the Keystone Tutors website.” You can untick this at any time to remove your profile from the Keystone Tutor’s website. Keystone Tutors may share your profile with prospective clients. We will pass on your contact details to clients for jobs that you have applied for or for jobs that you have expressed an interest in. Other than sharing information with our clients on the basis outlined above we will keep your personal information confidential within our group of companies and not pass it on to any 3rd parties unless we are required to do so by law.
How do we keep your information safe?
We take reasonable steps to ensure that your information is kept safe and will endeavour to protect it from unauthorised access. Your information will only be kept for a commercially reasonable period of time for the purposes stated above.
We occasionally issue session cookies when strictly necessary for the operation of the website (such as logging into our member account area). These cookies do not hold any personal information. You can find out more about what cookies are, how to control them and delete them here. Google Analytics and third party services such as Google Maps, Twitter and Facebook may issue cookies. Further information on Google Analytics and Privacy can be found here. You are welcome to opt-out of receiving cookies from us or third parties services at any time using the settings in your browser.
We shall retain your data only for as long as necessary in accordance with applicable laws.
Clients: We will keep you personal data whilst you are an active client of Keystone Tutors. If your do not receive any services for a period of 8 years your data will be deleted.
Tutors: For tutors who join Keystone Tutors as an employee or self-employed freelancer we will retain your data for up to 8 years.
Tutor Applications: We retain tutor applications for 8 years.
Right to be Forgotten
You have the right to object to our use of your personal data and to ask us to delete it if there is no need for us to keep it. This is known as your right to be forgotten. Please inform us if you think we are retaining or using your personal data incorrectly. If you wish for us to delete any data we hold about you, please inform us in writing and we will delete your data within 3 working days, unless there is a legal reason why we are not allowed to do so.
Access to your data
You have the right to request a copy of all personal information that we hold about you at no cost. We will also correct any inaccuracies in your information at your request.
Email tracking and Newsletters
Our newsletters employ tracking so that we can monitor at an individual level whether a recipient has opened the email and what content they have clicked on. We only send our newsletter to recipients where there is a legitimate interest to do so. This includes sending emails giving details of relevant events and courses and updates to individuals who have subscribed via our website or who are registered clients. Recipients are able to easily unsubscribe from the newsletter if they wish.
Third party sites
We link to a number of other websites on our site. We are not responsible in any way for the privacy policies of these sites nor for the way in which they may use the information they collect about you.
Changes to this policy
This policy may be changed or amended at our absolute discretion, so you should review it from time to time so you are aware of any changes. Any changes will be posted on the Website.
If you have any questions, please contact us using the details on the contact page.