Safeguarding Policy

Contents

1. Key contacts
2. Statement of Commitment
3. Aims
4. Application
5. Legislation & Statutory Guidance
6. Definitions & Terminology
7. Responsibility of Staff and all tutors
8. Key Safeguarding Principles
9. Recognise
10. Categories of abuse
11. Mental health & well-being
12. How concerns may be discovered
13. Respond
14. Report
15. Record
16. Confidentiality & sharing information
17. Safeguarding Concern Process
18. The role of the DSL
19. DSL's management of safeguarding reports and allegations
20. Communication with parents/carers
21. Escalation
22. The Keystone Professional Code of Conduct
23. Allegation or concern about the conduct of an employee or self-employed tutor
24. Low Level Concerns about an employee or self-employed tutor
25. Referral to the Disclosure & Barring Service (DBS) and Teaching Regulation Agency (TRA)
26. Appendix 1 Safeguarding Report Form
27. Appendix 2 Additional information on types of safeguarding concerns

1. Key Contacts

The person with responsibility for all aspects of Safeguarding within Keystone Tutors is:

• Designated Safeguarding Lead (DSL): Ed Richardson
• Telephone: 020 760 25310
• Email: safeguarding@keystonetutors.com

In his absence the deputy is:

• Deputy Designated Safeguarding Lead (DDSL): Imogen Drummond-Smith
• Telephone: 020 760 25310
• Email: safeguarding@keystonetutors.com

The Local Safeguarding Children Partnership (LSCP)

Keystone Tutors is located in the London borough of Hammersmith & Fulham and therefore follows their advice and guidance. Initial advice about any safeguarding matter should be sought from Hammersmith & Fulham using the contact numbers below.

However, referrals relating to students are usually made to the borough where the student principally resides, so other boroughs may also need to be contacted.

Hammersmith & Fulham Child Protection Services
Initial Consultation and Advice Team (ICAT)
020 8753 6600
Fax: 020 8753 4209
Familyservices@lbhf.gov.uk
Walk-in: Ground Floor, 145 King St, Hammersmith, W6 9XY
Out of hours service: 020 8748 8588

If you have an immediate concern for the well-being of a child or young person, call the police on 999.

For LADO consultations, when there are allegations about the conduct of a member of staff or a tutor, contact the duty Child Protection Adviser on:

• Telephone: 020 8753 5125
• Email: LADO@lbhf.gov.uk

If you cannot reach the duty CP Adviser contact:
Named LADO: Megan Brown

• Safer Organisations (incorporates LADO) and Safeguarding in Education Manager
• Telephone: 020 8753 5125
• Email: megan.brown@lbhf.gov.uk

CAMHS (Child & Adolescent Mental Health Services) A service for children and young people under 18 and who live in Hammersmith and Fulham, Ealing or Hounslow and are in need help and support. The aim is to offer telephone support via a helpline number, which includes basic counselling and problem-solving to young people and their families. The helpline is run by healthcare professionals who are familiar with local services and have a range of specialist knowledge, to help support and advise young people and their families.

CAMHS Helpline: 0800 328 4444

2. Keystone Tutors Statement of Commitment

2.1 Keystone's mission is to uphold the highest professional standards so its students are enabled to perform at their best and supported to build long-term academic resilience and life-long intellectual curiosity.

2.2 All Keystone employees and self-employed tutors are expected to abide by the Keystone Professional Code of Conduct.

2.3 The very nature of this work brings Keystone employees and self-employed tutors into contact with children, whether providing tutoring and educational services in the child's home, online or elsewhere. It is Keystone's duty, together with its employees and self-employed tutors to protect all children, always promoting their welfare and well-being.

2.4 Keystone is committed to providing a welcoming and safe environment in which students can engage with the tutoring undertaken by and on behalf of Keystone Tutors and by the tutors that are introduced to clients.

2.5 Keystone recognises that safeguarding and promoting the welfare of children is everyone's responsibility. Everyone who comes into contact with children and their families has a role to play. In order to fulfil this responsibility effectively, Keystone ensures that its approach is always child-centred. This means that it will consider, at all times, what is in the best interests of the child.

2.6 Keystone Tutors recognises the additional risks that children with SEN and disabilities face, including risks online, and accepts the responsibility to take reasonable and appropriate steps to ensure their welfare.

3. Aims

The aims of this policy are to:

• Promote and prioritise the safety and wellbeing of students
• To ensure that robust safeguarding procedures are in place and are followed by all staff in accordance with national guidance and locally agreed inter-agency procedures
• Ensure that all employees and self-employed tutors are provided with the knowledge and understanding to recognise and respond to signs of abuse, neglect and all other safeguarding concerns relating to children and young people
• For all staff to be fully aware and confident of their role in safeguarding students and of their responsibilities to report and record concerns, including possible harm or abuse by adults or other children
• For all staff to be fully aware of the need to report any concerns (including low level concerns and self-referal) about the actions of members of staff, tutors or volunteers
• Provide support to any individual/s who report concerns
• Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
• Employ safer recruitment procedures, in line with government guidance, to ensure only suitable individuals are recruited
• Promote effective working relationships with all partner agencies, sharing information to achieve the best possible outcomes for children
• Identify a Designated Safeguarding Lead and Deputy to ensure safeguarding is embedded into the culture of the company

4. Application

This policy applies to all employees, workers, volunteers and self-employed tutors of Keystone Tutors. It applies to all students of Keystone Tutors, regardless of their age.

Before beginning work, all employees, workers, volunteers and self-employed tutors of Keystone Tutors will be provided with:

• a copy of this policy
• a copy of the Keystone Professional Code of Conduct
• Part One and Annex B of Keeping Children Safe in Education (2023)

They must sign to confirm they have received these documents and have understood the content. Parents will be provided with this policy during Keystone's onboarding process.

5. Legislation & Statutory Guidance

The practices and procedures within this policy pay due regard to the following documents and statutory guidance.

• Keeping Children Safe in Education (2025) (KCISE)
• Working Together to Safeguard Children (2023)
• Prevent Duty Guidance for England and Wales (2023)
• Information Sharing - Advice for practitioners providing safeguarding services to children, young people, parents and carers (2024)
• What to do if you're worried a child is being abused (2015)
• UKCIS Education Group: Sharing nudes and semi-nudes: How to respond to an incident (2024)
• DfE guidance: Mental health and behaviour in schools: departmental advice (2018)

This policy also reflects the duties set out in the Children Acts 1989 and 2004, the Equality Act 2010, the Human Rights Act 1998, the Domestic Abuse Act 2021, and the Online Safety Act 2023.

6. Governance and Oversight

The Board of Directors retain overall responsibility for safeguarding and will review this policy annually. The DSL will provide safeguarding reports to the senior leadership team, ensuring effective governance and the continuous improvement of safeguarding arrangements.

7. Definitions & Terminology

The following definitions are referred to in this policy.

Child: In England, a child is someone under the age of eighteen whether living with their families, in state care, or living independently (Working Together to Safeguard Children 2023).

Safeguarding and promoting the welfare of children is defined in KCSIE as

• providing help and support to meet the needs of children as soon as problems emerge
• protecting children from maltreatment, whether that is within or outside the home, including online
• preventing the impairment of children's mental and physical health or development
• ensuring that children grow up in circumstances consistent with the provision of safe and effective care
• taking action to enable all children to have the best outcomes

Abuse: A form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.

Safeguarding concern: When there is information that a child or young person has been harmed, or is at risk of being harmed, by their own or someone else's behaviour.

Safeguarding allegation: Where a person who is either an employee or self-employed tutor of Keystone Tutors has:

• Behaved in a way that has harmed a child or an adult at risk, may have harmed a child or an adult at risk, or behaved in a way that might lead to a child or an adult at risk being harmed;
• Has possibly committed or is planning to commit a criminal offence against a child or an adult at risk or related to a child or an adult at risk
• Behaved towards a child or an adult at risk in a way that indicates they are or would be, unsuitable to work with children or adults at risk

Abuse of Trust: It is an offence for a person in a position of trust to cause or incite a child or young person to engage in any form of sexual activity, including remotely through technology. This applies even if the relationship appears to be consensual.

All Keystone Tutors whether employed or self-employed are in a position of trust and must follow the Keystone Professional Code of Conduct in relation to all students, including those students over the age of 18.

8. Responsibility of Keystone Staff and Self-employed Tutors

All employees and self-employed tutors have a responsibility to be alert to the fact that children and vulnerable people may be abused. They must always be aware that:-

• Safeguarding and promoting the welfare of children is everyone's responsibility
• They must report any concern, however minor it may seem
• They must always act in the best interests of the child
• They must be alert to identify children at risk and children who may benefit from early help
• They must follow this policy on reporting and recording processes

Abuse is not always identified by a single incident; it is often a complex web of what may appear to be more minor pieces of information reported by different professionals in contact with the child. This is why it is so important for everyone to take responsibility and for all concerns to be reported.

Keystone Tutors recognises that some children may benefit from early help. Staff should identify emerging concerns and discuss these with the DSL, who may initiate an early help assessment or referral to local authority services. Consideration will also be given to contextual safeguarding, which recognises that risks may occur outside the family home, including online, in peer groups, and in community settings.

9. Key Safeguarding Principles

The aim of the following procedures is to detail how Keystone Tutors will respond if:

• they suspect that a student is suffering abuse
• a student makes a disclosure or reports that they, or someone else, has been abused
• the behaviour of an adult or child towards another child gives cause for concern
• the actions or behaviour of a student causes concern
• they identify a breach of the Keystone Professional Code of Conduct

The procedures also detail the action that will be taken by the DSL or Deputy DSL when a safeguarding concern is reported. Further advice and guidance may also be found in What to do if you're worried a child is being abused: Advice for Practitioners (2015)

By following the four simple safeguarding principles of recognise, respond, report and record, Keystone Tutors aims to identify and obtain support for those students who may be at risk.

• RECOGNISE that a child is being harmed or is at risk of harm or neglect. (This includes self-harm and mental health.)
• RESPOND appropriately to what you are being told or what you see.
• REPORT Concerns that you have to the Keystone Designated Safeguarding Lead or Deputy DSL immediately
• RECORD Be accurate and comprehensive.

10. Recognise

All Keystone tutors must be alert for the signs and indicators that students may be suffering abuse, remembering that they may also be abused by other children and young people as well as by adults.

Indicators that a student may be being abused may include the following:

• Unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries
• An injury for which the explanation seems inconsistent or implausible
• The young person describes what appears to be an abusive act involving him/her
• Someone else (a young person or adult) expresses concern about the welfare of another
• Unexplained changes in behaviour (e.g. becoming very quiet, withdrawn or displaying sudden outbursts of temper, changes in educational progress)
• Inappropriate sexual awareness/behaviour
• Sudden or unusual distrust of adults, particularly those with whom a close relationship would normally be expected
• Difficulty in making friends or sustaining friendships
• Being prevented from socialising with other young people
• Displaying variations in eating patterns including overeating or loss of appetite; or a sudden weight change
• Becoming increasingly dirty or unkempt
• Self-harming behaviour
• Overly concerned about their online status or activity

However, it should be recognised that this list is not exhaustive and the presence of one or more of the indicators is not proof that abuse is taking place, many other factors may also be involved. A good working relationship with parent/guardians will help to identify any other concerns that a young person may be experiencing. For example, a family bereavement, which could cause some of the changes listed above.

It is important to remember that:-

• Abuse may occur anywhere - within the family, in school or in any other setting – place of worship, sports club etc.
• Many children are abused by someone they know and trust e.g. family member, teacher, sports coach and by other children/young people
• They may also be abused via the internet without any contact taking place
• They may be abused by one or more adults, or by another child(ren)
• The abuser may be male or female

11. Categories of abuse

KCSIE categorises abuse into four main areas: physical abuse, emotional abuse, sexual abuse and neglect. However, it is important to realise that abuse is complex and rarely fits neatly into one category.

Physical abuse: A form of abuse which 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. The following are often regarded as indicators of concern:

1. an explanation which is inconsistent with an injury
2. several different explanations provided for an injury
3. unexplained delay in seeking treatment
4. the parents/carers are uninterested or undisturbed by an accident or injury
5. repeated minor injuries (which may represent a “cry for help” and if ignored could lead to a more serious injury)
6. two simultaneous bruised eyes, without bruising to the forehead (rarely accidental, though a single bruised eye can be accidental or abusive)
7. repeated or multiple bruising on the Head or on parts of the body unlikely to be injured accidentally
8. the outline of an object used, e.g. marks from a belt or a hairbrush, or of a hand print
9. grasp marks

Emotional abuse: The persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child's emotional development. This may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed.

It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.

Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone. Emotional abuse may be difficult to recognise, as the signs are usually behavioural rather than physical. The manifestations of emotional abuse may also indicate the presence of other forms of abuse.

The following may be indicators of emotional abuse:

1. abnormal attachment between a child and parent/carer, e.g., excessive anxiety on the part of either
2. indiscriminate attachment or failure to attach
3. aggressive behaviour towards others
4. scape-goated within the family
5. low self-esteem and lack of confidence
6. withdrawn or seen as a “loner” – difficulty relating to others
7. reverting to younger behaviour
8. depression, withdrawal
9. fear of academic failure or ‘getting things wrong’.

Sexual abuse: Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue (see KCSIE, Annex B).

Recognition of sexual abuse can be difficult, unless the child makes a disclosure. There may be no physical signs and indications are more likely to be emotional/behavioural.

Some behavioural indicators associated with this form of abuse are;

1. inappropriate sexualised conduct
2. sexually explicit behaviour, play or conversation, inappropriate to the pupil's age
3. continual and inappropriate or excessive masturbation
4. self-harm (including eating disorders), self-mutilation and suicide attempts

Neglect: The persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy because of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: a. provide adequate food, clothing and shelter (including exclusion from home or abandonment) b. protect a child from physical and emotional harm or danger c. ensure adequate supervision (including the use of inadequate caregivers) d. ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child's basic emotional needs. The following may be indicative of neglect of a child:

1. the child is dirty, poorly clothed or appears underfed
2. the child exhibits significant changes in behaviour, aggressive behaviour, severe tantrums
3. an air of ‘detachment’ or a ‘don't care’ attitude
4. overly compliant behaviour
5. a child who is reluctant to go home or is kept away from school for no apparent reason
6. ‘tummy pains’ with no medical reason
7. running away from home, suicide attempts
8. extreme anger, sadness or depression
9. child left with adults who are intoxicated or violent
10. child left alone for excessive periods

Affluent Neglect

Tutors should also be aware of the impact of affluent neglect, which refers to the neglect experienced by children in more wealthy families. This can be difficult to identify, as the type of neglect experienced by children in these circumstances is often emotional.

Parents may work very long hours or be absent for extended periods, leaving children in the care of paid carers. This can create an emotional disconnect and leave children feeling isolated and lonely, with their emotional needs unfulfilled by their parents.

Affluent parents may also subject their children to a high amount of pressure to succeed academically, or in other pursuits such as sport or music, which can lead to psychological and emotional problems.

Absent parents may also have little knowledge of what their children are doing. This can lead to increased risks with children who may spend long periods online or at an older age have the financial means to facilitate drug abuse and the independence to engage in harmful sexual activity.

Domestic abuse

It is also important to appreciate that children or young people may also be regarded as being abused if they are living in a household where adults are affected by domestic abuse, drug/alcohol abuse, mental health issues or in a situation where there is an acrimonious separation/divorce. Experiencing domestic abuse can have a serious, long lasting emotional and psychological impact on children.

Young people can also experience domestic abuse within their own intimate relationships. This form of child-on-child abuse is sometimes referred to as ‘teenage relationship abuse’. Tutors should also consider the impact of coercive and controlling behaviours in intimate relationships. Depending on the age of the young people, this may not be recognised in law under the statutory definition of ‘domestic abuse’ (if one or both parties are under 16). However, as with any child under 18, where there are concerns about safety or welfare, child safeguarding procedures should be followed and both young victims and young perpetrators should be offered support.

Further information on types of abuse is contained in KCSIE and in Annex B of this policy.

Children Missing Education

Keystone Tutors recognises that children missing education can be a sign of abuse or neglect. Where a student disengages or becomes uncontactable, the DSL will take steps to contact parents/carers and, where appropriate, make a referral to the local authority.

12. Mental health & wellbeing

Approximately 1 in 10 children aged under 15 years and 1 in 4 adolescents aged 16 & 17 experience mental health problems. Therefore, all professionals working with these age groups also have a role to play in identifying and addressing issues related to mental health and wellbeing.

Although early recognition of mental health problems is important, it can be difficult to detect the difference between a normal level of anxiety and a more worrying mental health problem. The border between normality and abnormality is not clear and there are no specific definitions. E.g. a very shy teenager may simply be lacking in confidence or could be on the verge of a serious anxiety disorder. Even for experts, it is not always easy to determine, and young people may often try to hide their feelings.

Therefore, it is important for tutors to be vigilant and look out for, not only for the more obvious signs of mental health problems, but also for more subtle signs that a student may be experiencing. Tutors should look for signs of distress or depression, poor concentration and/or social withdrawal and should listen for comments that may suggest an underlying problem. Tutors should also be alert to a pattern of events and of issues repeating over time.

12.1 Signs of mental health problems

It is important to recognise that all children and young people are different and the signs and indicators of mental health difficulties will differ. Some of the more common signs are listed below.

• sadness, or a low mood persisting for two weeks or more
• being irritable or grumpy all the time
• Repeated medical symptoms with no obvious cause e.g. stomach aches & headaches
• increase in irritability, recklessness or aggression
• looking sad or worried all the time, tearfulness
• worries that stop them carrying out day-to-day tasks
• sudden outbursts of anger directed at themselves or others
• not being interested in things they used to enjoy
• feeling tired and exhausted a lot of the time
• trouble sleeping or sleeping more than usual
• inability to concentrate
• being indecisive
• lack of confidence
• unable to relax
• eating less than usual or overeating
• changes in weight
• feeling guilty or worthless, talking negatively about themselves
• feeling empty or unable to feel emotions (numb)
• poor self-care
• presenting with hopelessness about their future
• refusing to go to school and/or decline in academic performance
• social isolation and giving up hobbies
• interacting less with friends and family
• thoughts about suicide or self-harming including talking/joking about self-harm/suicide
• actually self-harming, for example, signs of cutting their skin or taking an overdose
• panic attacks
• secretive behaviour
• obsessive or compulsive behaviour
• self-harm
• older children may misuse drugs or alcohol

Depression Most people feel low occasionally; this is a normal reaction to stressful or upsetting life events. When these feelings continue and interfere with normal daily life they may be a sign of depression. Some indicators of depression in young people include: moodiness and irritability, withdrawing from others, lack of energy, tearfulness, self-blaming/self-critical, thoughts of death/suicide, feeling unhappy, miserable or lonely much of the time. Not all young people will experience all these signs and it is also important how long symptoms have been present and the degree to which the young person is acting in a different manner.

Self-harm Behaviour where a young person causes harm to themselves to cope with thoughts, feelings or experiences they are not able to manage in any other way. In adolescents it usually takes the form of cutting, burning or non-lethal overdoses, in younger children it can manifest as picking/scratching wounds, pulling out hair, banging or bruising themselves.

Obsessions and compulsions Obsessions describe intrusive thoughts or feelings which are disturbing or upsetting; compulsions are the behaviours carried out to manage those thoughts or feelings. For example, obsessions related to symmetry or order may result in constantly evening up books or other items on a shelf or desk or rearranging items to be in a certain order. Fears of germs or contamination may result in repeatedly washing hands or using hand-sanitizer or refusing to use items such as pens or pencils which have been used by others. Fears related to numbers may result in a compulsion to say words a certain number of times or obsessive counting and having to start over if interrupted. Further online support and guidance can be found on OCD UK:

• http://www.ocduk.org/ocd/

Suicidal feelings Young people may experience complicated thoughts and feelings about wanting to end their own lives. Some young people never act on these feelings although they may openly discuss and explore them, while other young people take their own lives suddenly without any apparent warning signs. Further advice is also available at:

• https://papyrus-uk.org/hopelineuk/
• https://youngminds.org.uk/find-help/feelings-and-symptoms/suicidal-feelings/

Eating problems Food and body size may be used as a way of coping with, or communicating about, difficult thoughts, feelings and behaviours. Eating disorders include anorexia (where food intake is restricted), binge eating disorder and bulimia nervosa (a cycle of bingeing and purging). Primary age and younger children may also develop problematic behaviours around food such as refusing to eat in certain situations or with certain people. This can be a way of communicating messages the child does not have the words to convey.

• https://youngminds.org.uk/find-help/feelings-and-symptoms/eating-problems/
• http://www.anorexiabulimiacare.org.uk/help-for-you/young-people

12.2 Issues that increase the risk of mental health problems include:

• family difficulties
• bullying
• physical, emotional or sexual abuse
• a family history of depression or other mental health problems
• difficult life event e.g. family separation, divorce, a bereavement, bullying
• academic problems at school
• difficulties with peers

12.3 Concerns about mental health and managing disclosures

A student may choose to speak to a tutor about their mental health. If a student does so it is important that the tutor is calm, supportive and non-judgmental. They should listen, rather than advise. Confidentiality should not be promised as the tutor will need to seek advice and guidance about support for the student.

Any tutor who receives a disclosure about mental health or has concerns that a student is suffering from mental health problems must report this to the DSL immediately and complete a Keystone Safeguarding Report Form, as outlined in the processes below. It is important to discuss issues with the DSL first, before speaking to parents. If any student is at immediate risk of harm or requires medical attention, then the emergency services should be contacted immediately by telephoning 999.

Further information can be found at:

• https://youngminds.org.uk/

13. How safeguarding concerns may be discovered

• The student may reveal something of concern as they chat to you without realising they are disclosing significant information
• You may witness or hear something during a child's play, common in younger children
• Student may tell you directly – known as a disclosure
• Another adult may tell you of a concern
• You may see a mark or injury
• You may notice a change in behaviour/mood
• You may witness the action of a parent/carer or other adult
• Non-verbally in written work or art work

This list is not exhaustive and tutors must be alert to any signs which may indicate that a student is at risk.

14. Respond

Procedures for tutors if a student discloses safeguarding information

If a student discloses information which raises safeguarding concerns the tutor should:

• Stay calm – keep responses neutral
• Listen carefully and believe the child, try not to interrupt
• Reassure the student that he/she is right to tell you and is not to blame.
• Never promise confidentiality Find an appropriate point early on to explain that it is likely that the information will need to be shared with others – do not promise to keep secrets.
• Do not cross question the student. Only ask open-ended questions to clarify information. Do not press for further information. The student may need to be interviewed by a specialist later and too much questioning may prejudice later investigations.
• Do not attempt any examination or look further at an injury. Under no circumstances should photographs be taken of a student's injury.
• Do not attempt to investigate matters further; the tutor's role is to listen, record and report concerns to the DSL.
• Tell the student what you will do next and with whom the information will be shared. If they are adamant that they do not wish the information to be shared, explain that you will have to tell the DSL (or Deputy DSL) and that it will be discussed further with them.
• Do not speak to parents yourself, first seek advice from the DSL
• Keep matters confidential and do not speak to others about the matter unless directed to do so by the DSL
• Inform the DSL as soon as possible and no later than the next working day

Possible feelings

It is always difficult to hear about or witness possible harm or abuse experienced by a child or young person. You may also experience the following feelings when information is made known to you.

• Am I imagining it?
• Am I misinterpreting the situation?
• Am I being over anxious?
• Might I make matters worse?
• Will parents be upset if they know I have raised concerns?
• What if I'm wrong?

These feelings must not stop you acting if you have concerns. It is important to report your concerns and the DSL will decide if further action needs to be taken.

15. Report

It is not the responsibility of an employee or a self-employed Keystone Tutor to decide if child abuse is occurring or if a child is suffering from mental health problems, nor is it their role to investigate matters. However, it is their responsibility to report any concerns they may have without delay.

Safeguarding concerns MUST be reported immediately (or where this is not possible at the earliest opportunity) so that the report can be assessed, and action taken to protect the student involved.

If any student is at immediate risk of harm or requires medical attention, then the emergency services should be contacted immediately by telephoning 999

If a member of the public, parent/guardian, police or Local Authority Services reports a safeguarding concern to a Keystone Tutor then the matter must be referred to the DSL or Deputy DSL no later than the same working day.

If for any reason the DSL or Deputy DSL cannot be contacted, the following organisations can be contacted for advice:

• Concern about a child - You should contact the Local Authority Children's Services Department for the area in which the child lives.
• Local Police - Telephone 101 for non-emergency referrals and 999 for emergency response.
• NSPCC Helpline (0808 800 5000 help@nspcc.org.uk).

16. Record

It is important to keep an accurate written record of any safeguarding concern that you have or that someone raises with you. The following guidelines should be followed.

1. All concerns must be recorded on the Keystone Safeguarding Report Form (Appendix 1)
2. A record of the concern must be completed by the person who witnessed the behaviour, received the information or listened to the student. It must be dated and signed.
3. It should be made as soon as possible after the event/concern is raised.
4. Names and not initials should be used and the role of the person identified e.g. tutor, parent
5. The record should be completed as soon as possible after speaking to the student so the student is not alarmed by notes being taken. It is important to record as much as can be remembered, using the student's own words.
6. The record must contain all the known facts so the DSL receives a clear account of what has initiated the concern.
7. The record must be clear and concise, stating the facts. Do not add opinions or personal feelings about what has been heard/witnessed. You are not there to judge or ascertain whether what you are being told is correct.
8. The record must be specific about what has happened or been said. Avoid terms such as ‘inappropriate behaviour/language’
9. On receipt of the completed safeguarding report, the DSL will record the action taken and this must also be signed and dated.
10. The person making the report will be informed by the DSL of the action taken.
11. The DSL action will depend on the nature of the concern. It may include one or more of the following:
    • No action
    • monitoring the situation with a review date
    • a discussion with parents
    • consultation with Keystone's external safeguarding advisor and/or the NSPCC helpline to ascertain appropriate action
    • advice/referral to Children's Services
    • referral to the LADO
    • report to the police

All Safeguarding Reports must be emailed to: safeguarding@keystonetutors.com

Safeguarding records are stored securely and are reviewed annually by the DSL to ensure accuracy, confidentiality, and compliance with data protection standards.

17. Online Safety and Remote Tutoring

All online tutoring must take place on secure, monitored platforms approved by Keystone. Tutors must refrain from private communication with students outside authorised systems. Keystone ensures that filtering and monitoring measures are in place and offers training on recognising online risks, including cyberbullying, grooming, misinformation, and AI-generated content.

18. Confidentiality and sharing information

Effective and timely sharing of information is essential for the early identification of a child's needs. Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare and protect the safety, of children, which must always be the paramount concern. The Data Protection Act (2018) and/or the General Data Protection Regulations (2018) do not prevent the sharing of information related to safeguarding.

The DSL will record the decision-making around the need to share information.

Guidance states that any information shared should be:

1. Necessary and proportionate - Any information shared must be proportionate to the need and level of risk.
2. Relevant - Only information that is relevant to the purposes should be shared with those who need it.
3. Adequate - Information should be adequate for its purpose. Information should be of the right quality to ensure that it can be understood and relied upon.
4. Accurate - Information should be accurate and up to date and should clearly distinguish between fact and opinion. If the information is historical then this should be explained.
5. Timely - Information should be shared in a timely fashion to reduce the risk of harm.
6. Secure - Wherever possible, information should be shared in an appropriate, secure way.

The DSL or Deputy DSL and Company Director must always be contacted before any information is shared with an external organisation except in cases where there is a risk of immediate or serious harm and an emergency referral is necessary. The DSL or Deputy DSL will manage the process of sharing information with the police, local authority services and/or any third-party organisation.

Information should be kept confidential and should only be shared with Keystone Tutors staff members and those working on their behalf who need to know the information. If there is any doubt about whether to share information, the DSL should be contacted for advice by telephoning or emailing before disclosing any information.

19. Safeguarding concern – process

The following flow chart highlights the core procedures within Keystone Tutors for any safeguarding concerns or concerns about a child's mental health.

Safeguarding Concern - Process

1. Employee, Keystone Tutor, Self-Employed Tutor or any third party have a concern about a child or the conduct of an adult. (Is the child in immediate threat of harm or need urgent medical treatment? If yes, dial 999.)
2. Notify Keystone Designated Safeguarding Lead without delay and before talking to parents – Ed Richardson (or Deputy DSL Imogen Drummond-Smith). Telephone: 020 760 25310. Email: safeguarding@keystonetutors.com
3. Complete the Safeguarding Report Form.
4. Designated Safeguarding Lead or Deputy Reviews Safeguarding Report. The DSL may take one or more of the following actions:
   • No action required.
   • Discussion with parents/carers
   • Monitor situation – detailing a review date, possible discussion with parents/carers
   • Makes a Referral and/or takes advice from Children's Services
   • Referral to the LADO if it is an allegation against an adult and/or Police if a criminal offence has been committed

20. The Role of the Designated Safeguarding Lead and Deputy DSL

1. To be responsible for all matters relating to safeguarding and to be the first point of contact and advice for staff, self-employed tutors, parents, students and external agencies.
2. To keep detailed, accurate records, including records of any action taken.
3. To monitor the confidentiality, keeping and storage of records in relation to safeguarding. Access being restricted to the DSL and Deputy DSL.
4. The DSL and Deputy DSL will receive training every two years in inter-agency working and will have annual updates.
5. The DSL will ensure all Keystone staff including self-employed tutors receive safeguarding training when joining the company and that this training is updated every three years, with an annual reminder.
6. To ensure that all staff and tutors, including self employed tutors, have been provided with a copy of the Keystone Tutors Safeguarding Policy and KCSIE Part 1 and Annex A, and have understood the contents.
7. To liaise with, and report any concerns about students, to the local authority of where the student resides.
8. To report any allegations made about staff or tutors of Keystone Tutors to the Local Authority Designated Officer (LADO) for Hammersmith & Fulham
9. The DSL or Deputy DSL role is not to investigate the concern reported or to make judgements about any allegations but to ensure that appropriate referrals are made to statutory agencies and any effective internal action is taken.

21. The DSL's Management of Safeguarding Reports or Allegations

When a safeguarding concern or allegation has been reported to the DSL or Deputy DSL he/she will:

• Assess the information received
• Identify any risks to individuals contained within the report
• Decide if any emergency action is needed and take such action if it is required
• Decide whether a referral to the Local Authority and/or police is required
• Decide what further action by Keystone Tutors may be needed for the management of the concern

The action taken may include:

• taking no action
• a discussion with parents/carers
• monitoring the situation with a set review date
• consultation with Keystone's external safeguarding advisor and/or the NSPCC helpline to ascertain appropriate action
• a referral to children's social care and/or the police
• a referral to the LADO and/or the police

Whatever decision is taken the DSL will record this together with a rationale, even if no further action is to be taken. A decision to take no further action, monitor, or defer a decision is taken as seriously as a decision to make a referral.

Any referrals to statutory services must be made by the DSL or Deputy DSL without delay and no later than the next working day, unless it is an emergency.

Any referrals to statutory services must be followed up in writing according to local requirements and feedback received/sought within 3 working days of having made the referral to check what action is being taken. It is the responsibility of the DSL to ensure this takes place and to ensure that comprehensive records are maintained.

Each local authority has a process for receiving referrals about children and Keystone Tutors must use the relevant process according to the borough where the child primarily resides.

The referral process outlined in this policy is also followed when there are concerns about a student who may be at risk of radicalisation.

22. Communication with Parents/carers

1. Keystone Tutors follows the statutory guidance for schools in respect of reporting to the Local Authority and/or police any case of suspected abuse or allegations of inappropriate conduct.
2. Parents/carers are aware of this policy as it is published on the Keystone Tutors website.
3. Keystone Tutors aim is to work with parents in a supportive manner; however, it will always put the duty of care to the student as its priority and will refer concerns if it believes a student may be at risk of harm or has suffered harm.
4. The DSL will normally request a meeting with the parents of the student about whom there are concerns to discuss the matter. He will explain the reasons for the concerns and the course of action that he intends to take.
5. Referrals to Children's Services or the LADO (or initial advice from either service) do not require prior parental consent. The DSL must act in the best interests of the student, even if this results in making a referral against the parents' wishes.
6. If the DSL believes that notifying parents might in any way increase the risk to the student or if there are any other extenuating circumstances, initial advice will be sought from Children's Services prior to notifying the parents. This may result in an immediate referral to Children's Services without parents being notified.
7. If there is an allegation which involves a member of staff, parents will only be informed after the school has consulted with the LADO and has obtained the LADO's consent. If a parent has any safeguarding concerns he/she should contact the Keystone DSL as soon as possible.

23. Escalation

If, after reporting a concern, it is evident that the local authority or other agency has not taken appropriate next steps, then the DSL or Deputy DSL will determine if the matter needs escalating.

A record of any decisions and outcomes must be kept by the DSL or Deputy DSL.

Similarly if a member of staff or tutor believes the DSL has not taken the correct course of action he/she should press for the DSL to reconsider the matter. If still not resolved, the member of staff may make the referral to the Local Authority. This policy requires that all referrals are made by the DSL of Keystone Tutors; however, anybody can make a referral and in exceptional circumstances staff or tutors may raise concerns directly with Children's Services. If, at any point, there is a risk of immediate serious harm to a student a referral should be made to Children's Services or the police immediately.

24. The Keystone Professional Code of Conduct

The Keystone Professional Code of Conduct outlines the behaviour expected of employees and self-employed tutors of Keystone Tutors. Following this Professional Code of Conduct helps to protect children from abuse and reduces the risk of an allegation of impropriety against a tutor.

Any breach of the Professional Code of Conduct must be reported to the DSL or Deputy DSL. Serious breaches of the Code may also result in a referral being made to the police, and/or Local Authority if it is thought the breach amounts to a risk of harm to a child and/or constitutes a criminal offence.

25. Allegation or concern about the conduct of an employee or self-employed tutor

As part of its overall safeguarding ethos, Keystone ensures that it promotes an open and transparent culture in which all staff feel confident to report concerns about adults working with children and young people.

All staff and tutors must follow the Professional Code of Conduct and always conduct themselves in a professional manner, both to ensure the safety of the pupils, and to reduce the risk of any allegation of improper behaviour.

If any allegation of abuse or suspected abuse is made against a member of staff or tutor, Keystone will follow the guidance in Part 4 of KCSIE and the procedures of Hammersmith & Fulham SCP.

Allegations that might indicate that a person is unsuitable to work with children are where a person 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.

Any concern about a tutor or a member of staff's behaviour must, like all other concerns, be reported to the DSL or Deputy DSL and recorded on a Safeguarding Form. Never think that grooming or abusive behaviour by an adult is not possible, or immediately dismiss an accusation about someone because you think you know them well.

Any such allegations will be discussed with the Local Authority Designated Officer for Hammersmith and Fulham. Keystone Tutors will not determine the threshold for what is to be reported.

If there is an allegation, the priority will be to resolve the matter in a fair and consistent way, ensuring effective protection for any student involved, and where possible, supporting the person against whom the allegation has been made.

An assessment of any allegation will be made by the LADO and the DSL. They will judge whether there is a need for immediate action, whether the allegation is demonstrably false or whether there has been inappropriate behaviour or poor practice that can be dealt with through Keystone's own disciplinary procedures.

In the case of an investigation, before contacting any of the parties, the DSL will ensure that there is no objection by the LADO and/or the police.

All tutors and staff should feel able to raise concerns about poor or unsafe practice and that such concerns will be taken seriously.

The NSPCC whistleblowing helpline is available for adults who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285 – lines are available from 8:00am to 8:00pm, Monday to Friday, or email: help@nspcc.org.uk

26. Low Level Concerns about staff or tutors

A low-level concern is described in KCSIE as any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an adult working with children/young people may have acted in a way that is inconsistent with the Professional Code of Conduct, including inappropriate conduct outside of work, and which does not appear to meet the allegations threshold outlined above.

Tutors may also have concerns about how their own behaviour might be interpreted. Examples of such behaviour could include, but are not limited to:

• being over friendly with children
• having favourites
• taking photographs of children on their mobile phone, contrary to school policy
• engaging with a child on a one-to-one basis in a secluded area or behind a closed door, or
• humiliating children.
• Email, messaging, use of social media sites or other communication between adults and students outside agreed protocols
• Any incident where a tutor feels that his/her actions or behaviour towards a student may have been misinterpreted or may have given rise to a risk or misinterpretation.

Tutors must report any low-level concerns whatsoever to the DSL.

Tutors are encouraged, and to feel confident if the need arises, for them to self-refer to the DSL, where, for example, they have found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards.

All low-level concerns will be recorded in writing. The record will include:

• details of the concern;
• the context in which it arose;
• the decision categorising the type of behaviour;
• action taken;
• the rationale for decisions and action taken;
• the name of the individual sharing the concerns (respecting any wish to remain anonymous as far as possible)

The purpose of low-level reporting is to protect both students and the adults working with them and allows a system for a simple record to be kept in case events are later referred to or any patterns emerge.

Anyone who reports a Low-Level concern, or a more serious allegation, in good faith will suffer no detriment as a result.

27. Referral to the Disclosure & Barring Service (DBS) and Teaching Regulation Agency (TRA)

If Keystone Tutors ceases to use the services of any person because that person was considered unsuitable to work with children, a report will be made to the DBS. It also has a legal responsibility to report the matter to the Teaching Regulation Agency (TRA) which may result in a prohibition order being issued by the Secretary of State for Education, as required by sections 141D and 141E of the Education Act 2002. A report to the TRA may also be made for additional reasons ‘unacceptable professional conduct’, ‘conduct that may bring the profession into disrepute’ or a ‘conviction, at any time, for a relevant offence’. Advice about whether an allegation against a teacher is sufficiently serious to refer to the TRA can be found in Teacher misconduct: the prohibition of teachers (October 2015). Further guidance is published on the TRA website.

Policy implementation and review:

This policy was updated on 13th October 2025. This policy will be reviewed on an annual basis and in response to any incident, changes in safeguarding legislation and/or best practice.

Appendix 1 – Safeguarding Report Form

You must report any safeguarding concern to the Designated Safeguarding Lead by telephone as soon as possible and at the very latest by the next working day. Complete as much detail as possible, following the advice in Paragraph 14 above. For further advice about completing this form please contact the DSL or Deputy. If a child or adult is at immediate risk of harm or needs medical attention contact the emergency services on 999.

Part 1. Details of the student:

Name:

Age:

Sex:     Date of Birth:

Home Address:

Additional Needs (e.g. disability):

Parent or Carer(s) name(s) and contact telephone number:

Any other relevant information:

Part 2. If applicable, details of the Keystone Tutors Employee or self-employed tutor about whom the allegation has been made:

Name:

Age:

Role:

Home Address:

Contact Telephone:

Contact Email:

Part 3. Your details (the person making the report)

Name:

Role:

Home Address:

Contact Telephone:

Contact Email:

Date and Time you are making a report:

Date and Time you first received information or identified a concern:

Part 4. Safeguarding Report

Are you reporting your own concerns or responding to concerns raised by someone else?

If responding to concerns raised by someone else please provide their name, role and contact details (if known):

Please add any other relevant information known about the family/child/adult at risk circumstances.

Concern Raised/Allegation: What is the allegation, or the nature of the concern raised? Include as much detail as possible.

Has the child or adult at risk given an account of what happened? (e.g. of any incident, injury, disclosure, behaviour) (give details):

If applicable please provide details of the person alleged to have caused the incident/injury if known (e.g. names(s) /address/ incident address /relationship to child or adult at risk etc.):

Please provide details (name, role contact details if known) of any witnesses to the incident/concerns:

Part 5. Actions taken

State any risk of immediate danger:

Thank you for your report. Please email this form to safeguarding@keystonetutors.com If handwritten please hand to the Designated Safeguarding Lead. To be completed by Designated Safeguarding Lead:

Part 6. Immediate action and decisions by Designated Safeguarding Lead:

Date & Time

Name

Actions/Notes

Appendix 2 – Specific safeguarding issues

Up-to-date guidance and practical support on specific safeguarding issues or concerns will be sought where necessary by the DSL. Extensive guidance on a wide variety of specific issues can be found in Annex B of KCSIE (2024).

1. Bullying and Child on Child Abuse

Bullying is deliberately hurtful behaviour, usually repeated over a period of time, where it is difficult for the victims to defend themselves. The damage inflicted by bullying is often underestimated. It can cause considerable distress to children, to the extent that it affects their health and development and can be a source of significant harm, including self-harm and suicide. Bullying can include emotional and/or physical harm to such a degree that it constitutes significant harm.

The four main types of bullying are:

1. Physical abuse: hitting, kicking, stabbing and setting alight including for filming with mobile telephones and theft, commonly of mobile phones
2. Verbal or mobile telephone / online message abuse (e.g. racist, sexist or homophobic name-calling or threats: this type of physical bullying may include sexual harassment)
3. A mobile telephone or online visual image abuse: can include real or manipulated images
4. Emotional abuse e.g. isolating an individual from the group or emotional blackmail

2. Child on child abuse which involves sexual violence and sexual harassment

(Further detailed information can be found in Annex B of KCSIE)

Tutors must be aware that sexual violence and sexual harassment can also occur between children or groups of children of any age and sex, and within intimate personal relationships between young people. It can also occur online.

Tutors should follow the processes outlined in this policy when dealing with any student who reports sexual violence or sexual harassment.

It is essential that victims are reassured that they are being taken seriously and must never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment, nor should a victim ever be made to feel ashamed for making a report.

When responding to a report of sexual violence or harassment the DSL will decide on the response following the advice in Annex B of KCSIE.

3. Self-harm

Self-harm is any behaviour intended to deliberately cause harm to one's own body. Approximately one in ten young people in the UK engage in self-harming behaviours. This can include cutting, burning, bruising, pulling out hair and unusual eating habits. All tutors should be aware of the signs of self-harm in students. Any tutor who is aware of a student engaging in or suspected to be at risk of engaging in self-harm must refer the matter to the DSL.

4. Female Genital Mutilation (FGM)

Female genital mutilation (FGM) is the partial or total removal of external female genitalia for non-medical reasons. It is also known as female circumcision or cutting. Religious, social or cultural reasons are sometimes given for FGM. However, FGM is child abuse and it is illegal in the UK. There is a mandatory duty on teachers to report cases of FGM to the police if it is believed that an act of FGM has been carried out.

It is essential that staff are aware of FGM practices and the need to look for signs, symptoms and other indicators of FGM, including the reporting of this by younger siblings. Tutors should bring any concerns about FGM, including where there is suspicion a girl may be at risk of FGM being carried out, to the attention of the DSL immediately.

5. Modern Slavery and the National Referral Mechanism

Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. Further information on the signs that someone may be a victim of modern slavery, the support available to victims and how to refer them to the NRM is available in Statutory Guidance. Modern slavery: how to identify and support victims - GOV.UK

6. Anti-radicalisation (Prevent Strategy)

Note: This preventing radicalisation section remains under review, following the publication of a new definition of extremism on the 14 March 2024.

Children are vulnerable to extremist ideology and radicalisation. Similar to protecting children from other forms of harms and abuse, protecting children from this risk is part of a safeguarding approach.

Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. It can also call for the death of members of the armed forces, whether in this country or overseas

Early indicators of radicalisation or extremism may include:

• showing sympathy for extremist causes
• glorifying violence, especially to other faiths or cultures
• making remarks or comments about being at extremist events or rallies
• evidence of possessing illegal or extremist literature
• advocating messages similar to illegal organisations or other extremist groups
• out of character changes in dress, behaviour and child relationships (but there are also very powerful narratives, programmes and networks that young people can come across online so involvement with particular groups may not be apparent.)
• secretive behaviour
• online searches or sharing extremist messages or social profiles
• intolerance of difference, including faith, culture, gender, race or sexuality
• graffiti, art work or writing that displays extremist themes
• attempts to impose extremist views or practices on others
• verbalising anti-Western or anti-British views
• advocating violence towards others

If any concerns arise around radicalisation, or are disclosed by a student, they must be responded to following normal safeguarding processes and advice will be sought by the DSL from the local authority (either the Prevent co-ordinator or Children's Services) if necessary.

7. Domestic abuse

It is important for tutors to recognise that many children may be living (or may have lived) in families where domestic abuse is a factor, and that these situations have a harmful impact on children emotionally, as well as placing them at risk of physical harm. The definition of domestic abuse is;

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

The abuse can encompass, but is not limited to:

1. psychological
2. physical
3. Sexual
4. financial
5. emotional.

Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact. Tutors must report any concerns about this to the DSL.

Where a DSL determines that a student has encountered domestic violence, directly or indirectly, the DSL will immediately discuss the matter and take advice from Children's Services.

8. Children with special educational needs and disabilities or physical health issues

Tutors are made aware that children with special educational needs and/or disabilities as well as other vulnerable groups may be especially at risk of abuse. Such children are also more prone to peer group isolation or bullying. Therefore, extra care should be taken to correctly interpret apparent signs of abuse or neglect, acknowledging that behaviour, mood or injury may relate to possible abuse and not the SEN or disability. Staff should be aware that:

• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child's disability without further exploration
• these children can be more prone to peer group isolation or bullying (including prejudice-based bullying) than other children
• the potential for children with SEND or certain medical conditions being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs
• communication barriers and difficulties in managing or reporting these challenges.
• cognitive understanding – being unable to understand the difference between fact and fiction in online content and then repeating the content/behaviours or the consequences of doing so.

When working with children with special needs all tutors must recognise these additional challenges and be vigilant about safeguarding concerns.

9. Forced Marriage

A Forced Marriage (as distinct from a consensual "arranged" marriage) is defined as one which is conducted without the valid consent of both of the parties and where duress is a factor. Duress includes both physical and emotional pressure and cannot be justified on religious or cultural grounds. Forced marriage is child abuse and can put children and young people at risk of physical, emotional and sexual violence including rape. Forced marriage can have a negative impact on a child's health and development (Forced Marriage Unit, 2018)

10. Child Criminal Exploitation (CCE) and Child Sexual Exploitation (CSE)

Keystone Tutors know that different forms of harm often overlap, and that perpetrators may subject children and young people to multiple forms of abuse, such as criminal exploitation (including county lines) and sexual exploitation. In some cases, the exploitation or abuse will be in exchange for something the victim needs or wants (for example, money, gifts or affection), and/or will be to the financial benefit or other advantage, such as increased status, of the perpetrator or facilitator.

Children can be exploited by adult males or females, as individuals or groups. They may also be exploited by other children, who themselves may be experiencing exploitation – where this is the case, it is important that the child perpetrator is also recognised as a victim.

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur using technology (WTSC, 2023).

11. E-safety and online behaviour

The breadth of issues classified within online safety is considerable, but can be categorised into four main areas of risk:

• content: being exposed to illegal, inappropriate or harmful material
• contact: being subjected to harmful online interaction with other users
• conduct: personal online behaviour that increases the likelihood of, or causes, harm.
• commerce: risks such as online gambling, inappropriate advertising, phishing and or financial scams

Social networking sites and other apps can be sources of risk of inappropriate and harmful behaviour. This includes the risks related to harmful online challenges and hoaxes.

If a tutor suspects that a student may be at risk of or suffering from online harm, they should follow the reporting procedures set out in this policy.

12. Youth produced sexual imagery, nudes/semi-nudes, sexting, upskirting

The practice of children sharing images and videos via text message, email, social media or mobile messaging apps has become commonplace. However, this online technology has also given children the opportunity to produce and distribute inappropriate imagery (nudes, semi-nudes, sexting) in the form of photos and videos. Such imagery involving anyone under the age of 18 is illegal.

Upskirting is also a criminal offence and typically involves taking a picture under a person's clothing (not necessarily a skirt) without their permission and/or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. Anyone of any gender can be a victim.

If a tutor becomes aware of an incident involving inappropriate material they should follow safeguarding procedures and report it to the DSL immediately.

Tutors should not copy or print images, nor forward images by email or any other electronic means as this could constitute a criminal offence.

13. Fabricated Illness

Fabricated or induced illness is a condition whereby a child has suffered, or is likely to suffer, significant harm through the deliberate action of their parent and which is attributed by the parent to another cause.

There are three main ways of the parent fabricating (making up or lying about) or inducing illness in a child:

• Fabrication of signs and symptoms, including fabrication of past medical history;
• Fabrication of signs and symptoms and falsification of hospital charts, records, letters and documents and specimens of bodily fluid
• Induction of illness by a variety of means

Further information may be found at https://www.londoncp.co.uk/fab_ind_ill.html